D.C. residents with serious medical conditions will face an easier path to exemption from new Medicaid work requirements after a federal judge blocked the Trump administration's restrictive definition of "medically frail."

U.S. District Judge Richard Stearns ruled Oct. 29 that the Centers for Medicare and Medicaid Services (CMS) overstepped its authority when it required people with disabilities, substance use disorders and serious illnesses to also prove their conditions "significantly impair" their ability to work. The ruling, first reported by the Associated Press, handed a partial victory to a coalition of 25 states and D.C. that sued the administration in June.

The decision does not touch the work requirements themselves. Starting Jan. 1, 2027, most adults ages 19 to 64 enrolled in Medicaid through the Affordable Care Act expansion must work, volunteer or attend school at least 80 hours per month to keep their coverage.

What the judge struck down

Congress defined "medically frail" broadly in the One Big Beautiful Bill Act, which became law July 4, 2025. The law listed people who are blind or disabled, have substance use disorders, disabling mental disorders, certain physical or developmental disabilities, or serious medical conditions.

CMS published guidance in June that went further. It required individuals in those categories to show their conditions also "significantly impair" their ability to meet the work mandate. Stearns called that interpretation "contrary to law" and "beyond the powers of the CMS," according to Politico.

Stearns upheld two other federal restrictions: states must reject proof of medical frailty if the diagnosis is more than a year old, and states may accept only one self-attestation per continuous enrollment period.

Nearly 80,000 D.C. residents affected

The D.C. Department of Health Care Finance (DHCF) estimates that 79,106 Medicaid beneficiaries will be subject to the work requirements, according to testimony Jessica Berger, a supervising attorney at Legal Aid DC, delivered to the D.C. Council on Oct. 29. That figure comes from DHCF's own response to a Council hearing, dated Oct. 15.

DHCF estimates the affected group represents about one-quarter of current Medicaid enrollees, according to a biweekly eligibility briefing the agency published Oct. 21. The remaining 78% of enrollees, including children, seniors and adults in disability waiver programs, are not subject to the new rules.

The District applied Oct. 16 for a short-term hardship exemption for residents of Wards 7 and 8, citing unemployment rates that meet the law's threshold. DHCF said it would share any CMS response at future meetings.

Errors already surfacing

Berger warned the Council that the District's benefits system, known as DCAS, is already making mistakes with SNAP work-requirement exemptions. Legal Aid DC has seen cases where the system asked people in their 80s to prove a disability exemption and screened young children for work requirements, she said in her testimony.

In another case, one parent in a household was exempted based on a young child's age while the other parent was not. Berger said those errors raise concerns about how DCAS will handle Medicaid exemptions in 2027.

"Every time that DHS gets it wrong, and a beneficiary has to appeal a decision … there is a risk that the person will fall through the cracks," Berger said in her testimony.

What D.C. residents should do

The D.C. Department of Human Services launched a website, workrequirements.dc.gov, with a pre-screening tool to help residents determine whether the requirements apply to them. Service centers are open 7:30 a.m. to 4:45 p.m. weekdays at five locations, including Anacostia, Congress Heights and H Street NE.

Residents can also call the Public Benefits Call Center at 202-727-5355.

The Associated Press reported that representatives from the Department of Health and Human Services and CMS did not respond to a request for comment on the ruling.