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Massachusetts Medicaid guidance still lists a work exemption test a federal judge blocked

Roughly 360,000 MassHealth members could face new reporting obligations for work and education.

A healthcare professional reviewing medical paperwork with a patient.

Photo Credit: iStock

Massachusetts' online Medicaid guidance still describes a work-exemption test that a federal judge blocked, raising questions about how the state will apply the ruling.

Showing how a condition affects work capacity remained a possible requirement for some MassHealth members with disabilities or addictions as of Oct. 30.

Here's what to know

Being classified as "medically frail" exempts people from new Medicaid work requirements. A federal court rejected a standard from President Donald Trump's administration that restricted eligibility for that classification, This Week in Worcester reported.

Judge Stearns determined that the Centers for Medicare & Medicaid Services had exceeded its authority by adding restrictions to the exemption.

In Stearns' reading, the five qualifying categories Congress listed established a minimum level of protection that CMS could not reduce. Substance use disorders and serious or complex medical conditions were among those categories.

A six-month stay covers determinations of whether someone qualifies as medically frail. The court also blocked the additional test in the June 3 interim final rule, which required a person's condition to substantially interfere with meeting work obligations.

More background

Jan. 1, 2027, is the scheduled start of the work requirements enacted through the One Big Beautiful Bill Act. President Donald Trump signed that law on July 4, 2025.

Under the law, certain adults receiving Medicaid must work or perform community service for 80 hours monthly, or attend an educational program at least half-time, according to This Week in Worcester.

Massachusetts Gov. Maura Healey's office estimates that roughly 360,000 MassHealth members could face new reporting obligations for work and education beginning on Jan. 1, 2027.

Stearns found the government's explanations sufficient to support both a 12-month claims review and a once-per-enrollment limit on self-attestation. He upheld those provisions and rejected the states' two other challenges.

What's being done?

The lawsuit was co-led by Massachusetts Attorney General Andrea Joy Campbell, California Attorney General Rob Bonta and New Jersey Attorney General Jennifer Davenport. Campbell announced the ruling.

Together, they represented a coalition comprising two governors and 24 attorneys general challenging the administration's requirements, This Week in Worcester reported.

The states sought no postponement of the Jan. 1 start date, which remains in place despite the ruling — the six-month stay concerns medically frail determinations, not the broader implementation schedule.

Campbell's office did not address how the program's exemption process would change following the decision.

"This victory protects access to healthcare for residents with serious illnesses and disabilities and ensures their care won't be interrupted due to unlawful red tape," she said.

Where can I learn more?

The questions about MassHealth exemptions come amid other changes to health coverage and care in Massachusetts and beyond. These stories examine Medi-Cal reporting rules, Massachusetts Medicaid losses, rural hospital funding, and Health Connector costs.

• More than 1 million Los Angeles County residents may face Medi-Cal work-proof requirements.

• Massachusetts will end full Medicaid coverage for 7,300 documented immigrants amid regional losses.

• Six rural Massachusetts hospitals could receive funding for upgrades through a $162 million fund.

• Massachusetts Health Connector users face double-digit premium increases and dropped plans as enrollment opens.

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