States have just a few months to implement Medicaid work requirements for certain enrollees. CITIZ3N Government Solutions survey data reveals a significant gap between policy awareness and compliance readiness ahead of the deadline. At the time of the survey in June, almost 57 percent of Medicaid participants reported receiving no information from their state program, and 25 percent were unsure if the rules even applied to them.
CMS says 43 states and the District of Columbia cover populations subject to the 80 hours per month work requirement, referred to as Medicaid community engagement, although numerous exclusions and exceptions mean not every adult expansion enrollee will be obligated to demonstrate compliance.
Implementing this policy requires states to adapt their eligibility, verification, and operational infrastructure while also launching a massive communications push. The time for strategy is over. Medicaid programs must focus on operational execution to minimize inappropriate disenrollments.
The Work Requirement Implementation Timeline Creates Challenges for States
Under the new law, states must verify community engagement at application and renewal and may conduct additional checks between renewals. Separately, many of the same adults will move from annual to six-month Medicaid eligibility renewals beginning January 1, 2027.
Congress enacted the requirement in July 2025. CMS issued initial implementation guidance in December and the Interim Final Rule in June 2026, leaving states with a compressed implementation window before January 1.
The policy instructs states to use available data from reliable sources to check for an individual’s compliance or exemption, so they must build an infrastructure that supports system integration and a seamless user experience.
In a CITIZ3N webinar, Kevin Bagley, the State of Nebraska’s former Medicaid director, said, “It’s very much a ‘build the airplane as you fly it’ analogy. That is where we are right now.”
Enrollees Need Clear Communication on Changes
Medicaid eligibility can be very confusing. Work requirements make it even more perplexing for enrollees. States must deploy comprehensive communications campaigns.
Traditional outreach methods can miss beneficiaries when contact information is outdated, mail is returned, or access and preferences vary across communication channels. Reaching them requires a multi-lingual, multi-channel effort, from email and snail mail to texts and apps and even media campaigns. Nebraska aired radio and TV ads and offered a hotline when they implemented the new provisions in May.
Messages must be straightforward with actionable guidance. According to the CITIZ3N survey, nearly 55 percent of respondents said a step-by-step checklist would be most helpful. Four in 10 wanted text or email reminders, and one-third wanted a website or app to check their status.
A Medicaid beneficiary may receive notices from their Medicaid agency, managed care organization, CMS, the Social Security Administration, or a community organization. These entities should coordinate outreach to reduce confusion and increase reach.
Better data sharing between states and health plans will also help ensure that the right people receive the right information. Since the new rules only affect a specific adult Medicaid population, agencies should strive for targeted communications as much as possible.
Connecting Data Will Minimize Member Burden
Every unnecessary document request, manual review or member touchpoint adds work for agency staff and an opportunity for errors. Member contact should only come after all existing data has been exhausted.
To improve eligibility determinations, Medicaid programs are looking to link systems like claims history, IRS data, student databases, and Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families (TANF) enrollment. Several states are using consent-based verification of W-2 income and verification of self-employment/gig income. When reliable data establishes compliance or that the requirement does not apply, states should be able to resolve the case without asking the member for duplicative documentation.
States must build a decoupled, modular infrastructure that links information across systems without a major overhaul of core Integrated Eligibility Systems (IES). This modular format enables agencies to quickly adapt their systems and adjust as guidance changes, new sources become available, or additional rules are implemented.
The mandate for more frequent verification adds work for Medicaid agencies that are already facing staff and budget constraints. Connected systems enable programs to automate some of the workflow, such as cross-referencing records, document intake, data extraction, and targeted member communication. Automation can resolve routine verification and eligibility steps, but states remain accountable for the final eligibility action and need clear human-review pathways when evidence is incomplete, conflicting or requires judgment.
January 1 should not be viewed simply as a technology deadline. Successful implementation will depend on whether states can administer the requirement accurately, use reliable data before requesting documentation, preserve due process, and avoid making the complexity of the policy the member’s problem.
The author, Rob Miller, is General Manager & Senior Vice President of CITIZ3N Government Solutions, a Softheon brand.