Medicaid 2027 Series - Part 2

Medically Frail: The Exemption States Can't Afford To Get Wrong

Members who are medically frail are exempt from Medicaid work requirements, but only if the state can find them in its own data. Here is who qualifies, what the October 29, 2026 ruling changed, and how to identify frail members before a notice ever goes out.

For state eligibility and policy teams, and the vendors who build their systems. Updated November 2026.

• Start hereWhere Frail Members Get MissedWritten for state eligibility and policy teams, and for the vendors who build their systems.
• ConceptWho Counts As Medically FrailFederal law treats five groups of people as medically frail, and each state turns those groups into its own list of qualifying conditions.
• ConceptWhat The October 29 Ruling ChangedA federal court struck down the extra impairment test that CMS had added to the definition, and kept the limits on data and self-declaration.
• TaskFinding Frail Members In Existing DataStates must check data they already hold before asking a member for proof. Every frail member identified this way keeps their coverage without ever receiving a request.
• TaskWhen The Data Falls ShortSome frail members leave no useful trail in Medicaid claims, such as people who were recently uninsured or who get their care elsewhere. For them, the outcome depends on the proof they can give, and those rules tighten in 2028.
• ReferenceRules And DatesThe frailty rules in one place, as they stand after the October 29, 2026 ruling.