Medicaid recipients who qualify as medically frail will not have to separately prove that their conditions prevent them from meeting new work requirements under an Oct. 29 federal court ruling.

U.S. District Judge Richard G. Stearns in Boston rejected an additional restriction imposed by the Trump administration's Centers for Medicare & Medicaid Services (CMS). The decision partially favored a coalition of 25 states and the District of Columbia that challenged the federal government's implementation rules.

The ruling comes as New Hampshire prepares to implement Medicaid work requirements beginning Jan. 1, 2027. The changes will affect eligible adults covered through Medicaid expansion, including residents of Claremont, Newport and Sunapee.

New Hampshire was not among the states that filed the lawsuit.

What the ruling changes

The federal tax and spending law enacted in July 2025 requires many adults subject to Medicaid's new community engagement rules to work or participate in other qualifying activities for at least 80 hours each month, or attend an educational program at least half-time.

Congress created exemptions for certain people with medical conditions, including individuals who are blind or disabled, have substance use disorders or disabling mental disorders, have certain disabilities affecting daily activities, or have serious or complex medical conditions.

In June 2026, CMS issued rules requiring individuals in those categories to additionally demonstrate that their conditions significantly impaired their ability to comply with the work requirements.

Stearns found that the added condition improperly narrowed the categories Congress established.

In his 16-page ruling, the judge concluded that the federal agency could not impose an additional work-related impairment test on people covered by the law's specified medical-frailty categories.

The decision removes that extra federal test but does not eliminate the need to establish eligibility for a medical exemption.

What remains in place

The judge left the broader Medicaid work requirements intact. Their scheduled Jan. 1, 2027, implementation date remains unchanged.

The court also upheld two other provisions challenged by the states.

One limits the claims and encounter data that states may use to verify medical frailty to records from the preceding 12 months. The other limits recipients to one self-attestation of medical frailty during a continuous enrollment period.

Stearns concluded that CMS had provided a reasonable basis for those provisions.

The ruling also addressed implementation difficulties faced by the states that brought the lawsuit, including the costs of updating eligibility systems.

New Hampshire plans quarterly checks

New Hampshire is preparing to conduct work requirement compliance reviews more frequently than the federal minimum.

According to a KFF survey of state implementation plans, New Hampshire and Indiana plan quarterly verification checks rather than relying only on the six-month federal renewal schedule.

The more frequent checks reflect state legislation and could require Medicaid expansion recipients to demonstrate compliance or exemption status at additional points during the year.

States are expected to use available information to verify eligibility when possible, rather than requiring every recipient to provide documentation that the state already possesses.

New Hampshire previously attempted Medicaid work requirements in 2018 and 2019. That effort was suspended after substantial numbers of expansion enrollees were identified as noncompliant, according to PBS NewsHour's reporting on earlier state programs.

The new federal requirements will begin Jan. 1, 2027, unless a state receives authorization for a different implementation schedule.

For New Hampshire residents receiving Medicaid, the court's decision changes the federal standard for medical-frailty exemptions but does not remove the upcoming eligibility verification requirements.