States have less than a year to implement new Medicaid community engagement (CE) requirements, but many lack the systems needed to manage the new administrative burden.
Under the new rules, work requirements are now mandatory for all states with Medicaid expansion. States must verify that these enrollees are participating in work or qualifying community activities, or are exempt, before validating their enrollment. The new regulation also requires eligibility confirmation every six months, rather than once a year.
The concept is straightforward, but CE enforcement will be a high-volume documentation and outreach operation. Medicaid agencies must identify who is not exempt from the new mandate, communicate the changes, obtain necessary verification, and confirm compliance, all without creating barriers to coverage. CITIZ3N’s analysis suggests up to 25 percent of adults in Medicaid expansion states could ultimately be subject to CE requirements.
States must enhance their technology systems to manage these new requirements.
The Operational Reality of CE Verification
CE requirements involve multi-layered verification, reshaping the entire process. Medicaid agencies must prepare for:
- New exemption checks in eligibility workflows
- Cross-program data checks
- Surges in documentation volume
- Continuous multi-channel member outreach
The eligibility requirements will be new to members, so they will need education and explicit guidance on what they need to do and when, as well as reminders and ongoing support. With re-verification required every six months, this communication will be an ongoing initiative, rather than a periodic exercise.
Contacting Medicaid participants for documentation can be challenging because many have limited access to technology or inconsistent contact information. To overcome these barriers, states must deliver multilingual communication across many channels, from email and snail mail to texts and apps.
This is a population that often benefits most from clear guidance, education, and supportive pathways to coverage. When processes are fragmented or difficult to navigate, it can create confusion, delays, and unnecessary barriers to maintaining the coverage people rely on.
Failure to account for these changes increases the likelihood of inappropriate coverage loss through issues like missed notices, incomplete paperwork, processing delays, and other administrative errors. States that rely heavily on manual processes face higher risks. In past work requirement implementations, thousands of people lost coverage, demonstrating the importance of system readiness.
Managing these new demands will require automation and data integration.
Automation Makes CE Verification Manageable
States don’t have the staff to contact every Medicaid member, let alone manage ongoing correspondence and incoming paperwork. Not to mention, requiring members to verify their status creates many hurdles to sustaining coverage. Agencies must find a way to avoid unnecessarily reaching out to beneficiaries whenever possible.
States are sitting on plenty of data that can help them minimize the need for manual follow-ups. Cross-referencing other data sources, such as SNAP/TANF records and wage databases, can confirm compliance without input from the member.
Leveraging all this information requires states to connect all of their systems. States have varying levels of integration, but many are still stuck in silos. In the coming year, system integration will be essential.
Keeping up with this new verification expectation will be impossible without automation. Teams are already stretched thin, and the manual documentation backlog will spiral quickly.
Automated cross-referencing saves Medicaid agencies time, improves verification accuracy, and minimizes member burden. Agencies can then target a smaller subset of individuals for outreach.
At the same time, states should encourage digital self-service without making it a requirement. Online portals, mobile tools, and guided workflows can make it easier for members to submit documents, check status, and receive updates on their own time.
Teams can scale communication efforts with automation. These software solutions identify members who need verification, send personalized messages, track task completion, and manage follow-up notifications. States should also automate documentation intake and review.
Modular Solutions Accelerate Implementation
CE policies are complex, politically volatile, and likely to change. In fact, the final CMS rules are not due until the end of June 2026, even though enforcement must start by Jan. 1, 2027. With the incredibly short implementation timeline, states can’t afford to hardcode CE into their integrated eligibility system.
States should explore a modular, decoupled approach to CE compliance. In fact, CMS’s IT guidance has been moving in this direction. When implemented correctly, a modular CE component becomes an extension of the existing ecosystem that solves a specialized problem.
CE programs are an ongoing, evolving operational undertaking. States will be judged by both compliance and their real-world impact on members. Modernizing must start now to meet federal guidelines and prevent inappropriate coverage loss. Help is available; Several health technology companies have pledged to CMS that they will support states in preparing and implementing these requirements.
The author, Rob Miller, is General Manager & Senior Vice President at CITIZ3N Government Solutions, a Softheon brand.