Medicaid Work Requirements Start by 1 January 2027: A Clinic's Patient-Outreach Playbook

Help patients keep Medicaid in 2027 with reminders and exemption visits. Your texts can point the way. Patients still report to their state.

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The short answer

H.R. 1 (Public Law 119-21, signed 4 July 2025) added a Medicaid "community engagement" requirement. Most adults aged 19 to 64 in the Medicaid expansion group must show 80 hours a month of work, community service, a work program or half-time school, or qualifying income, unless they are exempt. CMS published an interim final rule on 3 June 2026, effective 31 July 2026. States must start no later than 1 January 2027, and some may start earlier. Patients report and verify with their state Medicaid agency. A clinic can remind patients, explain where to report, and see patients who may qualify for an exemption. A text from your clinic does not meet the requirement, report hours, or prove an exemption. This page is general information as of 15 October 2026, not legal advice.

Risky vs safe: Medicaid outreach texts, rewritten

A patient's coverage is PHI, and an Insecure text can't contain PHI. Keep regular texts general and put anything about the patient's own Medicaid in a Secure text with link.

  • Risky

    Reply with your work hours each month and we'll take care of your Medicaid.

    Safer

    You report your hours to the state Medicaid agency, not to us. Here's how: {{state_portal_url | your state Medicaid website}}.

    A text to your clinic is not a report to the state and does not satisfy the requirement.

  • Risky

    Maria, your Medicaid ends Jan 1 because of the work rule.

    Safer

    Hi {{first_name | there}}, some state health coverage rules change on Jan 1, 2027. If your state sends you a letter, read it and answer by the deadline. Questions? Call (555) 010-0142. Reply STOP to opt out.

    The risky version puts coverage status in a regular text and states an outcome no clinic can know.

  • Risky

    Come in this week and we'll get you a medical exemption.

    Safer

    If you think a health condition may exempt you, book a visit. Your state decides who qualifies, and we can help with paperwork it asks for.

    States decide exemptions. Providers can supply documentation the state may accept, but can't promise the result.

Disclaimer: not legal advice

This page is general information for clinics, checked against the federal sources listed below on 15 October 2026. It is not legal advice. Your state's rules, start date and reporting process control, and the federal rule is in active litigation. Talk to your counsel or your state Medicaid agency before you change how you handle eligibility. Nothing your clinic texts satisfies the work requirement for a patient.

The timeline

Section 71119 of Public Law 119-21 (H.R. 1), signed 4 July 2025, added section 1902(xx) to the Social Security Act. CMS published the interim final rule (CMS-2454-IFC) on 3 June 2026. It took effect on 31 July 2026, and comments were due the same day.

States must implement the requirement no later than 1 January 2027. They may start earlier through a section 1115 demonstration or a state plan amendment. CMS can grant a state a temporary "good faith effort" exemption. CMS expects to approve first requests for no more than 6 months, and every exemption ends by 31 December 2028 at the latest.

States had to begin outreach early. For a 1 January 2027 start, CMS says initial notices go out in July, August or September 2026. Notices must go by mail (or electronically, if the person chose that) plus at least one more channel, such as phone or text. Many of your patients may already have a state letter.

Who it affects and who is exempt

The requirement applies to non-pregnant adults aged 19 to 64 who are eligible for or enrolled in the Medicaid adult (expansion) group or certain section 1115 demonstrations, and who are not entitled to or enrolled in Medicare. They show 80 hours a month of work, community service or a work program, half-time school, or a combination, or income equal to 80 hours at the federal minimum wage (CMS fact sheet).

Exempt groups include pregnant and postpartum people, parents or caregivers of a child 13 or under or of a disabled person, American Indians and Alaska Natives, veterans with a total disability rating, former foster youth, people in drug or alcohol treatment, and people who are medically frail. The rule defines medically frail as people who are blind or disabled, have a substance use disorder, have a disabling mental disorder, have a disability that significantly impairs one or more activities of daily living, or have a serious or complex medical condition.

States check at application and at renewal, and may check more often. Applicants show one to three months of activity before the month they apply, depending on the state. If a state can't verify compliance, it must send a notice and give the person 30 calendar days to show compliance or an exemption.

