Center on Budget and Policy Priorities

How States Will Implement H.R. 1’s Medicaid Policies, Including Those Taking Coverage Away for Not Meeting Work Requirements

Analysis examining how states are likely to implement H.R. 1’s Medicaid provisions, including work requirements and other policies that can put eligible people at risk of losing coverage due to administrative barriers.The resource outlines key implementation timelines under both early and standard implementation scenarios, highlighting the first and last enrollee cohorts affected, major state policy decisions, critical eligibility and enrollment deadlines, and policy effective dates that apply across states and implementation pathways.

States Need More Time to Prepare for Medicaid Work Requirement

States face an unrealistic timeline to implement Medicaid work requirements by January 2027 due to the compliance demands of data integration, system upgrades, and application portal modifications. These challenges are compounded by limited federal guidance, technical system constraints, and insufficient state capacity, making it difficult for states to adapt and administer the changes effectively. Consequently, those inside and outside the expansion group may face increased barriers to accessing these public benefits due to administrative strain.

Coordinating Medicaid and SNAP Work Requirements to Streamline Determinations

States can simplify and streamline determinations for individuals and agenciesand, reduce administrative burden, and minimize unnecessary coverage loss by leveraging the overlap in compliance activities and exemption reasons for individuals applying for or enrolled in both programs. Strategies on aligning exemptions, sharing data, and integrating verification processes highlighted through process flows and crosswalks.