Medicaid Work Requirements

On June 29, 2026, a coalition of 25 attorneys general filed a lawsuit in Massachusetts against the Trump Administration for its unlawful implementation of new Medicaid work requirements included in the One Big Beautiful Bill Act and implemented through an interim final rule.

We argue that the interim final rule:

• Unlawfully narrows Congress's protections for medically frail Medicaid recipients.
• Violates the Administrative Procedure Act by ignoring substantial evidence that work reporting requirements cause eligible individuals to lose healthcare coverage because of administrative barriers rather than failure to work.
• Fails to adequately consider the significant harms that will be imposed on states, Medicaid beneficiaries, healthcare providers, and state healthcare systems.
• Unconstitutionally coerces states by imposing new compliance requirements after states had already begun implementing the One Big Beautiful Bill Act based on the statute’s plain language and CMS's prior guidance.

Massachusetts, et al v. Oz