New Guidance for States on Medicaid Community Engagement Requirements

On December 8, the Centers for Medicare & Medicaid Services (CMS) released preliminary guidance on the mandatory Medicaid work requirements, also known as community engagement. The preliminary guidance provides information on notification requirements, a timeline for state outreach, and some details on reporting compliance. However, CMS said it is developing an interim final rule that will provide guidance on the use of reliable information, the role of Managed Care Organizations (MCO), and six-month redeterminations.

Overview of the Preliminary Guidance

1. Which states do work reporting requirements apply to?

• • The guidance notes that some states with Section 1115 demonstration waivers for adult expansions may have to comply but says that more guidance is coming on which states.

2. What notifications do states have to provide to Medicaid enrollees?

• • States must alert Medicaid expansion enrollees about the new work reporting requirements by mail, or in electronic format if elected by individuals, AND one other format in a timely manner.
  • Options for the second format of communication: “an internet website, other commonly available electronic means, and other format the Secretary determines appropriate.”
  • Best practices: States should continuously communicate with a variety of methods (i.e. text, email, and phone) to effectively reach eligible people enrolled in Medicaid.

3. How long do states have to conduct outreach to Medicaid enrollees?
   • States must implement work reporting requirements by January 1, 2027.
   • States can choose whether they want individuals to demonstrate community engagement for one to three months. The minimum time for outreach depends on which month they will report.
     • Notification by September 2026: One month, December 2026, is included in community engagement reporting.
     • Notification by August 2026: Two months, November and December 2026, are included in community engagement reporting.
     • Notification by July 2026: Three months, October through December 2026, are included in community engagement reporting.

4. What are the reporting requirements at the time of Medicaid renewal?
   • Medicaid beneficiaries must demonstrate compliance with the requirements for at least one month, whether or not they are consecutive months. The number of months will be determined by the state.
   • An individual will have successfully met the requirement if they demonstrate community engagement at any point during the eligibility period, as long as the total number of months meets the state’s specifications.

Read the full preliminary guidance at: State Requirements to Establish Medicaid Community Engagement Requirements