The suit names HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Mehmet Oz as defendants. Co-leads include Massachusetts Attorney General Andrea Joy Campbell and New Jersey Attorney General Jennifer Davenport, with participation from attorneys general in Arizona, Colorado, Connecticut, Delaware, D.C., Hawaii, Illinois, Maine, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, Virginia, Washington, and Wisconsin, plus governors of Kentucky and Pennsylvania. Plaintiffs argue the rule illegally narrows protections for medically frail Medicaid recipients, violates the Administrative Procedure Act by disregarding evidence that work reporting causes coverage loss through administrative barriers, and unconstitutionally coerces states with new compliance requirements imposed after they began implementing the 2025 law.
The One Big Beautiful Bill Act, passed in 2025, requires Medicaid expansion enrollees aged 19–64 to work or perform community service 80 hours monthly, or attend school half-time, beginning January 1, 2027. While the statute exempts medically frail individuals—defined as those with substance use disorders, disabilities, or serious medical conditions—the CMS rule narrowed this exemption to require conditions that "significantly impair" ability to work, volunteer, or attend school at required levels. The rule requires beneficiaries to attest to this definition in 2027 and once in 2028, but demands proof of impairment when renewing coverage in 2028, creating substantial new barriers for vulnerable populations.
The filing comes as states race to implement new Medicaid systems before the January 1, 2027, deadline. Plaintiffs warn the rule will generate unnecessary bureaucracy and cause eligible individuals to lose coverage due to administrative obstacles rather than actual work failures, placing medically frail people—including those with cancer, disabilities, and substance use disorders—at risk of losing health coverage. The coalition characterizes the rule as creating harmful coverage barriers and implementation chaos precisely when states face strict compliance deadlines.