Massachusetts v. Oz

Brief Filed: 9/26 
Court: United States District Court for the District of Massachusetts
Year of Decision: Pending

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Whether a federal rule unlawfully narrows Medicaid’s categorical exemption from community-engagement requirements for individuals with substance use disorders and disabling mental disorders.

Mentally Ill and Intellectual Disabilities (Rights Of)

H.R. 1 requires certain low-income, working-age adults to satisfy community-engagement requirements as a condition of Medicaid eligibility. Congress excluded medically frail individuals, expressly including people with substance use disorders and disabling mental disorders. The challenged Interim Final Rule conditions that exemption on additional proof that the person’s condition significantly impairs the ability to work or otherwise satisfy the community-engagement requirement. The plaintiff States contend that this added requirement contradicts the statute and creates burdensome eligibility and documentation procedures. The American Psychological Association joined four other national mental health organizations in supporting the States’ request for summary judgment and an injunction against the challenged provisions.

APA and the other amici argue that substance use disorders and disabling mental disorders are often chronic and cyclical. Individuals may work and function successfully for extended periods while remaining vulnerable to unpredictable relapse or recurrence, making continuous treatment and Medicaid coverage central to sustained recovery. These conditions can impair executive functioning, including the ability to plan, organize, maintain records, and navigate administrative systems, particularly during periods when treatment needs are greatest. Coverage interruptions can increase the risk of relapse, hospitalization, and reliance on emergency services while placing additional pressure on an already strained behavioral-health workforce. APA further argues that the rule improperly shifts benefits-eligibility assessments to clinicians, reducing time available for patient care and potentially undermining patient trust and candor. The rule’s 12-month restriction on medical records and limitation on self-attestation disregard the long-term and recurrent nature of these conditions and make eligible individuals less likely to establish medical frailty when they most need coverage.

Pending