A 25-year-old Kansas City woman who has already lost her Medicaid coverage twice because of paperwork problems is now one of five enrollees suing the Trump administration over a new rule she says could take her health coverage away for good. Emily Byrd relies on Medicaid to pay for services and medications tied to autism spectrum disorder, obsessive compulsive disorder and other conditions, and she is not currently working after mental health conditions derailed her training to become a certified nurse assistant.
Byrd is one of five individual plaintiffs named in a lawsuit filed Friday in the U.S. District Court for the District of Maryland, according to the Missouri Independent. The case, filed September 18 as *Taylor et al. v. Kennedy Jr. et al.* and assigned to District Judge George Levi Russell III, names HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Mehmet Oz as defendants, per court docket records. Byrd is co-represented by Legal Aid of Western Missouri alongside the National Health Law Program and Democracy Forward, according to the National Health Law Program.
The other four plaintiffs are Sonya Taylor, Contonnia M. Turner Jr., Rob Bricken and Lauren Bush; the five individual plaintiffs are from Kentucky, Illinois, Indiana, Missouri and North Carolina, reflecting the rule's reach well beyond Missouri, as The Indiana Lawyer reported. Bush, who has type 1 diabetes, says she experiences stress and anxiety over meeting work requirements while managing her condition without secure Medicaid coverage, per the Missouri Independent. Six medical organizations, including the American College of Physicians and the American Academy of Pediatrics, joined the suit as plaintiffs, along with the city of Columbus, Ohio, which provides medical services regardless of a resident's insurance status, the outlet reports.
What the Rule Actually Requires
Under Public Law 119-21, the One Big Beautiful Bill Act signed in July 2025, Congress created an 80-hour monthly work, volunteer or education requirement for Medicaid expansion adults ages 19 to 64 starting January 1, 2027, while carving out categorical exemptions for people who are medically frail — a group that includes blind or disabled people, those with a substance use disorder, a disabling mental disorder, a serious or complex medical condition, or a physical, intellectual or developmental disability significantly impairing daily activities. The lawsuit argues CMS exceeded that statutory authority by adding a secondary test requiring medically frail enrollees to prove their condition specifically impairs their ability to meet the 80-hour requirement, rather than simply qualifying by diagnosis. Jane Perkins, litigation director at the National Health Law Program, said the rule imposes what she called a backdoor work requirement on people Congress meant to exempt, per the Missouri Independent. Amber Christ, executive director of Legal Aid of Western Missouri, said the rule adds a test that Congress did not write, the outlet reports.
The lawsuit also contends the rule requires medical providers to assess whether a patient's condition impairs work-requirement compliance without clear criteria for doing so, and that it will push patients to schedule appointments solely to obtain Medicaid eligibility paperwork. It also argues that doctors could be drawn into eligibility decisions. Perkins told the Missouri Independent that community clinics and local-government-funded emergency medical services will see increased demand without added compensation as a result.
A Rule With National Reach
An independent analysis by Manatt Health, cited in the legal complaint obtained by the National Health Law Program, projects the interim final rule will push annual national Medicaid coverage losses from a baseline of 6.4 million people to roughly 8.2 million — a 30 percent increase attributable to the added administrative proof requirements. The rule, published at 91 Fed. Reg. 33348, also specifically excludes people with substance use disorders who have been in stable recovery for five or more years from qualifying for the medically frail exemption, according to The AIDS Institute. The lawsuit asks the court to vacate both the medical-condition provision and the stable-recovery exclusion, per the Missouri Independent.
This is the second major legal front against the work-requirement rule. A separate suit, *Massachusetts v. Oz*, was filed June 29 in Boston federal court by 25 states and Washington, D.C., challenging the same CMS rule, and a federal judge denied a preliminary injunction request in July 2026 pending full summary judgment hearings, according to a filing tracked by the Massachusetts Attorney General's Office. The lawsuit was filed in June.
Missouri's Own Paperwork Problem
The Missouri angle carries particular weight given the state's recent enrollment history. Federal CMS data shows Missouri dropped more than 333,000 Medicaid enrollees between January 2025 and February 2026, with paperwork issues accounting for nearly 92 percent of those disenrollments, according to the Missouri Independent. Byrd herself has already lost Medicaid coverage twice for the same reason — paperwork problems, not a change in her actual eligibility — before this lawsuit was filed. She previously worked as an assistant manager, cashier and stocker at three retail stores before mental health conditions interrupted her nurse assistant training, the outlet reports.
Missouri has not yet settled how it will screen for medical frailty once the work rule takes effect. Jess Bax, speaking at a MO HealthNet oversight committee meeting on August 12, said the department would work with patient and healthcare advocates throughout 2027 to assess medical frailty, per the Missouri Independent's reporting. Department official Baylee Watts said Missouri is still finalizing its approach for identifying and verifying medically frail individuals and has not decided whether to use self-attestation during 2027 or which screening methodology to adopt, the outlet reports.
That uncertainty puts Missouri in a different position than some of its neighbors. While federal rules allow states to accept self-attestation of medical frailty through 2027, eight states — including Missouri neighbors Arkansas and Iowa — rejected that grace period and will demand strict medical proof starting January 1, 2027, as Hoodline reported in August. CMS itself released non-binding guidance on September 8 suggesting a three-tier structure for frailty determinations: diagnoses that automatically qualify, conditions that qualify with additional documentation, and cases requiring individualized review when information is insufficient, according to the Missouri Independent. Under the challenged rule, states will eventually be limited to accepting just one self-attestation per enrollment period once stricter verification begins in 2028.
