The federal government just told 43 states and the District of Columbia that before anyone loses Medicaid over a new work requirement, the state has to warn them it exists. The Centers for Medicare & Medicaid Services built that sequencing directly into the rule creating Medicaid’s new community engagement requirement, which will eventually require many working-age adults to log 80 hours a month of work, school, training or community service to keep their coverage. For a household that depends on Medicaid to see a doctor or pick up a prescription, that outreach duty is the difference between finding out about a new condition on coverage in a letter with time to respond, and finding out when a claim gets denied.
The Outreach Duty CMS Wrote Into the Rule
CMS issued the rule, formally known as CMS-2454-IFC, on June 1, 2026, as an interim final rule with a comment period — a format that lets a requirement take legal effect right away while the public comment process runs alongside it. Inside the rule’s list of state responsibilities sits a sequencing requirement that has to happen before any state can start checking whether a Medicaid enrollee actually meets the new work rule.
“States must conduct outreach to adults who are already enrolled in Medicaid and could be subject to the requirement prior to implementing the new requirement,” according to CMS’s own fact sheet on the rule. The obligation doesn’t end once implementation begins, either — the same fact sheet directs states to keep notifying new applicants and people up for renewal on the same eligibility basis after the requirement takes effect, so the outreach duty runs continuously rather than as a single mailing.
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Who Counts as an “Applicable Individual” Under the 80-Hour Rule
The work requirement applies to non-pregnant adults ages 19 to 64 who aren’t entitled to or enrolled in Medicare and who are eligible for or enrolled in Medicaid’s adult expansion group, or in certain Section 1115 demonstrations that cover adults on a similar basis. CMS calls this group “applicable individuals,” and the legal authority behind the requirement traces to Section 71119 of the Working Families Tax Cut legislation, according to Medicaid.gov’s community engagement page.
An applicable individual can satisfy the requirement by working, doing community service or participating in a work program for at least 80 hours a month, by enrolling in an educational program at least half-time, by combining those activities to reach 80 hours, or by earning at least 80 times the federal minimum wage in monthly income — $580 a month at today’s federal minimum wage, under CMS’s fact sheet. States must verify that status at application and again at every renewal, and may check more often if they choose.
The 30-Day Notice Before a Case Closes
If a state can’t confirm that someone subject to the requirement is actually meeting it, the rule doesn’t let the state close the case immediately. It has to send a notice of noncompliance first, and the individual then has 30 calendar days to show either that the requirement is met or that an exemption applies. Only after that window passes without a response can a state deny an application or disenroll someone already covered.
Even a disenrollment isn’t necessarily final. Someone cut off for not meeting the requirement can reapply for Medicaid at any time, and the state has to assess their compliance status fresh when they do. That reapplication path matters for households where the gap wasn’t a real change in work status but a missed notice, a wrong address on file, or paperwork that didn’t reach the right caseworker in time.
Which Adults Are Exempt, and the Hardship Exceptions States Can Add
A long list of adults never has to meet the requirement in the first place. CMS’s fact sheet exempts people who are pregnant or in a postpartum period, adults who are disabled or medically frail, parents and caretaker relatives of a child 13 or younger or of someone with a disability, veterans with a total disability rating, former foster care youth, American Indians and Alaska Natives, people already meeting TANF or SNAP work requirements, participants in drug or alcohol treatment programs, and people incarcerated in public institutions.
States also have the option, but not the obligation, to offer short-term hardship exceptions on top of those exemptions. Where a state chooses to offer them, they can cover people receiving inpatient hospital or nursing facility care, residents of a county with an unemployment rate at or above 8 percent or 1.5 times the national average, residents of a county under a presidentially declared disaster, and people traveling outside their community for extended medical treatment for themselves or a dependent. Because these are state options rather than federal mandates, whether a hardship exception exists at all will depend on where someone lives.
Forty-Three States, Zero Territories, One January 2027 Deadline
CMS’s fact sheet counts 43 states plus the District of Columbia as currently covering the adult populations the new requirement reaches, meaning all of them will have to build outreach and verification systems before the rule takes hold. U.S. territories are not subject to the requirement at all. States generally have until January 1, 2027 to implement the rule, though any state can choose to start sooner.
The rule itself, published in the Federal Register on June 3, 2026, also puts CMS in charge of monitoring how each state carries out both halves of the requirement over the next several months — the outreach that has to come first, and the verification and notice process that follows once enforcement actually begins.
What ends coverage most often
Not ineligibility, but a renewal packet returned late or missing one document.
The SNAP & Medicaid Renewal Organizer includes a 13-page organizer, 51 state packs and a renewal document checklist.
See the renewal document checklist in The SNAP & Medicaid Renewal Organizer.
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.
