Feds quietly moved a Medicaid technology project to a central data hub as new eligibility requirements approach

The Centers for Medicare and Medicaid Services recently told states it will no longer move an “Eligibility Made Easy” — or Emmy — application programming interface into production and will instead incorporate that technology designed to support Medicaid eligibility checks into the existing Federal Data Services Hub, Nextgov/FCW has learned from multiple state Medicaid agencies.

“In the interest of allowing CMS to focus their resources and work with states more effectively, we are consolidating efforts from Emmy API into the Federal Data Services Hub (aka the ‘Hub’ or ‘FDSH’) instead,” the federal agency told the Colorado Department of Health Care Policy and Financing earlier this month.

The shift means states will be able to connect with a familiar data system to check if a Medicaid recipient is enrolled in school or is a disabled veteran exempt from forthcoming work requirements mandated by the One Big Beautiful Bill Act. CMS is relying on data from the National Student Clearinghouse and the Department of Veterans Affairs for those verification features, multiple state Medicaid agencies said.

A CMS spokesperson said the agency is working to make additional data sources and APIs available through the Federal Data Services Hub before most states have to implement Medicaid work requirements on Jan. 1, 2027. One employee with the Department of Health and Human Services who spoke with Nextgov/FCW praised the CMS Federal Data Services Hub integration because it would give states fewer technical connections to worry about for Medicaid applicant data verification.

But states are split on using CMS data verification services and Medicaid policy experts told Nextgov/FCW that those federal offerings won’t be able to fulfill all eligibility check needs.

“I do think that one of the strengths of CMS' approach is really that it's modular. And states have that flexibility,” said Verlon Johnson, chief government and corporate affairs officer for Acentra Health, in an interview.

Spokespeople for Medicaid agencies in Colorado, North Carolina, West Virginia and Georgia said their states plan to use one or both of the CMS data verification features to support Medicaid eligibility checks.

States that use the free features could see technical implementation costs fall by reducing data development and maintenance costs, Johnson said.

Even so, spokespeople for Medicaid agencies in Pennsylvania, North Dakota, Vermont, Missouri, South Dakota, New York and Illinois told Nextgov/FCW that they were not planning to use the Emmy API. Several of those states said they are already working with contractors on Medicaid data verification needs, suggesting they don’t plan on relying on the Federal Data Services Hub offerings either.

A spokesperson for the Pennsylvania Department of Human Services told Nextgov/FCW that the agency “did consult and review the Emmy product, but ultimately it did not meet our needs nor help us meet the requirements and timelines in [President] Donald Trump’s disastrous and unfunded mandates in [the One Big Beautiful Bill Act].” 

“Further, it would not reduce caseworker and client burden. Additionally, CMS was unable to provide details on total cost, support expectations, and long-term maintenance of the product,” the spokesperson added. Pennsylvania is instead working with consulting giant Deloitte on implementing eligibility checks and beefing up IT staff. 

CMS did not respond to a request for comment on Pennsylvania’s concerns by publication time.

“Missouri determined that while CMS-provided shared tools offer valuable baseline concepts, leveraging and expanding upon technology solutions already embedded within Missouri’s enterprise environment provided a faster, lower-risk path to meeting the strict federal technical implementation deadline,” said a spokesperson for the Missouri Department of Social Services. 

Missouri is working with SteadyIQ, Equifax, ID.me, ServiceNow, RedMane and Information Resource Group on implementing various aspects of new Medicaid work requirements.

Under the One Big Beautiful Bill Act signed into law last year, most states must verify that certain Medicaid recipients have either worked, completed community service, or enrolled in school for at least 80 hours per month. The law includes exemptions for veterans with a total disability rating, medically frail patients and other specific categories of individuals.

While the law included $200 million for state implementation grants, CMS has taken several additional steps to help ease the burden of new requirements. 

The Emmy API’s consolidation into the Federal Data Services Hub is one of those steps. CMS has also created a mobile-friendly Emmy app — which allows Medicaid recipients to pull income and student enrollment data — announced discounted Medicaid software offerings from technology companies and partnered with the General Services Administration to accelerate vendor access to an acquisition schedule.

The CMS spokesperson said that the agency is also “providing technical assistance, helping states connect to available data sources and APIs, coordinating with eligibility system vendors, and supporting implementation planning. States are taking different approaches based on their existing systems, and CMS is supporting those efforts with flexible tools and technical guidance.”

But even with all of the federal technology offerings, states are likely to struggle to implement Medicaid work requirements. 

“There are a lot of things that [the Emmy] API doesn't cover, or that the consent-based verification tool doesn't cover, and those are connected with probably the largest exemption category, which is medical frailty,” said Danny Mintz, director of safety net policy for Code for America, in an interview.

At issue is a recent CMS interim final rule holding that states can’t use medical diagnostic codes for health conditions to find that a Medicaid applicant is medically frail and therefore exempt from work requirements. The applicant must instead provide additional proof their health condition prevents them from working, Mintz explained.

“There's not really necessarily a good data source that covers those cases at this point, and they're not part of the data sources that CMS is making available for free through Emmy,” Mintz said. 

The Trump administration’s definition for medically frail is currently being litigated in court, with Democratic states seeking a less strict interpretation, according to Politico. The outlet also detailed how states are struggling to manage the cost of Medicaid technology upgrades and new IT staff amid tightening budgets.