Must sentencing courts orally pronounce nonmandatory conditions of supervised release to protect defendants' right to be present and to put them on notice of the conditions they must follow to avoid reincarceration?

Federal criminal defendants have a right to be present at sentencing, grounded in the Fifth Amendment Due Process Clause and codified in Federal Rule of Criminal Procedure 43(a)(3). Circuits , however, are split as to whether this right requires sentencing courts to orally pronounce non-mandatory conditions of supervised release at sentencing or if these conditions can be added later to the written judgment. Seven circuits require all non -mandatory conditions to be orally pronounced, while two do not . Must sentencing courts orally pronounce nonmandatory conditions of supervised release to protect defendants’ right to be present and to put them on notice of the conditions they must follow to avoid reincarceration?