On June 29, 2026, California Attorney General Rob Bonta, Massachusetts Attorney General Andrea Campbell, and New Jersey Attorney General Jennifer Davenport co-led a coalition of 24 attorneys general and the governors of Pennsylvania and Kentucky in suing the administration to block the implementation of new Medicaid work requirements included in the One Big Beautiful Bill Act. The multistate lawsuit challenges provisions of an interim final rule published by the U.S. Department of Health and Human Services and Centers for Medicare & Medicaid Services (CMS) on June 3, 2026.   

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. Despite months of working with states on implementation, CMS surprised states with the interim final rule, “Community Engagement Requirement for Certain Individuals,” which adopted a new interpretation of key terms like “medically frail” that make it harder for medically vulnerable individuals to waive the work requirements. 

The interim final rule imposes additional administrative burdens, creates unnecessary red tape, and increases the risk that eligible individuals—including those who are already working or otherwise qualify for an exemption—will lose their health coverage. The rule also disregards substantial evidence that Medicaid work reporting and verification requirements cause eligible individuals to lose coverage because of administrative barriers rather than ineligibility. The complaint alleges that CMS failed to meaningfully consider reasonable alternatives or the resulting harms to states, beneficiaries, healthcare providers, and state healthcare systems, while also failing to provide states with clear or workable implementation guidance. 

The coalition argues that the rule unlawfully narrows Congress’s protections for medically frail Medicaid beneficiaries, violates the Administrative Procedure Act by disregarding evidence and imposing arbitrary requirements, and unconstitutionally changes the conditions attached to federal Medicaid funding after states had already begun implementation. The plaintiff states ask the Court to declare the challenged provisions of the interim final rule unlawful, vacate those provisions, and enjoin the federal defendants from implementing or enforcing them, rather than limiting relief solely to the plaintiff states. 

People with serious illnesses or disabilities already face major challenges in their daily lives — they shouldn’t also have to worry about losing their healthcare because of work requirements or related barriers. That was Congress’s will, and it must be respected. Time and again, the Trump Administration has pursued policies that threaten the most vulnerable among us. The interim final rule is the latest example. We won’t stop fighting back.Attorney General Rob Bonta