NEW YORK — New York Attorney General Letitia James joined a coalition last week of 24 other states and the District of Columbia in suing the Trump administration over a new federal rule threatening to take healthcare away from vulnerable Medicaid recipients.
The rule, issued by the U.S. Department of Health and Human Services and the Centers for Medicare and Medicaid Services, creates new barriers that will force many New Yorkers with serious health conditions, disabilities, mental health needs and substance use disorders to prove they are sick enough to keep their health insurance.
The coalition is asking the court to block restrictive provisions of the rule and protect access for Medicaid recipients nationwide.
“New Yorkers who are battling cancer, living with a disability, managing a serious mental health condition or recovering from addiction should be able to get the healthcare they need without being buried in paperwork,” she said in a statement.
“This rule would create needless barriers for some of our most vulnerable neighbors and put thousands of New Yorkers at risk of losing lifesaving health coverage.”
FEDERAL CHANGES
In 2025, Congress enacted the One Big Beautiful Bill Act, which imposed new work requirements on some adults who receive Medicaid. The law explicitly protected some “medically frail” people from those requirements, including those with substance use disorders, serious mental health conditions, disabilities and serious or complex medical conditions.
When the Trump administration introduced its plan to implement the law, however, it went a step further, blindsiding states that had been in touch with CMS to develop implementation plans for months.
Under the administration’s new rule, many medically vulnerable people must prove in new ways their condition makes it significantly harder for them to work or meet new requirements.
This new standard was not included in the law, and it was not part of prior federal guidance to states.
The coalition argues the new rule will make it harder for states to automatically identify Medicaid members who should be protected. The state may need more than a diagnosis to confirm someone is medically vulnerable, including additional information about how severe their condition is or what care they receive.
That information may not be available for many Medicaid members, which means fully eligible recipients could be forced to submit extra paperwork, call the state for help or appeal a denial to keep their healthcare. Some may lose coverage altogether if they cannot obtain the required paperwork.
The coalition also argue the rule violates the Administrative Procedure Act and constitutional limits on federal spending authority by imposing unclear and shifting requirements on states after they have already spent significant time and resources preparing to implement the law based on prior federal guidance.
They are asking the court to block challenged provisions while the case proceeds and, ultimately, vacate them in full.
IMPACT ON NEW YORK
New York’s Medicaid program covers about 6.4 million people, including children, families, older adults and people experiencing homelessness, disabilities or serious health conditions.
Approximately 1.9 million New Yorkers — nearly 30% of all New York Medicaid members — are low-income adults who could be affected by new work requirements and more frequent eligibility checks.
In the last state fiscal year, approximately $17.5 billion in federal Medicaid funding supported health coverage for these New Yorkers.
The new work requirements are expected to have a profound impact statewide.
The New York State Department of Health estimates at least 475,000 New Yorkers could be kicked off Medicaid due to the combined impact of work requirements and more frequent eligibility checks.
The DOH also estimates New York’s uninsured population could increase by up to 45%, from about 1 million people to as many as 1.45 million people.
Because the rule adds even more restrictions, DOH expects an even larger group could lose coverage.
Unable to afford doctor visits, prescriptions or other care, DOH anticipates these individuals may return to the program sicker and in need of more costly care, increasing costs for the state and reducing the quality of care for Medicaid recipients.