Guyer Quoted in Stateline on States' Struggles to Implement New Medicaid Medical Frailty Rules

Manatt Health Senior Managing Director was quoted in Stateline on the significant challenges states and providers face to implement the new Medicaid work requirement rules in the wake of recent federal guidance that narrows the definition of who qualifies as “medically frail.”

States had been operating under the assumption that they could rely on the plain language of the law as passed by Congress, as well as months of guidance from CMS, to apply the “medically frail” designation, which covers five distinct categories of disabilities and illnesses without requiring a determination of whether a person can work, according to the article. The Trump administration's June 1 interim guidelines changed that, now requiring that individuals not only have a significant health condition but also demonstrate that it significantly impairs their ability to work.

Guyer warned that the new guidance transforms what had been a straightforward protection for people with disabilities and serious health conditions into a complex documentation process requiring health care provider involvement, at a time when states are already racing to build systems to enforce the new work requirement rules by the January 2027 deadline.

"Now, it's not enough just to have that diagnosis. You may need to go to your doctor and get a special note,” said Guyer. “So, it's turned it from a very straightforward protection of people with disabilities and significant health conditions into a paperwork morass, where all of a sudden they have to get their health care providers involved in documenting and assessing their capacity to work.”

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