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BALTIMORE, MD – Attorney General Anthony G. Brown secured a decision by the U.S. District Court for the District of Massachusetts finding the Trump administration’s implementation of new Medicaid work requirements under the “One Big Bill Act” unlawful.
The ruling will likely protect thousands of Medicaid recipients in Maryland, as the state previously estimated that an estimated 150,000 Marylanders, or 45% of adults covered through the state’s Affordable Care Act Medicaid expansion, could lose coverage due to the requirements imposed under the rule. The Court’s ruling will likely spare the state significant administrative costs, as the rule was previously estimated to impose $2 million in such additional burdens.
In a lawsuit filed in June 2026, Attorney General Brown joined a multistate coalition in challenging provisions of an interim final rule, which adopted a new interpretation of key terms like “medically frail,” making it harder for medically vulnerable individuals to be excused from the work requirements. In the decision, the District Court held that the Trump administration’s definition of “medical frailty” is unlawful. The Court struck down the definition, issued a permanent injunction, and granted the coalition states a six-month stay of enforcement to accommodate any errors or delays resulting from the necessary changes to implementation.
“The Trump Administration's unlawful policy would force people who are fighting just to stay alive to meet work requirements or lose their health coverage,” said Attorney General Brown. “By securing this victory, our Office is protecting Marylanders who are managing a wide range of serious health conditions, including physical and developmental disabilities.”
Medicaid is the nation’s safety net healthcare program for low-income Americans and is jointly funded by states and the federal government, with the federal government providing at least 50% of the cost of services. Congress created exemptions from Medicaid’s work requirements to ensure that people with serious illnesses and disabilities do not lose coverage or face interruptions in care.
Earlier this year, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule that makes it harder for medically vulnerable individuals to be excused from the work requirements and makes other changes that increase administrative burdens, create unnecessary red tape, and put eligible people at risk of losing their health coverage – including those who are already working or qualify for an exemption. The coalition argued that the rule disregarded substantial evidence that should have been considered, failed to adequately evaluate reasonable alternatives, and did not give states clear or workable guidance.
Past Medicaid work requirement programs have shown that added bureaucratic red tape causes eligible people to lose coverage, placing greater strain on state Medicaid programs, safety net providers, and emergency rooms, while increasing costs as more medically frail residents become uninsured.
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