Trump administration’s definition of ‘medically frail’ unlawful, according to federal judge

A federal judge Thursday ruled that the Trump administration’s definition of “ medically frail ” used for Medicaid is unlawful, issuing a temporary injunction on states having to determine medical frailty.

U.S. District Judge Richard Stearns found in his ruling Thursday that the One Big Beautiful Bill Act’s definition of “medically frail” was “contrary to law” and that demands by plaintiff states to have it vacated were warranted.

The One Big Beautiful Bill passed last year included a new definition of “medically frail” that would exempt a Medicaid beneficiary from work requirements .

In order to be considered medically frail under the One Big Beautiful Bill, a beneficiary had to establish they had a “physical, mental, or other behavioral health condition” that “significantly” impaired their “ability to comply with the community engagement requirement.”

Prior to this, a person was considered medically frail if they met the Social Security definition of having a disability; had a substance use disorder; a disabling mental health condition; a physical, intellectual, or developmental disability that impaired their ability to perform basic activities or living; or a serious medical condition.

While the One Big Beautiful Bill did not eliminate these conditions, critics argued that having to also demonstrate a health condition “significantly impairs” a person’s ability to work was overly burdensome and threatened continued access to care.

The Centers for Medicare and Medicaid Services (CMS) issued an interim final rule in June explaining to states how they should implement new Medicaid work requirements. The interim final rule limited the ability of states to rely on medical records to confirm medical frailty, only allowing them to use claims and encounter data from the 12 months preceding an application.

Critics argued that many patients who have been living with long-term or lifelong disabilities probably did not have a recent diagnosis confirming their disability.

Stearns agreed with plaintiff states’ argument that the 12-month rule was “arbitrary or capricious.”

“The States have met their burden of showing irreparable harm for which monetary damages would provide inadequate compensation – they face the burden of costly and intensive alterations to their eligibility verification system,” Stearns wrote.

The judge also issued a six-month stay on enforcement of states having to determine whether someone counts as medically frail, citing the short amount of time states have had to change their verification systems.

Medical groups welcomed news of the ruling Thursday.

“Today’s decision is a victory for patients as it strikes back against unnecessary barriers to care. The court rightly rejected a federal restriction that would have made it harder for people with serious or complex health conditions to qualify for an exemption from Medicaid work requirements,” Willie Underwood, president of the American Medical Association (AMA), said in a statement.

“Patients should not have to clear unnecessary bureaucratic hurdles to keep their health coverage, especially hurdles that go beyond what Congress intended,” said Underwood. “The AMA will continue fighting to protect access to medically necessary care and ensure bureaucratic red tape doesn’t stand in patients’ way.”

New York Attorney General Letitia James (D) said in a statement, “New Yorkers who are living with cancer, a disability, a serious mental health condition, or addiction should never have to prove they are sick enough to keep their health care. The more barriers to coverage there are, the less healthy our communities become. I am pleased to have secured this potentially life-saving relief for some of our most vulnerable New Yorkers.”

The Hill has reached out to the Department of Health and Human Services for comment.