Across the country, Medicaid caseworkers are assembling mailing lists this month for a notice that will decide whether millions of enrollees keep their coverage past the end of the year. The letter itself is only half the job. Under the federal rule that created Medicaid’s new work requirement, a state cannot rely on a single envelope to warn someone their coverage is at risk — it has to reach that person a second way, too.
That second-contact requirement is not a technicality. It grew directly out of what happened the last time Medicaid ran a mass notice campaign. During the 2023–2024 unwinding of pandemic-era coverage protections, large numbers of people lost Medicaid over paperwork after a single mailed notice went to an old address or sat unopened in a stack of mail. The interim final rule that created the new work requirement builds redundancy into the notice process from the start.
Two Contacts, Not One, Before Coverage Is At Risk
The rule, issued by the Centers for Medicare & Medicaid Services on June 1, 2026 and formally published in the Federal Register two days later under file code CMS–2454–IFC, requires state Medicaid agencies to notify people who may be subject to the community engagement requirement through at least two separate channels. The first is regular mail, or an electronic format if the individual has already chosen to receive Medicaid communications that way. The second has to be something different in kind: a phone call, a text message, a posting to the person’s online Medicaid account, or another commonly available electronic method.
States choose the specific combination, but they have to spell out, in their own outreach plans, who receives a notice, how often, and exactly what it has to say. According to KFF’s review of the rule and state implementation plans, the notice has to explain the work requirement itself, who is exempt, what happens for noncompliance, and how to report hours or activities. A postcard restating the rule in six words does not satisfy it.
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Why the Notices Are Going Out Right Now
The timing is not arbitrary. The work requirement takes effect nationwide on January 1, 2027, and states have to look back at least one prior month of activity the first time they check compliance. For a state using the minimum one-month lookback, that first lookback period is December 2026, and the rule requires the initial outreach notice to go out at least three months before a person’s first lookback period begins. Count backward from December and the deadline lands squarely on this September.
That is exactly what is happening in places like Nevada, where the state Medicaid agency began mailing notices earlier this month and says it will follow up with text messages and emails through the rest of September. Other states are running the same clock right now. If someone covered under the Medicaid adult expansion group hasn’t heard anything by early fall, that is worth raising with the state Medicaid office directly instead of waiting on a second letter that may or may not come.
What the Second Notice Is Supposed to Catch
CMS built the two-channel requirement around a specific failure mode: an outreach letter that never reaches the person it was sent to. Medicaid enrollees move more often than the general population, and a state’s address file is frequently a year or more out of date by the time a mailing goes out. A phone call, text, or online account message doesn’t fix a bad mailing address on its own, but it gives the state a second attempt through a channel that isn’t tied to wherever the enrollee happened to live when they last updated their file. It also gives caseworkers a paper trail showing more than one good-faith attempt was made, which matters if a disenrollment is later challenged.
This two-channel rule is separate from the notice a state sends after determining someone hasn’t met the requirement, which carries its own 30-day window to demonstrate compliance or claim an exemption. The outreach notice covers an earlier, informational stage: making sure a person knows the requirement exists at all, before any individual determination has been made about their case.
Making Sure the State Can Reach You
Because the rule gives states real flexibility in choosing the second channel, the practical burden shifts to enrollees to make sure at least one of those channels actually works. That means confirming a current mailing address with the state Medicaid agency, checking that a phone number or email on file is current, and creating or logging into a state Medicaid online account where one exists. Some states are also enlisting their Medicaid managed care plans to help with outreach calls and mailings, so a call this fall from a health plan about “new requirements” is not automatically a scam. Keeping that contact information current is a five-minute task through a state Medicaid portal, and it is far less disruptive than the appeals process that follows an incorrect disenrollment.
Anyone unsure whether the requirement applies to them can ask directly rather than guessing from the notice alone. The community engagement requirement applies specifically to the Medicaid adult expansion group, not to every Medicaid pathway, and CMS’s own program guidance points enrollees back to their state Medicaid agency for a pathway-specific answer. The agency’s fact sheet on the rule is a reasonable place to start before that call.
This article was produced with AI assistance and reviewed by a human editor. Figures are linked to their primary sources; where a claim could not be verified from the public record, we say so.
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