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Medicaid and Medicaid Frailty

September 10, 2026

The One Big Beautiful Bill Act (OBBRA) includes provisions requiring individuals who receive insurance coverage through the Patient Protection and Affordable Care Act (ACA) Medicaid expansion to complete at least 80 hours per month of work or other qualifying community engagement (known as “Medicaid work requirements”). The statute includes an exemption for “medically frail” individuals. However, the Interim Final Rule (IFR) implementing the work requirements greatly narrows the definition of medically frail, making it more difficult for patients to qualify for the exemption.  

States sued to vacate the IFR in Massachusetts v. Oz.  ACS CAN joined an amicus brief supporting the plaintiff states. The brief supports the plaintiff states by providing historical context on how Congress structured Medicaid to ensure early, broad, and continuous coverage of medically frail individuals, illustrates how the IFR’s restrictions will result in substantial coverage losses, shows that conditions that render individuals medically frail vary widely, how continuous coverage is required to manage them, and why the IFR creates another barrier to health care for low-income people with serious health conditions. To read the press release and ACS CAN’s extensive comments objecting to the rule, click here.