Jennifer Evans discusses the legal uncertainty surrounding the Trump administration's new Medicaid work requirements, particularly its narrow interpretation of the "medically frail" exemption for individuals who are unable to work. She notes that the policy is likely to face significant legal challenges over whether CMS has the authority to adopt such a restrictive standard and how courts will evaluate the agency's interpretation. Evans also warns that requiring Medicaid beneficiaries to verify their work status or exemption every six months, rather than through the traditional annual eligibility review, significantly increases the risk of administrative errors that could result in eligible individuals losing coverage.

(subscription required)