Medicaid Work Reporting Requirements: Verifying Compliance and Exemptions

Kinda Serafi, Lisa Sbrana and Liz Dervan, Manatt Health

H.R.1’s mandatory work reporting requirements expressly direct states to use an ex parte process, relying on reliable information to verify compliance and mandatory exemptions, and avoiding requests for additional information from individuals whenever possible. To meet the aggressive timeline required by federal law to implement mandatory work reporting requirements, states will need to quickly assess which data sources are currently available and which data sources require new state builds and/or data matching processes. This toolkit lays out the federal statutory definitions for qualifying activities and mandatory exemptions, describes whether the criteria can be verified via an ex parte review using data sources that are currently available or would require new state builds and whether a state needs to add a new question to its single streamlined application. Note: the toolkit was updated as of November 5, 2025. 

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