BOSTON — On Thursday, a federal judge rejected the request from 26 states to delay the enforcement of Medicaid work requirements introduced in June.
This legal action challenges a critical component of one of President Trump’s major legislative initiatives. The lawsuit centers on implementing work requirements for Medicaid recipients, with the specifics announced in June and a target implementation date of Jan. 1. States are also required to inform Medicaid recipients by Aug. 31 about how these changes might impact them.
In his order on Thursday, U.S. District Judge Richard Stearns of Massachusetts initially decided to deny the states’ request for a preliminary injunction to halt the work requirement rules. During a hearing on Tuesday, the states argued they lacked the personnel and resources to implement the work requirement within the timeline set by the federal Centers for Medicare and Medicaid Services, claiming it would lead to “harm and chaos.” They also contended that the implementation violates the Administrative Procedure Act, which outlines how agencies should enact policy changes.
The states’ lawsuit stated, “Contrary to months of regular communications with CMS and preliminary guidance materials upon which Plaintiff States based their implementation plans, CMS adopted a rule that dramatically narrowed the Congressionally established categorical exclusions from the work requirement for some of the most vulnerable Medicaid members.”
In response, government attorneys argued that Congress had authorized the work requirement when it passed H.R. 1, known as the One Big Beautiful Bill, last year. They also claimed they thoroughly considered the implications of redefining “medically frail.”
Judge Stearns, appointed by Bill Clinton, noted that it was unclear how much responsibility CMS bore for the stringent timeline. He stated, “It is not clear how much this harm can fairly be attributed to CMS. This timeline was set by Congress in H.R. 1, not by CMS in the challenged IFR,” and expressed skepticism that “the States have shown that their expenditures are likely to be totally irrecoverable.”
During the Tuesday hearing, the states argued that CMS was overstepping its authority by interpreting H.R. 1 more narrowly than the law intended. Although the judge denied the preliminary injunction, he recognized that “this case presents difficult issues regarding the scope of Congress’s delegation of interpretative authority to the Secretary and the faithfulness to Congressional intent with which the Secretary performed his task.”
The denial of the preliminary injunction was issued without prejudice, allowing the lawsuit to proceed to a more in-depth hearing on the case’s merits. Judge Stearns aims to schedule these hearings before the work requirement’s implementation on Jan. 1. If the case’s progress stalls, he indicated that states could renew their request for judicial relief.

