A group of 47 senators — 45 Democrats and two independents — submitted a letter to the Centers for Medicare and Medicaid Services urging the Trump administration to withdraw the interim final rule relating to Medicaid work requirements.
The One Big Beautiful Bill Act (H.R. 1) created a mandate — effective January 2027 — that will require Medicaid members ages 19 to 64 covered through the Affordable Care Act Medicaid expansion to prove 80 hours per month of employment, education or volunteering.
However, via an interim final rule announced in June, CMS took this a step further by adding conditions to the medical frailty exemption from the work requirements. The new rule now requires that medical frailty be limited to situations in which a person’s condition impairs their ability to meet the work requirement. This means it’s not enough to merely have one of these conditions to qualify for an exemption; beneficiaries have to prove to state authorities that their condition is serious enough that they can’t fulfill the requirements.
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“This rule transforms Medicaid from a health care program into a bureaucratic maze that will fail eligible Americans,” the senators said in the letter. “It will strip coverage not because people are not already working or refuse to work, but because they cannot navigate a complex web of forms, passwords, and deadlines. Implementing ineffective, exclusionary work reporting requirements will create costly administrative barriers and deny Americans access to health care, resulting in poorer health, higher mortality, and reduced financial security.”
The senators argue that states and individuals will face significant challenges when it comes to the new conditions on medical frailty. States won’t be able to rely on automation and will need to revamp IT systems and add new staff, while individuals will have to prove that they are “sick enough” to qualify for exemption.
“In practice, a person in the middle of a mental health crisis or a course of cancer treatment, or someone managing severe substance use disorder, will be forced to secure explicit provider attestations linking their illness to their capacity to work. If they cannot jump through this hoop, the penalty is severe: they are cut off from the very medical care they need to survive,” the letter said.
The senators also said that they support a full repeal of the One Big Beautiful Bill Act’s Medicaid cuts, but in the absence of Congressional action on this repeal, they urge CMS to delay implementation of these cuts.
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The letter notes that 92% of adults with Medicaid are already working, going to school, caregiving or have a disability. In addition, it states that an assessment of H.R. 1 by the Congressional Budget Office estimated that 5.3 million enrollees will lose coverage by 2034 without even accounting for the changes in the interim final rule.
The senators also argue that the interim final rule ignores states’ previous experiences with work requirements. For example, Arkansas implemented these requirements and 18,000 people lost coverage in five months.
“They didn’t lose their Medicaid coverage because they suddenly found jobs with health benefits; they lost it because they didn’t have internet access, never received the notices, or couldn’t log into a glitchy state website,” the senators said.
In addition, the letter states that implementation costs may exceed federal funding. The senators argue that the $200 million provided by Congress for system upgrades is insufficient, noting CMS estimates states may spend nearly $700 million on required system changes.
“Implementing this rule will worsen Americans’ overall quality of health, waste millions of dollars on administrative red tape, and cause preventable health emergencies for all Americans. This rule does not strengthen Medicaid; it dismantles it, turning a program designed to protect vulnerable Americans into a system that systematically denies them care,” the senators said.
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