Written By: Paul Norton, Madison Olmsted, and Remi Fernández
In July 2025, Congress passed H.R. 1, the budget reconciliation bill that included sweeping changes to Medicaid, Medicare, and the Supplemental Nutrition Assistance Program. Among the Medicaid provisions, H.R. 1 introduces new work and community engagement requirements, along with more frequent eligibility redeterminations, for many enrollees.
For community-based organizations (CBOs) that support Medicaid enrollees, these changes raise a practical question: how can CBOs help clients keep their coverage once the new rules take effect? This covers what the requirements are, why large scale verification processes will inevitably leave some people out, and where CBOs can and will inevitably step in to close that gap.
What H.R. 1 Requires
Beginning January 1, 2027, most Medicaid enrollees aged 19 to 64 must complete 80 hours per month of qualifying activity, such as employment, participation in a work program, community service, or enrollment in an educational program, unless they qualify for an exemption. The same date brings six-month eligibility redeterminations for many adults, replacing the current annual cycle.
The law includes numerous exemption categories, covering parents and caregivers of young children or disabled family members, veterans with a total disability rating, individuals meeting Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families (TANF) work requirements, and people navigating a documented health condition that limits their ability to work. Each exemption category carries its own documentation standard, and some of those standards, including the one for health-related exemptions, are still being finalized by federal and state agencies.
Estimates of the impact vary, but research suggests that between three and seven million people could lose Medicaid coverage nationally due to work requirements. How much of that decline actually happens will depend heavily on how well states and their partners coordinate communications and share information. For CBOs, this is the heart of the issue: an exemption or verification only protects a client’s coverage if someone identifies it, documents it, and submits it in time.
Why Ex Parte Verification Will Not Catch Everyone
States are required to attempt to verify a member’s compliance or exemption status using existing data, a process known as ex parte, before ever asking the member for information directly. In practice, this means state systems check wage and tax records, other public-benefit enrollment data, and federal databases to flag members who are already compliant or exempt.
Ex parte verification will reduce or eliminate the documentation burden for a meaningful share of enrollees automatically, but it depends on the underlying data being complete, current, and consistent across systems. Unfortunately, this standard is usually not met, and a few groups are particularly likely to fall through the cracks:
- Individuals experiencing homelessness who qualify for a medical frailty exemption, but do not frequently interact with the healthcare system.
- Workers in nontraditional employment, including gig work, seasonal work, or self-employment, whose income and hours are not captured in state wage and tax data.
- Caregivers whose qualifying relationship, such as caring for a dependent child under age 14 or a disabled family member, is not documented or linked within Medicaid eligibility systems.
- Individuals with a documented exemption in state data sources that does not reconcile cleanly with their Medicaid record due to data mismatches.
A recent study published in Health Affairs Scholar estimated that nearly half of the individuals subject to work requirements would qualify for an exemption, but were likely to face barriers in getting these exemptions documented and properly shared with their state agencies. CBOs and their partners play a critical role in closing this gap.
The Critical Role CBOs Can Play
Due to the relationships and trust that they hold within their community, CBOs often have current, first-hand knowledge of a client’s employment situation, caregiving responsibilities, or health circumstances well before that information ever reaches a state eligibility system, if it reaches it at all.
Consider a client who recently started part-time work, enabling them to meet the work requirements to enroll in SNAP. Under H.R. 1, their successful SNAP enrollment should automatically exempt them from the Medicaid work requirement as well, but a mismatch between the two systems could cause their compliance status to go unrecognized, putting their coverage at risk despite doing everything they were supposed to do. A care coordinator who already knows about their CalFresh enrollment is positioned to catch that mismatch and route them to a benefits navigator before coverage lapses.
Or consider a single parent caring for two young children, who qualifies for a caregiver exemption that has simply never been formally verified in the state system because no one has flagged it. They have no reason to know they need to assert this exemption, and the system has no reason to apply it without documentation. A CBO that already serves them through a family resource center, a home visiting program, or a similar touchpoint can identify the exemption, help gather documentation of their children’s ages, and connect them to a navigator who can file it, closing the gap before it becomes a coverage loss.
What CBOs can do right now
As state and federal officials finalize implementation guidance for work requirements, there are steps that CBOs can begin taking right now:
- Map your client base: Which of your clients are adult Medicaid members? What are the likely challenges they may face in maintaining coverage under the new requirements?
- Identify your unique knowledge: What information do you have regarding your clients’ employment, life or health circumstances that may help them maintain coverage?
- Reach out to your partners: Health plans, county agencies, and local conveners, such as United Way chapters, are counting on partner organizations to fill data gaps. Proactive conversations with these partners can inform the workflows your organization will build to help your clients stay covered.
- Build a data collection and sharing process: How can you ensure this crucial information can be easily shared, either by the client as part of their enrollment process or by your organization with the state to verify eligibility?
- Provide volunteer opportunities: For individuals that need to fulfill the work requirements, how can your organization provide an opportunity through volunteering, and ensure this information is captured?
While we all await more detailed guidance from state and federal officials, these tactical steps will prepare community-based organizations to continue delivering services that your clients depend on and keep them enrolled in the programs that are crucial for their health and well being.