With the passage of the 2025 budget reconciliation bill (H.R. 1), state Medicaid agencies must implement new work requirements for certain Medicaid members ages 19-64 by December 31, 2026. While the U.S. Department of Health and Human Services is expected to release work requirement guidance to states by June 1, 2026, many states are already beginning to design their approaches given the significant administrative investments required. As states prepare for implementation, they face the challenge of translating federal requirements into policies that are understandable and navigable for members. Engaging Medicaid members and community-based organizations (CBOs) early in the process can help states identify potential barriers, reduce administrative complexity, and support more effective communication and implementation. This brief outlines strategies states can use to partner with Medicaid members and CBOs in implementing work requirement policies that reflect community input.

What’s the issue?

Work requirement policies can be confusing and challenging for Medicaid members to navigate — especially when they are not implemented with clear communication and an understanding of member experiences. Past efforts, such as in Arkansas, have shown that even Medicaid members who meet the required work/volunteer hours may lose coverage due to administrative hurdles and complex reporting requirements. Without strong community partnerships to help shape policy implementation and outreach strategies with member needs and preferences in mind, states risk creating unintentional barriers that complicate compliance and jeopardize coverage. To reduce the risk of eligible members inappropriately losing coverage, states can work to develop reporting systems that are as streamlined and user-friendly as possible.

What can be done?

States can go beyond simply informing enrollees of work requirement policies and instead seek input from Medicaid members and CBOs to inform the development and implementation of work requirements, operational plans, and outreach efforts. The new federally required Beneficiary Advisory Councils (BACs) within state Medicaid agencies can serve as a vehicle for informing and testing various aspects of work requirements (such as verification requirements, notice provisions, and grievance and appeals) to ensure that the policies and processes can be implemented effectively.

Medicaid members’ experiences and perspectives will be most useful in the planning and implementation phases. For example, state Medicaid agencies can work with Medicaid members to better understand how to most effectively structure and use online portals for submitting required documentation, gather input on documentation requirements, and identify the most effective channels and messaging strategies for communicating information about work requirements. States can also involve members in user testing digital tools — such as online forms — to help ensure systems are intuitive, user-friendly, and error-free.

What are the lessons from past Medicaid experiences?

Past efforts in states like Arkansas and Georgia show that work requirement policies can be confusing, inefficient, ineffective, and costly. Since launching its work requirements pilot in July 2023, Georgia has spent approximately $100 million of primarily federal funds implementing its program, Georgia Pathways to Coverage. More than half of those funds ($55 million) have been used to develop a digital platform to verify Medicaid members’ work hours and eligibility, illustrating the potentially high cost of these systems. At the same time, the system experienced technical difficulties, and many eligible Medicaid members were unable to confirm their employment, especially those who may not have had traditional pay stubs. Medicaid agencies and their technology vendors can solicit input from Medicaid members to inform the design of the reporting platform and processes for providing information to the state.

In Arkansas, communication issues reportedly impacted the outcome of the state’s 2018 work requirement policy. The Arkansas Center for Health Improvement found that only 10 to 15 percent of the first-class mail sent to Medicaid members to inform them of the policy reached the intended individuals. Communications were written at an eighth-grade reading level when a fourth-grade level was later found to be more appropriate. Medicaid agencies can ask members to identify and test the best ways to communicate with and reach their communities.

Additionally, Medicaid agencies can look to recent lessons learned from “unwinding,” the process through which states resumed their eligibility determinations after the COVID-19 pandemic, when determining how to best communicate with Medicaid members. For example, the Maine Department of Health and Human Services called households that did not return renewal paperwork as expected. In Louisiana, the Department of Health used text messages to remind Medicaid members of upcoming renewal process deadlines. These processes used during unwinding could be considered for work requirement-related communications.

How can Medicaid leverage BACs to inform work requirement policies?

Medicaid agencies can engage BAC members to help design and implement work requirement policies more accurately and efficiently. Agency staff can include work requirements as a standing topic on BAC meeting agendas to: first, gather meaningful input on work requirement-related policy communication details (e.g., communicating with Medicaid members, reporting challenges); and second, gather feedback on the practicality and usability of proposed implementation approaches (e.g., required documentation, reporting platforms, verification methods).

When planning for engagement of BAC members around work requirements, states can consider strategies across three facets: communications, implementation, and evaluation. The following are examples of questions to explore with BAC members in each of these areas:

Communicating with members on work requirement policies.

• What are the best ways to inform people about whom the work requirement policies will and will not apply to? What organizations are trusted sources to deliver this type of information?
• How would you like the Medicaid agency to communicate with you to share relevant information about this policy? (e.g., email, call center, text, live chat function)
• How would you like to communicate challenges or issues to the Medicaid agency? Would the current feedback channels work, or should there be other options?

Implementing work requirement policies.

• What documents would be easy to provide to demonstrate you have been working, volunteering, attending school, or are exempt from the work requirements? (e.g., pay stubs, tax forms, timecards, school transcripts)
• What are the easiest ways to submit documentation of your work, education, volunteer activities, or exempt status? (e.g., an online portal, email, phone, with the help of navigators)
• Do you have concerns about how to verify and report on your work, education, or volunteer activities?
• What would be the best way to remind you to report on your work or volunteer activities each month?
• What are the most common barriers that keep Medicaid members from working? (e.g., access to consistent transportation, language barriers, flexible scheduling)
• What resources or support would you need to help you to find a job, education, or volunteer opportunity? (e.g., information about job fairs, resume writing support, interview preparation, and coaching)

Evaluating work requirement policies and implementation.

• Are there parts of the work requirement policies that have been hard to meet? Why is that?
• What has your experience — or the experience of other Medicaid members you know — been like when submitting required documents to maintain Medicaid coverage?
• Did information about the work requirement policies reach you — and other Medicaid members you know — in ways that worked best for you? (e.g., email, text, phone calls, regular mail)
• If you had questions, were you able to get timely answers?

What roles can CBOs play?

CBOs can play a variety of important roles in helping Medicaid agencies clearly communicate work requirement policies to members and helping members acquire the support they need to enter or reenter the workforce. By leveraging the unique expertise and relationships of CBOs, Medicaid agencies can better address specific member needs and strengthen outreach and engagement efforts. For example:

• Educating: CBOs with experience in policy work — such as AARP chapters or caregiver advocacy groups — would be well-positioned to translate the details of work requirement policies into plain language that will resonate with Medicaid members. Partnering with these organizations can help Medicaid members understand the requirements, timelines for documenting work activities, who may be exempt, and other key details.
• Engaging: CBOs with deep community ties — such as faith-based groups or disease-specific advocacy organizations — that regularly engage with Medicaid members at community events can help identify the most effective ways to reach members.
• Providing feedback: CBOs will be an important resource for Medicaid agencies to understand what Medicaid members need throughout the work requirements design and implementation process. Medicaid agencies can regularly check in with CBOs to receive any feedback the CBOs are hearing in the community about work requirements.
• Troubleshooting: CBOs will be able to support Medicaid members who may be struggling to understand or comply with work requirements. For example, community-based legal organizations can be helpful in explaining requirements and troubleshooting challenges.