Written By: Marina Pascali, Senior Director, Cúram
Explore how H.R. 1 policy changes impact Medicaid and SNAP with strategies to navigate new mandates while supporting eligible communities.
H.R. 1, formally titled the One Big Beautiful Bill Act, was signed into law in July and set in motion changes at both the federal and state levels. These changes will fundamentally reshape how eligibility and enrollment will be determined for Medicaid and Supplemental Nutrition Assistance Program (SNAP) recipients.
Working through these changes means that agencies must understand the added administrative complexity, updated work requirements, and new funding implications of error rates, among others.
An Overview of H.R. 1’s Impact on SNAP and Medicaid
With the passage of H.R. 1, states now face new verification mandates, community engagement requirements, and oversight measures, which bring significant administrative and financial changes. Compliance will demand new data integrations, updated workflows, enhanced tracking, and detailed reporting, stretching already limited budgets and resources.
The Kaiser Family Foundation (KFF) estimates that federal health care spending cuts could reduce Medicaid funding by $911 billion over the next decade, straining state finances and jeopardizing coverage for millions. How states address this new financial responsibility will have widespread implications. Compounding the issue, states must implement key requirements within very short timeframes with a workforce that’s already stretched with high vacancy and turnover rates.
To effectively navigate these challenges, agencies will benefit from an agile planning and deployment strategy that is focused on workflow optimization, rethinking business processes, and leveraging automation and AI to reduce administrative burden on both caseworkers and beneficiaries. Agencies’ ultimate success lies in ensuring continued support for eligible individuals who rely on these essential programs.
How Do H.R. 1 Policy Changes Impact Benefits Eligibility and Enrollment?
Community Engagement Requirements Add Administrative Complexity
The new community engagement requirements for Medicaid eligibility are a key part of H.R. 1. To maintain health coverage, adults aged 19 to 64 who are enrolled in the Medicaid expansion group must now provide:
- proof of employment;
- work program participation;
- educational enrollment or;
- community service activities.
This will require comprehensive education and outreach campaigns to ensure Medicaid enrollees understand the new reporting requirements and compliance procedures. At the same time, agency caseworkers will need to understand and manage new eligibility requirements during both application and recertification processes, placing additional demands on an already overloaded workforce.
The administrative overhead extends to processing new forms of documentation, tracking compliance, and handling appeals, creating multiple checkpoints in a complex system of eligibility. Sophisticated, automated systems, leveraging new technologies such as AI and predictive modeling, will be essential for states to efficiently implement these new policies with minimal workforce expansion.
H.R. 1 demands a fundamental transformation of business processes to address these new requirements. Agencies must reconfigure workflows to streamline exemption management, accommodate new evidence types, and implement these verification mandates.
SNAP Work Requirements Extend to New Groups
Though work requirements are not a new concept for SNAP programs, agencies will face some similar challenges with the expansion of work requirements not only to new age groups but also to populations who are no longer exempt.
New waiver restrictions, elimination of previous temporary exemptions, and eligibility restrictions for certain populations create a need for additional verifications. Some of these changes might be simple configuration updates to existing integrated eligibility systems but others will require more complex business and workflow reevaluation.
More Frequent Verification Will Require a New Approach
H.R. 1 introduces verification mandates that significantly increase the frequency and complexity of Medicaid eligibility checks. These enhanced oversight measures include monthly address validation, quarterly deceased enrollee verification, and biannual redetermination checks for Medicaid expansion populations.
While designed to reduce improper payments and ensure program integrity, more frequent eligibility checks require more effort and risk increasing churn due to missed deadlines or administrative errors. For example, housing instability among Medicaid enrollees can make meeting address verification requirements particularly difficult. Self-service portals and more automated processing will go a long way to address the increased workload associated with more frequent verifications. Integrations with trusted external data sources can provide data on an individual’s health status, work hours, or educational status, potentially fully automating the verification process. Intuitive, self-service portals that provide clear guidance will reduce calls to agencies for clarification and assistance.
These tools can help reduce manual tasks while improving user experience and supporting caseworkers managing increased workload volumes.
Retroactive Coverage Windows Narrows Support
H.R. 1 brings major changes to retroactive coverage for Medicaid and the Children’s Health Insurance Program (CHIP). What was a uniform approach now varies based on population. This additional complexity will need to be accurately introduced to existing eligibility and benefit determination systems to avoid errors.
Agencies will need systems to differentiate between expansion and non-expansion groups, applying the new retroactive coverage rules accurately. Purpose-built platforms that can adapt and meet evolving requirements through flexible configuration and customization options will make these changes easier.
SNAP Error Rates Will Impact Future Funding
Beginning in 2028, the SNAP program will require, for the first time, that states with payment error rates at or above 6% contribute to the SNAP benefit costs. This creates a feedback loop where administrative accuracy directly impacts future funding levels, making precise eligibility determination increasingly critical for fiscal sustainability, and successful planning.
Target strategies to help improve accuracy and reduce errors include discrepancy checks, advanced analytics to identify errors, and risk scoring to prioritize second party reviews. Automation will also be key to reducing the occurrence of manual errors.
Moving Ahead with Strategic Implementation
Flexible systems designed to support changes to verification processes and workflows are best positioned to support agencies implementing these new policy changes.
An agile planning approach will be critical as guidance evolves within tight timeframes. New data integration strategies will play a key role in automating verification processes while targeted AI use cases can streamline efforts for both beneficiaries and caseworkers. As agencies navigate these challenges, state partnerships with experienced leaders will be essential. Cúram has focused on the needs of health and human services agencies for over 30 years, providing solutions to navigate constantly changing landscapes. For insights and actionable steps to simplify H.R. 1 implementation, read our blog post on strategic approaches for government agencies.
About the Author
Senior Director at Cúram
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