Court strikes ‘medically frail’ definition in Medicaid community engagement requirements 

The U.S. District Court for the District of Massachusetts yesterday ruled in favor of 25 states and the District of Columbia to vacate the Centers for Medicare & Medicaid Services’ definition of “medically frail” from its Medicaid community engagement requirements. The definition would have required medically frail individuals to demonstrate they had a qualifying condition that significantly impairs their ability to comply with the community engagement requirements. The requirements call for certain adults to complete 80 hours per month of “qualifying activities,” such as employment, education, community service or participation in a work program, or meet equivalent income thresholds. In the decision, District Judge Richard Stearns said CMS went beyond its scope in authorizing the provision and narrowing the definition of “medically frail.”  

“Because enforcement of an unlawful definition of ‘medically frail’ may lead to the disenrollment of otherwise eligible vulnerable individuals relying on Medicaid coverage for continuity of care, the States (and public) face potential for great hardship in the absence of an injunction,” Stearns wrote. The remaining provisions under the community engagement requirements will be enforced beginning Jan. 1, 2027. 

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