What Community Engagement Means for States

A former state Medicaid director’s take on the final CMS rule
By Tara LeBlanc, Medicaid Policy and Operations Strategist, Vimo

When I served as Medicaid Executive Director in Louisiana, every major federal rule prompted the same set of questions – not about whether I agreed with the policy, but how we were going to implement it. What systems would need to change? What new processes would have to be built? How much time would we have? And, most importantly, how could we implement new requirements while minimizing disruption for beneficiaries?

Those are the questions that immediately came to mind in June when the Centers for Medicare & Medicaid Services (CMS) released its interim final rule (IFR) on implementing Medicaid community engagement (work) requirements. Here’s my quick take on what the rule means for state Medicaid agencies, the people they serve, and the partners supporting implementation.

The New Requirements

The IFR implements the Medicaid community engagement provisions included in this year’s federal reconciliation law. Beginning no later than January 1, 2027, most states that expanded Medicaid must condition eligibility for certain adults ages 19–64 on completing at least 80 hours per month of qualifying activities, which include employment, participation in a work program, community service, or at least half-time enrollment in school. Individuals may also qualify by meeting an income threshold.

The law includes statutory exemptions for certain populations, including pregnant and postpartum individuals, caregivers of young children, medically frail individuals, and veterans with a full disability rating. While states retain some flexibility in how they verify compliance and exemptions, the overall framework is now established. The rule becomes effective July 31, 2026, with public comments accepted through that date.

The Implementation Challenge

From an operational standpoint, this is where the real work begins. States have a relatively short window to:

• Update eligibility systems to incorporate a completely new eligibility factor.
• Build or modify processes to verify compliance at application, renewal, and potentially between renewals.
• Establish auditable exemption processes, particularly for medically frail individuals whose circumstances may change over time.
• Expand automated data matching by connecting to payroll sources, SNAP and TANF systems, veterans’ data, education enrollment databases, and other trusted sources so that as few people as possible need to submit documentation manually.
• Redesign notices, online portals, and call center scripts so enrollees have a clear understanding of who is affected and what is required of them.

None of these functions are conceptually new – states have spent years automating renewals and improving verification processes. What’s different is the scale, complexity, and timeline. CMS estimates that a meaningful share of affected individuals could lose coverage during the early years of implementation because of either noncompliance or procedural issues. That projection underscores how much rides on getting the verification and outreach infrastructure right at the outset.

Where Technology Meets Policy

The states that most successfully implement these requirements are likely to be ones that approach them first as a data integration challenge, and then as a compliance issue. That means:

• Maximizing ex parte (automatic, data-driven) determinations before requesting documentation from enrollees.
• Building resilient connections to the data sources CMS has flagged, such as wage data, SNAP and TANF systems, education databases, and veteran records, with reliable fallback paths when electronic verification isn’t possible.
• Giving eligibility workers a unified view of each case so they’re not toggling between multiple systems to determine eligibility or exemptions.
• Making the consumer experience as simple as possible through intuitive portals, clear text messaging, and plain-language notices. Even well-designed eligibility systems can result in unnecessary procedural disenrollments if consumers struggle to understand or navigate the process.

Technology, however, is only part of the solution. Equally important are strong partnerships among Medicaid agencies, health plans, workforce agencies, educational institutions, community organizations, and other stakeholders who help eligible individuals maintain coverage.

The Importance of Enrollee Education

For me, one lesson stands out based on what I saw play out repeatedly during the unwinding of continuous Medicaid coverage. Many people who lost coverage during that period did not become ineligible. Instead, they didn’t understand what was being requested, didn’t respond in time, or simply didn’t realize they needed to take action. Procedural disenrollments – not changes in eligibility – accounted for much of the coverage loss.

Community engagement requirements introduce an entirely new concept for many Medicaid enrollees. That makes education and communication a frontline operational strategy, not an afterthought. In practice, states should focus on:

• Explaining the requirements in plain language well before anyone’s coverage is at risk.
• Clearly identifying who may qualify for exemptions, such as caregivers, medically frail individuals, and students, so people don’t disengage or panic over requirements that may not even apply to them.
• Communicating through multiple channels – mail, text, email, phone, trusted community partners – since a single notice is easily missed, especially among populations experiencing housing instability or limited digital access.
• Providing simple, straightforward ways to submit documentation without requiring office visits or lengthy call center waits.
• Giving enrollees advance warning before coverage termination, along with opportunities to correct missing information or missed deadlines. A 30-day noncompliance window can pass quickly if someone is traveling, sick, or simply never received or understood the notice.
• Training frontline staff and community partners – including navigators, community health centers, legal aid organizations, and 211 operators – on the new rules, since many enrollees will first learn about these requirements from someone other than the state.

Education, outreach, and communication strategies must work together. Even the most sophisticated eligibility system can fall short if the people it serves don’t understand what is expected of them.

The Bottom Line

The community engagement rule is now part of the Medicaid operational landscape, regardless of where stakeholders stand on the underlying policy. For state Medicaid agencies, the practical challenge is a familiar one: connect to trusted data sources, minimize the burden on eligible individuals by verifying information electronically whenever possible, and build flexible systems that can adapt as federal guidance evolves. States that began preparing after CMS issued preliminary guidance in December 2025 have a meaningful head start. For everyone else, the implementation clock is ticking.

As someone who led a state Medicaid program, I believe the biggest determinant of success isn’t whether states meet the implementation deadline. Success will depend on designing an implementation approach that is operationally sound, data-driven, and centered on helping eligible residents maintain their coverage.

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Tara LeBlanc is a nationally recognized Medicaid leader with 30+ years of public service and 17 years in health care leadership. As Medicaid Executive Director for the Louisiana Department of Health, she oversaw a program serving more than two million enrollees.