Litigation status (as of 15 October 2026)

On 29 June 2026, a coalition of states sued in federal court in Massachusetts over provisions of the interim final rule, mainly how it treats medically frail people (Commonwealth of Massachusetts v. Oz). The Arizona Attorney General described the coalition as 24 attorneys general and two governors. The suit challenges the rule, not the law itself. On 29 July 2026 the court denied the states' motion for a preliminary injunction. Cross-motions for summary judgment were still being briefed in October 2026.

A separate lawsuit challenging the rule was filed on 18 September 2026 in federal court in Maryland by medical groups, a city and individual Medicaid enrollees (Taylor v. Kennedy). As of 15 October 2026, no court order had stopped the rule. That could change. Check the dockets and your state agency before relying on any date here.

What a clinic can and can't do

You can remind patients that rules are changing, tell them to open mail from the state, and point them to the state's reporting website or phone line. You can see patients who may qualify as medically frail or for another exemption, and document their conditions. CMS says states may accept documentation from many types of practitioners, including physicians, nurse practitioners, physician assistants, psychologists, counselors and clinical social workers. You can also host coverage-help hours with your enrollment staff.

You can't report hours for a patient through a text to your clinic, decide who is exempt, or promise that coverage will continue. Patients, or someone helping them, report to the state. The state decides. A reminder from you helps a patient act in time. It is not compliance.

A 90-day outreach plan

October: tell every adult patient that state coverage rules are changing and to watch the mail. Use a general Insecure text sent to your whole adult list. November: send a Secure text to patients your records show are on Medicaid, with your state's reporting link and what counts toward 80 hours. December: invite patients with conditions that may qualify as medically frail to book a visit. After the start date: remind patients at renewal time and when they mention a state notice, since they have 30 days to answer one.

Send only to patients who have agreed to texts from your clinic. These messages are informational, and FCC rules generally require prior express consent for autodialed texts to mobile numbers. Honor opt-outs within 10 business days and send between 9am and 8pm in the patient's time zone.

How to send it in BloomText

Export the patient list from your EHR or practice management system as a CSV with MRN, phone, first name and any columns you need, such as state_portal_url or renewal_month. In BloomText, open Broadcast and follow Details, Recipients and Message. Pick Insecure text (can't contain PHI) for general notices and Secure text with link (can contain PHI) for anything about the patient's own coverage. See create a broadcast.

Upload up to 20,000 rows and map the columns (add recipients). Add variables with fallbacks, such as {{first_name | there}} (personalize messages). Send now or schedule a date, time and time zone. Set the time between messages so your front desk can keep up with replies, and pause if the phones get busy (send and track).

Numbers on your org's opt-out list aren't texted. In an Insecure broadcast they show as Failed with the reason. Replies arrive as private one-to-one conversations in your team inbox.

Broadcasts need the Patient SMS Add-on, membership in a team with an assigned phone number, and a verified account. BloomText verifies new accounts before their first broadcast. Broadcast runs in the BloomText web and desktop apps. The BAA is included on every plan, including the free plan.

Sample Medicaid work requirement reminder texts

These are informational and consent-based: send them only to patients who have agreed to texts from your clinic. None of them satisfies the requirement or reports anything to the state. Fill state-specific details, such as the reporting link, from your CSV. Opt-out rules: under 47 CFR 64.1200(a)(10), honor STOP and other reasonable opt-out requests within 10 business days. The FCC is revising its separate rule on whether one opt-out covers unrelated texts (FCC Order 26-67), so check the current rule before you rely on a date.

