Interim Final Rule/Medical Frailty Decision Statement
November 2, 2026
When it enacted H.R. 1, the federal government made it more difficult for individuals to get basic health care. CMS then issued a rule that went further and would have made it even harder for the most medically vulnerable to qualify for Medicaid.
But, on October 29, 2026, at the urging of California and other states, a federal court determined that CMS had unlawfully exceeded its authority by creating additional requirements for individuals to be able to meet the medical frailty exemption from the new work and community engagement requirements. The court’s decision affirms that CMS cannot create additional obstacles to obtaining Medicaid for the most medically vulnerable that appear nowhere in the statute.
California remains committed to helping eligible Medi-Cal members obtain and maintain coverage while complying with federal law. We will continue working with counties, health plans, providers, community organizations, and federal partners to support an orderly implementation of H.R. 1 and provide members with clear information about any program changes.
Consistent with our longstanding approach, DHCS is focused on minimizing unnecessary coverage losses and maintaining access to affordable, integrated, and high-quality health care for Californians.
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