The AMA Filed a Court Brief Yesterday Asking a Judge to Block the New Medicaid Rule Before Millions Get Notified in August.

The American Medical Association filed a court brief on July 28 urging a federal judge to grant a preliminary injunction blocking the new Medicaid “medically frail” rule before August 31. The brief told the court that without a pause, millions of Medicaid beneficiaries with chronic illnesses will spend August scrambling to prove their conditions meet a standard the AMA and 26 states argue was never authorized by Congress.

The case is Commonwealth of Massachusetts et al. v. Oz et al., filed in the U.S. District Court for the District of Massachusetts. The rule at issue - CMS’s Interim Final Rule implementing Medicaid work requirements - became final on July 31. States must notify enrollees about changes to the medically frail exemption by August 31.

What the AMA’s Brief Argued

The AMA told the court that the CMS rule’s “significant impairment” test creates a burden for people with cancer, diabetes, heart disease, and other serious conditions that the original statute did not require. “If the judge doesn’t pause parts of CMS’ interim final rule,” the AMA stated, “millions of Medicaid beneficiaries will be running to their providers in August to help them understand CMS’ impermissibly narrow exclusion.”

The AMA entered as an amicus - a friend of the court - supporting the coalition of 26 states and the District of Columbia that filed the underlying lawsuit in late June. The plaintiff states argued that CMS changed the rules mid-implementation, after states had already spent months and money building systems based on different guidance. California’s attorney general noted that Medi-Cal had “relied extensively” on preliminary CMS guidance before the June 3 rule reversed course.

The August 31 Deadline the Court Must Beat

States face two sequential deadlines: August 31 to notify enrollees of changes to the medically frail exemption, and January 1, 2027 for the full work requirements to take effect. The preliminary injunction request asks the court to block the contested portions of the rule before the August 31 notifications go out. If the injunction is not granted in time, states will send notices under a definition of medical frailty that the court may ultimately strike down - creating a second disruption when any ruling arrives.

The Urban Institute projected that work requirements could cause 3 to 7 million Medicaid expansion enrollees to lose coverage. The CMS itself projected the requirements would reduce Medicaid enrollment by approximately 2.3 million individuals in FY 2027.

The Ruling the Court Must Make

The court will weigh the states’ and AMA’s likelihood of success on the merits, the irreparable harm argument, and the public interest. The August 31 deadline constrains the timeline. No ruling date has been publicly announced. The injunction motion, if granted, would pause the contested rule provisions while the case proceeds. If denied, the rule and its notification requirements go forward as written.

References: AMA To Court: Promptly Grant States’ Injunction Request In Medicaid Work Req Lawsuit | AG Campbell Sues Trump Administration Over Unlawful Medicaid Work Requirements Rule | Medicaid Work Reporting Requirements: States Ask a Federal Court to Protect Medically Frail Individuals