  • General notice to all adult patients

    Insecure text: can't contain PHI

    Hi {{first_name | there}}, some state health coverage rules change on Jan 1, 2027. If you get a letter from the state about your coverage, read it and answer by the deadline. Riverside Family Clinic can help: (555) 010-0142. Reply STOP to opt out.
  • How to report

    Secure text with link: can contain PHI

    Hi {{first_name | there}}, starting {{state_start_date | January 1, 2027}}, many adults with Medicaid need to show they meet new rules to keep coverage. That can be 80 hours a month of work, volunteering or a work program, half-time school, enough income, or an exemption. You report to the state Medicaid agency, not to us. Find out how at {{state_portal_url | your state Medicaid website}}. Questions? Call Riverside Family Clinic at (555) 010-0142.
  • Possible exemption visit

    Secure text with link: can contain PHI

    Hi {{first_name | there}}, some people with ongoing health conditions are exempt from Medicaid's new work rules. If you think that may apply to you, book a visit with Dr. {{provider_last_name | your provider}}. Your state decides who qualifies, and we can help with paperwork it asks for. Call (555) 010-0142.
  • Renewal reminder

    Secure text with link: can contain PHI

    Hi {{first_name | there}}, your Medicaid renewal may be coming up in {{renewal_month | the next few months}}. Watch for mail from {{state_agency | your state Medicaid agency}} and answer by the deadline. If the state says it couldn't confirm you meet the rules, you have 30 days to respond. We can help: (555) 010-0142.
  • Coverage-help hours

    Insecure text: can't contain PHI

    Riverside Family Clinic is holding health coverage help hours on {{event_date | Saturday}} from 10am to 1pm. Bring any letters from the state. Questions? Call (555) 010-0142. Reply STOP to opt out.
  • Ask before sending deadline reminders

    Insecure text: can't contain PHI

    Hi {{first_name | there}}, Riverside Family Clinic can text you reminders about state health coverage deadlines. Reply YES if you'd like them. Reply STOP to opt out of texts from us.

    Send only to patients who already agreed to texts from your clinic. A YES reply arrives in your inbox. Record it in your own system.

Send Medicaid deadline reminders with the Patient SMS Add-on

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Frequently Asked Questions

When do Medicaid work requirements start?
States must implement them no later than 1 January 2027, under H.R. 1 and the CMS interim final rule published 3 June 2026. States may start earlier. CMS can grant a temporary good faith effort exemption that ends by 31 December 2028 at the latest. Check your state's date.
Does a text from our clinic satisfy the requirement for a patient?
No. Patients, or someone helping them, report activity or an exemption to the state Medicaid agency, and the state decides. A text from your clinic can remind and explain. It does not report hours, prove an exemption or keep coverage on its own.
Can our providers help a patient get a medically frail exemption?
Providers can see the patient and document their conditions. CMS says states may accept documentation from many types of practitioners, such as physicians, nurse practitioners, physician assistants, psychologists and clinical social workers. The state decides whether the patient qualifies.
Is the rule blocked by the lawsuits?
Not as of 15 October 2026. A federal court in Massachusetts denied the states' request for a preliminary injunction on 29 July 2026, and the case continues. A separate challenge was filed in Maryland on 18 September 2026. Rulings could change the rules, so check the dockets and your state agency.
Can a regular text mention that a patient has Medicaid?
Keep it out. A patient's coverage is PHI, and an Insecure text can't contain PHI. Send general notices as regular texts and anything about the patient's own coverage as a Secure text with link, which can contain PHI.
What consent do we need to send these texts?
These are informational texts. FCC rules generally require the patient's prior express consent for autodialed texts to mobile numbers. Send only to patients who have agreed to texts from your clinic, honor opt-outs within 10 business days, and send between 9am and 8pm in the patient's time zone. This is general information, not legal advice.

Sources

Last verified October 15, 2026.

  1. Public Law 119-21 (H.R. 1), section 71119 (signed Jul 4, 2025)
  2. Federal Register: Medicaid Community Engagement Requirement interim final rule (Jun 3, 2026)
  3. CMS fact sheet: Medicaid community engagement interim final rule (Jun 1, 2026)
  4. Court docket: Commonwealth of Massachusetts v. Oz, No. 1:26-cv-12962 (D. Mass.)
  5. Court docket: Taylor v. Kennedy, No. 1:26-cv-03705 (D. Md.)
  6. Arizona Attorney General press release (Jun 29, 2026): states sue over the interim final rule
  7. eCFR: 47 CFR 64.1200 (FCC robocall and robotext rules)
  8. FCC Order 26-67: revisions to the TCPA consent revocation rules (2026)