CHCS Analyzes Medical Frailty Exemption Design Under Medicaid Work Rules
In a Center for Health Care Strategies blog post, the authors examine how states should implement the medical frailty exemption under new federal Medicaid work requirements, which take effect January 1, 2027. The piece contrasts the statutory exemption language, which lists five disability-related categories, with CMS's June 2026 interim final rule, which adds a second test requiring that a condition "significantly impair" a person's ability to comply with work requirements, modeled on the ADA disability definition. The authors argue these two frameworks reflect conflicting policy objectives, protecting disabled people from coverage loss versus promoting workforce participation, and note that an estimated 44% of ACA expansion enrollees subject to work requirements have a physical or behavioral health disability. The post draws on input from an Elevance Health advisory board to offer states a more balanced approach to exemption design.