A federal judge on July 29 denied a request from 25 states and Washington, D.C., to temporarily block parts of the Trump administration’s Medicaid work requirement rule.
Six things to know:
1. U.S. District Judge Richard Stearns denied the states’ motion for a preliminary injunction, finding they had not shown they were likely to suffer irreparable harm before the case is resolved. The denial was issued without prejudice, meaning the states may renew their request under certain circumstances.
2. The states sued CMS, HHS and administration officials June 29 over a June 3 interim final rule implementing community engagement requirements under HR 1.
3. The lawsuit challenges the rule’s inclusion of a work-related limitation in the definition of “medically frail,” its use of a 12-month look-back period when evaluating medical frailty and its imposition of a work requirement on a short-term hardship exemption tied to emergency declarations.
4. The states argued they would incur unrecoverable staffing and system costs while making changes needed to comply with the rule. Mr. Stearns said the federal government has represented that it will reimburse 90% of states’ costs to design, develop and install eligibility systems.
He was also not persuaded that the remaining costs justified the “extraordinary” remedy of a preliminary injunction. On the remaining 10% of costs, Mr. Stearns said the states’ main complaint was the tight compliance timeline. He noted that Congress — not CMS — established the implementation timeline.
5. The ruling does not resolve the merits of the lawsuit. Mr. Stearns said the case raises “difficult issues” involving the scope of authority Congress delegated to HHS and whether the agency’s rule is consistent with congressional intent.
The court said those questions should be addressed using a more developed evidentiary record at the summary judgment stage.
6. The court plans to establish an expedited briefing schedule so the case’s merits can be considered before the Jan. 1, 2027, implementation deadline. The states may seek emergency relief again if briefing is delayed beyond Dec. 31 through no fault of their own and the administration does not postpone implementation.
The plaintiffs include Massachusetts, California, New Jersey, Arizona, Colorado, Connecticut, Delaware, Washington, D.C., Hawaii, Illinois, Kentucky Gov. Andy Beshear, Maine, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Pennsylvania Gov. Josh Shapiro, Rhode Island, Vermont, Virginia, Washington and Wisconsin.
At the Becker's 5th Annual Fall Payer Issues Roundtable, taking place November 2–3 in Chicago, payer executives and healthcare leaders will come together to discuss value-based care, regulatory changes, cost management strategies and innovations shaping the future of payer-provider collaboration. Apply for complimentary registration now.
