Mapping Medicaid’s “medically frail” exemption, state by state.

01 · The Challenge

A federal rule, applied fifty different ways.

The One Big Beautiful Bill Act, signed in July 2025, created Medicaid work requirements for certain adults ages 19–64 enrolled in expansion coverage, and most states must implement them by January 1, 2027. Roughly 20 million people could be subject to the new reporting rules, and the Congressional Budget Office estimates that 5.2–7.5 million enrollees could lose coverage.

People with serious or complex medical conditions can be exempt as “medically frail” — but states have discretion over how they define and apply that exemption, and a diagnosis alone may not qualify someone. For patients with cystic fibrosis, sickle cell disease, and kidney disease, the state they live in could shape whether they keep their coverage.

02 · The Approach

Track it, brief it, translate it.

1. Track

   Built and maintained a 50-state tracker of “medically frail” exemption definitions under the new requirements, giving Public Affairs one place to compare how each state was defining and applying the exemption.

2. Brief

   Synthesized the CMS interim final rule into an executive briefing for ~40 US Public Affairs staff, including Director- and VP-level leadership.

3. Translate

   Wrote a patient-facing one-pager that turns eligibility rules, required actions, and enforcement deadlines into plain language for cystic fibrosis, sickle cell, and kidney disease advocacy organizations — backed by six primary federal sources.

03 · The Outcome

Used by the team, shared with patients.

The patient one-pager was cleared by Vertex for public sharing. The tracker and executive briefing are internal to Vertex and are not published here.

Skills Applied