Grantmakers In Health (GIH) has joined an amicus curiae brief filed September 10 in Commonwealth of Massachusetts v. Oz, supporting a challenge to a federal rule that the brief argues would strip Medicaid coverage from millions of people with serious health conditions.
GIH joined the American Public Health Association, the Jacobs Institute of Women’s Health and the National Center for Medical-Legal Partnership at the George Washington University Milken Institute School of Public Health, Liberty Health Alliance, and 161 public health and health policy deans, chairs, and scholars in signing the brief. It supports the 26 states challenging the interim final rule issued by the Centers for Medicare and Medicaid Services (CMS) to implement Medicaid community engagement requirements.
Under legislation enacted in 2025, certain Medicaid enrollees must complete at least 80 hours per month of work, community service, or education coursework to enroll in or maintain coverage. Congress created an exclusion for people who are medically frail or have special medical needs, including those with serious or complex medical conditions, certain disabilities, substance use disorders, and disabling mental health conditions.
The amici argue that CMS exceeded that intent, in violation of the Administrative Procedure Act, by also requiring people with qualifying conditions to prove that their condition significantly impairs their ability to meet the 80-hour requirement, and by limiting the evidence states may use to determine who qualifies for the exclusion. The brief points to earlier Medicaid work requirement experiments in Arkansas and Georgia, which produced substantial coverage losses without measurable gains in workforce participation.
The brief further warns that coverage losses would increase uncompensated care and administrative costs for hospitals, community health centers, and other safety net providers, particularly in underserved and rural communities. The amici ask the U.S. District Court for the District of Massachusetts to grant the plaintiffs’ motion for summary judgment and vacate the challenged portions of the rule.
The full brief is available here.