Change Log

Regulatory Change Log

July 4, 2025New
H.R. 1 is signed into law. It creates the community engagement requirement and moves expansion adults to six-month renewals.
March 6, 2026Guidance
CMS sends states a State Medicaid Director Letter on six-month renewals, including the two ways to transition.
June 1, 2026New
CMS publishes interim final rule CMS-2454-IFC on community engagement.
July 31, 2026Deadline
The comment period on the interim final rule closes.
July 1 to September 1, 2026Deadline
Advance outreach notices fall due, with each state's date set by its look-back period.
October 29, 2026Ruling
A federal court strikes down part of the medically frail definition in the interim final rule.
January 1, 2027Effective
Work requirements and six-month renewals take effect.
December 31, 2028Deadline
Every good-faith exemption that delays a state's start runs out.

Version	Date	Change
1.0	October 2026	First publication, covering federal rules and guidance issued up to October 2026.
1.1	November 2026	Copy revised throughout, and the October 29 frailty ruling added.
Planned	When CMS finalises CMS-2454-IFC	Update the requirements and exemptions to match the final rule.