Templates & Toolkits | Oct 6, 2025

Strategic Verification Hierarchy for Medicaid Work Reporting Requirements

Kinda Serafi, Patti Boozang, Lisa Sbrana and Judy Arnold, Manatt Health

States are working towards establishing a robust data verification process to meet H.R.1’s ex parte verification requirements and determine individuals’ compliance with or exemption from Medicaid work reporting requirements. As part of this work, states are evaluating their data sources and systems to identify where they need to prioritize new data matching sources and processes and information technology (IT) systems enhancements.

One new IT systems’ enhancement is a verification hierarchy that enables states to efficiently identify individuals who can be exempted from or deemed compliant with work reporting requirements by prioritizing the most accessible and reliable data sources. This toolkit lays out a potential step-by-step strategic verification hierarchy for identifying compliance with or exemption from work reporting requirements at application. States should use this toolkit as a jumping off point as they assess their own state-specific eligibility systems’ capabilities and available data sources.

For a more detailed description of potential data sources for verification, see the State Health and Value Strategies toolkit, “Medicaid Work Reporting Requirements: Verifying Compliance and Exemptions.”