What the Law Actually Requires

H.R. 1 Section 71119 conditions Medicaid eligibility for expansion adults on completing at least 80 hours per month of qualifying community engagement activities. Those activities include employment, participation in a workforce development or job training program, enrollment in an educational program at least half-time, community service, or any combination of the above. States must verify compliance at both initial applications, using a look-back period of one to three months, and at each six-month redetermination going forward. The law also moves the Medicaid expansion population from annual to semi-annual eligibility reviews, effectively doubling the administrative workload for eligibility systems overnight.

What makes this harder is what the law does not do easily: automate. Employment data for traditional W-2 workers can be pulled through the Federal Data Services Hub via tools like Equifax’s The Work Number, which delivers real-time payroll data from over four million contributing employers. That covers a meaningful portion of the population. But community engagement activities, including volunteering, localized vocational training, peer mentorship, and informal caregiving support, live outside any centralized database. That gap is where states will feel the most pressure.

The Real Risk Is Procedural, Not Behavioral

The Arkansas experience offers a sobering preview. When Arkansas implemented Medicaid work reporting requirements in 2018, over 18,000 people lost coverage within four months. Research published in the New England Journal of Medicine found no meaningful change in employment rates. The coverage losses were driven primarily by confusion, a lack of awareness about reporting obligations, and barriers to navigating the state’s reporting systems. People who were already working, already volunteering, already meeting the spirit of the requirement lost their coverage because the administrative process failed them.

That is the central risk in H.R. 1 implementation as well. The Congressional Budget Office projects that 4.8 million people will lose Medicaid specifically due to the work requirements over the next decade, with the majority of losses driven by administrative barriers rather than genuine ineligibility. For state leaders, that projection represents both a compliance liability and a mission-critical failure they have the technical tools to prevent.

Building the Engagement Hub: What Modern Systems Must Do

For states with existing digital eligibility portals, the most cost-effective path is transforming those platforms from passive intake tools into active engagement verification systems. Based on my experience architecting enterprise platforms across Child Welfare, Medicaid, and Eligibility modernization at scale, that transformation requires three specific capabilities.

• Mobile-first evidence capture that allows members to submit documentation of volunteer logs, training certificates, or employer records directly through a phone-based interface. For the populations Medicaid serves, mobile is not a convenience feature. It is the primary access point.
• Intelligent validation workflows that use a tiered verification hierarchy: first leveraging automated data sources like The Work Number and state wage records to clear traditionally employed members, then routing only unresolvable submissions to caseworker review. This protects staff capacity while reducing procedural disenrollment.
• Real-time compliance dashboards that give members a clear, plain-language view of their reported hours, what has been received, what is still needed, and when their next six-month redetermination window opens. Proactive visibility reduces panic, reduces call volume, and reduces the procedural churn that drives unnecessary disenrollment.

For States on Older Systems: The Modular Sidecar Approach

For states operating on legacy eligibility platforms, a full portal overhaul before January 2027 is not realistic. I have managed those timelines firsthand, and no serious systems engineering professional should promise otherwise. The defensible path forward is a modular deployment strategy.

A lightweight community engagement reporting module, deployed as a standalone digital front door and integrated with the core eligibility system via API or secure batch file, can be operational in weeks rather than years. This approach follows CMS’s own stated preference for modular Medicaid system design, satisfies the compliance mandate, and preserves the state’s long-term modernization roadmap. Cardinality’s configurable solution is built on exactly this architecture, supporting mobile and web submission, automated compliance reminders, status tracking for members and program staff, and secure integration with existing eligibility infrastructure, and it is available for procurement directly through the General Services Administration.

The Operational Imperative

The states that successfully implement H.R. 1 community engagement requirements will be the ones that treat this as an enterprise systems engineering challenge from day one, not a policy communications problem handled at the end. That means designing verification hierarchies that lead with automated data before burdening members, deploying member-facing tools that are genuinely usable on a mobile device by someone working two jobs, and structuring APD submissions to maximize the federal match before state budgets absorb costs that were never theirs to carry alone.

Having built and led these kinds of transformations at the Indiana Department of Child Services and the Indiana Family and Social Services Administration, I know that technology is not the limiting factor. Execution discipline, early planning, and the willingness to deploy proven modular solutions rather than waiting for a perfect system that arrives too late are what separate states that protect their members from states that lose them to paperwork. The deadline is fixed. The federal match is available. The solutions exist. What remains is the decision to act.