Medicaid Work Requirements for People With Disabilities
If you have a disability or a serious health condition, you are likely exempt. After an October 2026 court ruling, being in one of five health categories is enough.
Short answer: If you get Medicaid because of a disability or SSI, or you have Medicare, the rule does not apply to you at all. If you are in the adult expansion group, you are exempt as "medically frail" if you are in any one of five categories in the law. Since an October 29, 2026 court ruling, you do not also have to prove your condition keeps you from working.
The five medically frail categories
Federal law (sec. 1902(xx)(9)(A)(ii)(V)) excludes anyone who is "medically frail or otherwise has special medical needs," including a person:
- Who is blind or disabled under the Social Security definition
- With a substance use disorder (the CMS rule leaves out people in stable recovery for 5 years or more)
- With a disabling mental disorder
- With a physical, intellectual, or developmental disability that significantly limits one or more activities of daily living, like bathing, dressing, or eating
- With a serious or complex medical condition
You do not need to get SSI or Social Security disability to fit these categories.
Court ruling, October 29, 2026. In Massachusetts v. Oz, a federal court struck down the CMS rule's extra test that your condition must "significantly impair" your ability to meet the requirement. Being in one of the five categories is now enough. The court kept the CMS proof rules. CMS may appeal. More about the ruling.
What counts as a serious or complex condition
The CMS rule describes it as a condition that, for example, is life-threatening or seriously disabling, causes significant pain that disrupts daily life, needs frequent monitoring or several specialists, or carries a risk of serious complications. CMS gave examples such as cancer, end-stage kidney disease, viral hepatitis, sickle cell disease, COPD, HIV/AIDS, heart disease, ALS, Parkinson's, cystic fibrosis, multiple sclerosis, and hemophilia. The list is not complete.
Each state must keep its own list of qualifying diagnoses, update it, and let you ask to be considered if your condition is not on it. CMS did not publish one national list.
Who is not covered by the rule at all
- People who get Medicaid through a disability group, including SSI recipients (they are in a different eligibility group)
- People with Medicare Part A or Part B, at any age (many people on Social Security disability get Medicare after 24 months)
Other rules that can help
- Caring for someone with a disability is its own exemption. See parents and caregivers.
- Hospital and medical travel months: states may choose to excuse a month when you stay in a hospital, nursing facility, or psychiatric hospital, or must travel far for treatment of a serious condition. See short-term hardship.
- Drug or alcohol treatment is a separate exemption. See substance use treatment.
What proof is usually needed
- Your state must first check your Medicaid claims and encounter records from the past 12 months.
- Until January 1, 2028, if records don't show it, the state may accept your signed statement each time it checks.
- From January 1, 2028, a signed statement can be used only once while you stay enrolled, and the state must confirm it with records or documents at your next renewal.
- Medically frail status is rechecked at least every 12 months.
A letter from your doctor or other provider describing your condition is useful to keep on hand. The court upheld these proof rules.
What to do next
- Use the free checker to see if the rule applies to you and which exemptions may fit.
- Ask your state Medicaid agency for its list of qualifying conditions, and ask to be considered if yours is not on it.
- Keep a recent letter from your doctor or clinic and copies of disability award letters.
- Find your state guide for start dates, how to report, and who to call.
- Got a notice? You have at least 30 days to answer, and you can ask for a fair hearing. See what to do about a notice.
Frequently asked questions
Are people with disabilities exempt from Medicaid work requirements?
Yes, in most cases. People who get Medicaid through a disability group or SSI are not covered at all. People in the expansion group are exempt as medically frail if they are blind or disabled, or have a disability that significantly limits daily activities, a disabling mental disorder, a substance use disorder, or a serious or complex condition.
Do I need to be on SSI or SSDI?
No. The medically frail categories cover many people who do not get disability benefits. The state looks at your medical records or your statement.
Does depression or anxiety count?
A "disabling mental disorder" counts. CMS did not publish a national list of mental health diagnoses, so each state decides which ones are on its list. If yours is not listed, you can ask to be considered.
Do I have to prove I can't work?
No, not since October 29, 2026. The court struck the CMS test that your condition must significantly impair your ability to meet the requirement. CMS may appeal, so this could change.
What if my state says I am not medically frail?
Send any medical records or a provider letter you have, and ask for a fair hearing if the state still says no. Coverage continues during the 30-day notice period.
Sources
- Public Law 119-21 (H.R. 1), sec. 71119: community engagement requirement (GovInfo)
- CMS interim final rule, Medicaid community engagement requirement, 91 FR 33348 (June 3, 2026)
- CMS-2454-IFC, official PDF (GovInfo)
- Massachusetts v. Oz, No. 1:26-cv-12962-RGS (D. Mass.), memorandum and order (Oct. 29, 2026)
- HFMA: court rules on medical frailty in Medicaid work requirement (Oct. 29, 2026)
- GIH: federal court strikes medical frailty limits from CMS rule (Oct. 30, 2026)