States continue to explore solutions to federal rule changes for public benefit programs
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States must consider new data sources and approaches to ensuring their benefit systems are on track to comply with impending changes to the Medicaid and SNAP program, one expert says.
The start of 2026 means states have the next 12 months to comply with new federal work requirements and cost sharing rules for public benefit programs like Medicaid and the Supplemental Nutrition Assistance Program. However for many states, the path to making those changes is still murky despite the fast-approaching deadline.
Under HR 1, for example, federal officials determined that, to remain enrolled in state Medicaid programs, certain beneficiaries must adhere to community engagement requirements, such as participating in community service, education or the workforce. And for SNAP, states will have to pay a larger share of costs based on payment error rates.
States are facing a “significant burden … to revamp their eligibility and enrollment systems to be able to capture [new] employment or work requirement data,” said Akeiisa Coleman, senior program officer at the Commonwealth Fund.
States have typically leveraged wage information from sources like their own data systems or services like Experian to determine benefit eligibility and administration, but the new federal rules could push officials to seek additional data resources to support their rule implementation efforts, Coleman said.
As an example, she pointed to Louisiana, which has been working with the Centers for Medicare and Medicaid Services to pilot an income verification app since last year. The app aims to streamline residents’ and officials’ efforts to confirm that they meet the new Medicaid eligibility requirements. Enrollees can share their payroll data directly through the app for officials to review, reducing the need for manual paperwork submissions.
Since May, the Louisiana Department of Health has texted more than 13,000 enrollees to opt into the verification service, but only 7% of beneficiaries have done so as of October, and results of the tool’s impact on enrollment are unclear.
When designing and launching solutions for the eligibility verification process, officials should consider the burden such tools and services place on residents, which can impact the likelihood residents use them, Coleman said. For instance, many Americans work or attend school part-time or participate in the gig economy, which could complicate how they are able to document and report the required data to prove they meet the amended SNAP or Medicaid requirements.
Several states, like Missouri, have already started exploring the use of platforms that gig workers can use to upload their paystubs and other wage-related data to generate income reports that benefit officials can more efficiently review for eligibility and enrollment.
Indeed, recent research underscores that benefit enrollment and application processes that are designed for enrollees to easily navigate and interact with can help ease states’ rollout of the SNAP and Medicaid changes.
But as states explore how to leverage tech and data to modify their benefit systems, Coleman cautioned against the temptation to turn to artificial intelligence as a means to their solutions.
“I am dubious of how useful AI will be in the context of enrollment and eligibility, given how many different eligibility categories there are and how much eligibility varies from group to group within a state,” she said.
In a single family unit, for instance, members can qualify for different programs or benefits, and those variabilities can prove difficult for an AI product to adequately and accurately capture, especially in the tight timeframe states are already facing, Coleman explained.
States can instead turn to existing data sources they haven’t tapped yet to support their efforts to verify enrollees’ eligibility and compliance with the new program rules, she said. For example, workforce training systems or databases that report college enrollment can serve as critical resources that include additional data states need to work toward HR 1 compliance, such as informing automated renewal processes.