Report: Steps states can take to navigate HR 1 benefit rules
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States are racing against the clock to implement changes to their benefit systems under HR 1. New research from the Beeck Center for Social Impact and Innovation suggests cross-agency and resident collaboration can help support their efforts.
New research explores how states are approaching integrated benefits eligibility and enrollment systems. States’ movement toward such systems comes amid the looming deadline to implement federally required changes to how Medicaid is administered under H.R. 1.
Research released last week from the Beeck Center for Social Impact and Innovation at Georgetown University offers suggestions on how state leaders can implement integrated eligibility and enrollment programs.
States’ are rethinking the design and administration of integrated benefits eligibility and enrollment systems as they face mounting pressure to meet the Jan. 1, 2027, compliance deadline for new Medicaid work requirements outlined in HR 1. But the federal government has provided scant guidance thus far for states as they scramble to reconfigure their Medicaid programs to comply with the new requirement that adults 19 to 64 years old verify that they work, volunteer or attend a work or education program for 80 hours a month in order to maintain their Medicaid coverage.
Late last year, the Centers for Medicare and Medicaid released preliminary guidance that clarified some HR 1 rules, but still left states “in a little bit of a guessing game” when it to comes to finalizing their plans to implement the changes, said Ariel Kennan, senior director at the Beeck Center for Social Impact and Innovation at Georgetown University.
The guidance stipulates, for example, Medicaid beneficiaries subject to work requirements must provide proof that they fulfilled such requirements for at least one month, depending on a state’s specifications, for their coverage to be renewed. The guidelines also prohibit states from dictating in which month a beneficiary must complete the work requirement and from requiring a beneficiary to fulfill the requirement in consecutive months, according to the Centers for Medicare and Medicaid.
But the federal government offers less clear rules on how states should establish processes to determine if a beneficiary is subject to meeting the new work requirements. The guidance instructs states to use “reliable information” available to them, such as case records, payroll data or Medicaid provider payments.
States must still wait for final direction on the topic, as CMS said it “expects to provide additional guidance … including guidance on the use of reliable data sources and instructions on documenting such policies and procedures.”
As states wait for the official rules to inform how they implement their Medicaid benefits systems, which will be announced in June, they must calculate the risk of moving forward with program updates in the meantime, Kennan said. That means as they interpret current CMS guidance to meet the fast approaching compliance deadline, they must hope the federal government ultimately has the same interpretation.
But there are approaches states can take that can help them navigate and adapt to evolving changes in federal or state policy, according to the Beeck Center’s research.
Increasingly, states are turning to an integrated approach to eligibility and enrollment systems, through which a resident can access multiple benefit programs using a single process, Kennan said.
Maryland, for example, launched its Maryland Benefits One Application tool last year, which enables people to apply to up to five benefit programs at once. By integrating separate benefit program databases, the tool streamlines the application process for clients and the verification process for benefit administration staff.
One step states can take to build integrated benefit systems is to “bridge gaps between state legislators and their implementation team to come together and find common, successful ground,” Kennan said.
Benefit system administrators and technologists, for example, can offer information sessions to help legislators better understand how eligibility and enrollment systems function, which is helpful for informing policies that aim to improve the function or delivery of such programs, she explained.
The report also suggests that state officials maintain a shared repository where benefit system code and technical documentation is accessible to IT teams, policymakers and stakeholders involved with implementing and maintaining system changes. Collaboration between policy and implementation leaders can help agencies better “synchronize the effective dates of legislation with feasible development cycles and implementation roadmaps,” researchers wrote.
States should also consider how they can leverage the procurement process to support the development of integrated benefit systems, Kennan said. Rather than relying on one vendor to complete an entire project, which is often time- and cost-intensive, particularly for states looking to implement changes quickly, officials can adopt a modular approach to procurement.
A modular procurement approach, for example, could entail a state agency exploring how a vendor could be tasked with completing one part of a project or system, Kennan explained. This model enables tech leaders to implement changes or updates to integrated systems in pieces, instead of tackling the entire infrastructure at once, and it could also expose state governments to a more diverse pool of vendors, according to the report.
Another critical tool for states to leverage to inform their approach to HR 1-compliant benefit systems is the voice and input of their residents, Kennan said.
“Real people know their stories, their communities and the needs that they have” when it comes to understanding how their coverage eligibility could change under the new rules and how they can navigate new enrollment and renewal processes,” she said.
Several states have created committees made up of residents who “are able to talk about challenges that they and their community might be having with the [benefit] system, or overall accessing help,” Kennan said. Those insights can inform leaders if they should, for example, clarify language used in messaging about HR 1’s impact on their benefit eligibility or target pain points in the application form, such as improving the flow of questions.