In a Massachusetts federal court on June 29, 2026, governors and attorneys general from 25 states filed a complaint alleging that the Centers for Medicare and Medicaid Services (CMS) overstepped in their interpretation of Medicaid Community Engagement Requirements.

On June 1, CMS posted an Interim Final Rule (IFR) with comment period. The plaintiffs alleged that the IFR went significantly beyond the statute by requiring individuals seeking exclusion through “medical frailty” to demonstrate a connection between their serious or complex medical condition and their inability to meet the work requirement. The suit claims that CMS’ rule did not contemplate the burden on the implementing states, was arbitrary and capricious in their expansion beyond the statute and called for “preliminary relief … to avert irreparable harm” by staying the IFR’s challenged provisions and effective date of July 31 in the plaintiff states.

LeadingAge will be watching the suit and related implications. Stay up to date through our serial post.