Pennsylvania Sues to Block Medicaid Work Requirements

Yesterday, Pennsylvania joined 24 other states and the District of Columbia in a lawsuit seeking to block Medicaid work requirements from taking effect on January 1, 2027.

Filed in federal district court in Massachusetts, the lawsuit challenges the Interim Final Rule (IFR) the Trump Administration issued in early June. The IFR spells out how states must put "Community Engagement Requirements"—better known as work requirements—into effect starting January 1, 2027. (See our recent coverage of the IFR here.)

These work requirements are just one part of a much larger set of Medicaid cuts and changes under the 2025 budget reconciliation bill (also known as H.R. 1), signed into law on July 4, 2025. Among its many provisions, the law requires people in the Medicaid Expansion group to prove they are working in order to keep their coverage.

In the lawsuit, Pennsylvania and the other states argue that the Interim Final Rule:

• Strips away protections Congress put in place for medically frail Medicaid recipients, narrowing them beyond what the law allows.
• Ignores substantial evidence that work requirements cause eligible people to lose coverage—not because they aren't working, but because the paperwork and red tape trip them up. By disregarding this, the states say, the rule violates the Administrative Procedure Act.
• Overlooks the significant harm the rule will cause to states, Medicaid enrollees, healthcare providers, and state health systems.
• Unconstitutionally coerces states by imposing new compliance requirements after certain states had already begun implementing H.R. 1 based on the law’s plain language and CMS's earlier guidance.
   

The states are asking the court to block these provisions and ultimately strike them down. PHLP will keep readers posted as the case moves forward.