New report and toolkit offers states strategies to streamline HR 1 implementation
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A nonprofit recently released guidance for states as they implement changes to their Medicaid eligibility and enrollment systems to comply with new work requirements.
States have less than a year to implement major changes to their Medicaid eligibility and enrollment systems to comply with new work requirements established under HR 1. A report from nonprofit design studio Civilla aims to help expedite the process for state leaders by offering templates for online and digital Medicaid applications.
The report, released last week, also includes a toolkit of form templates and policy guidance to help reduce states’ burden of altering Medicaid applications and improve residents’ experience navigating the new benefit enrollment process.
The toolkit offers “a whole suite of tools that could be adaptable to states and be implemented in this very short timeframe they have,” said Rachel Rosenbaum, design lead at Civilla.
Under HR 1, state Medicaid programs must require beneficiaries ages 19 to 64 years to participate in a job, education, work program or community service to maintain their coverage. For an estimated 18.5 million people covered by the federal-state health program, the new policy means they will have to continuously verify they participate in some community engagement for at least 80 hours a month or that they qualify for an exemption.
The federal requirements also mean state leaders are responsible for implementing frontend and backend changes to their eligibility and enrollment systems to comply with the federal mandates. The Civilla toolkit and report offers user-tested and policy-reviewed templates in an effort to cut out some of the work for states so they can meet the Dec. 31, 2026, compliance deadline, Rosenbaum said.
One priority states should consider is to weave work requirement-related questions into existing Medicaid applications, rather than implementing a separate application or questionnaire to collect such information, the report stated.
Doing so can help streamline the state’s data verification process by reducing the amount of forms a staff member must track and manage, which could otherwise create backlogs if benefit system staff have to reach out to enrollees every time they need to contact an applicant for an error or missing information in the form, Rosenbaum said.
Additionally, as states implement HR 1 changes amid shrinking budget and resource capacity, “the cost of updating processes is much lower than the whole cost of … creating something new and trying to plug it in on the back end,” she said.
States should also consider incorporating conditional skip logic functions to simplify the application process for enrollees, particularly when it comes to collecting HR 1 exemption-related information from residents. Such exemptions could include whether someone is pregnant, a caregiver of certain individuals or living with certain medical conditions, Rosenbaum said.
The report also specifies that states present any and all exemption questions before work reporting questions in the general flow of the online application to enable skip logic and conditional question features.
“This is the core advantage of online applications — residents who don’t need to report work never see those questions,” the report explains. This model also “gives eligibility workers complete information to properly assess eligibility status and duration for all household members applying for Medicaid,” according to the report.
Another way states can simplify the new Medicaid application process for residents is to adopt broader self-attestation policies with regard to an enrollees’ proof of exemption or community engagement. Doing so could help reduce administrative burden and procedural denials, Rosenbaum said. Self-attestation refers to an enrollee’s ability to self-report that they meet a certain requirement or exemption without having to provide documentation to verify it, she explained.
While state leaders may fear that self-attestation could enable bad actors to defraud Medicaid programs, there is little evidence to support such claims, Rosenbaum said. However, federal rules surrounding self-attestation are still not clear yet, which is why states should also be prepared to leverage existing data systems to verify work and exemption conditions among enrollees.
For instance, to verify resident’s exemption and work statuses, states can integrate the application process with supplemental security income and social security disability insurance records, education databases, medical claims data and other program systems to automate the verification process, according to the report.
Ultimately, as states battle a fast-approaching compliance deadline and unclear guidance from the federal government, Civilla’s toolkit aims to help states “ensure residents can actually get benefits they’re eligible for and stay on benefits that they’re eligible for,” Rosenbaum said.