WASHINGTON, D.C. – Late Tuesday, the American Cancer Society Cancer Action Network (ACS CAN), along with 31 partner organizations, filed an amicus curiae brief with the U.S. District Court for the District of Maryland in the case of Taylor v. Kennedy. The litigation was filed on behalf of individuals with Medicaid coverage, healthcare providers and the City of Columbus challenging the Interim Final Rule (IFR) on Medicaid work requirements released by the Centers for Medicare and Medicaid Services in June 2026. This rule unlawfully narrows the exemption from work requirements for “medically frail” individuals provided by Congress in the One Big Beautiful Bill Act (OBBBA) passed in 2025. Such a narrow definition will be detrimental to patients who have no other option for affordable, comprehensive coverage.
The brief highlights how Medicaid coverage critically affects health outcomes, that the IFR improperly burdens the very patients Congress intended to exclude from Medicaid work requirements, and that the bureaucratic barriers imposed by the IFR will result in significant coverage losses.
Below is an excerpt from the brief.
“The Rule improperly burdens individuals with ‘serious or complex medical condition[s],’ by erecting roadblocks between them and a work-requirement exclusion Congress provided. And, as amici explain, Congress excluded such individuals for good reason: people with serious or complex health conditions experience routine disruptions to their ability to work, making case-by-case evaluation unnecessary.
“The upshot of the Rule will be loss of coverage for seriously ill Medicaid recipients. Indeed, many Medicaid recipients who unquestionably cannot work under any standard will nonetheless lose coverage due to their inability to submit the paperwork required to meet the Rule’s bureaucratic and confusing requirements.
“Amici have a strong interest in avoiding that outcome and protecting Medicaid recipients from losing coverage…
“…The impact of a loss in coverage, especially for patients with life-threatening diseases, is significant. Patients with serious conditions who rely on Medicaid will either have to forgo lifesaving treatment or take on significant debt to receive it. Even short gaps in coverage can put patients at serious risk. This upends Medicaid’s benefits and undermines Congress’s purpose in excluding such individuals from the new work requirement.”
The groups listed on the amicus brief include;
Access Ready Inc.
American Cancer Society
American Cancer Society Cancer Action Network
American Diabetes Association
American Heart Association
American Network of Community Options and Resources (ANCOR)
American Society of Clinical Oncology
Arthritis Foundation
Autistic Self Advocacy Network
Autistic Women & Nonbinary Network
Bazelon Center for Mental Health Law
Blood Cancer United
Cancer Nation
Cancer Support Community
CancerCare
Crohn's & Colitis Foundation
Cystic Fibrosis Foundation
Disability Rights Education and Defense Fund (DREDF)
Epilepsy Foundation of America
Justice in Aging
Legal Action Center
Lupus Foundation of America
Muscular Dystrophy Association
National Academy of Elder Law Attorneys
Susan G. Komen Breast Cancer Foundation
The AIDS Institute
ZERO Prostate Cancer
The groups are represented by the law firm of Morrison Foerster.