Three Principles for Implementing Work Requirements in a Human-Centered Way

The passage of H.R. 1—the so-called One Big Beautiful Bill Act—will cause big changes in the safety net space. One of the largest changes states and clients will experience in the next year will be the expansion of work reporting requirements in the Supplemental Nutrition Assistance Program (SNAP), and the addition of new work reporting requirements in Medicaid. These new eligibility rules will require many people to demonstrate they’re working in order to receive benefits, which means an additional reporting burden for clients and more paperwork to review for caseworkers. 

Without strategic, client-centered planning, states run the risk of adding crushing administrative burden on caseworkers and endless backlogs of paperwork. Clients are at risk of getting lost in the details and potentially losing critical benefits in times of crisis.

While guidance and regulations are still being released, agencies can adopt strategies now to place themselves on a trajectory that minimizes these impacts. Code for America has worked with government partners during periods of severe policy and operational upheaval, and has been collaborating with states and external partners to map out how work requirements in SNAP and Medicaid will impact staff and caseworker experiences across the benefits journey. 

We’ve put together three principles that can help states implement these new rules in more human-centered ways.

1. Use the right data in the right way to reduce burden

Work reporting policy is notoriously confusing for clients, and many will need to comply with inconsistent rules for multiple programs. But state agencies can automate data collection from available sources to find exemptions or compliance without requiring clients to understand complicated rules or submit documents. For example, data exchanges between SNAP, Temporary Assistance for Needy Families (TANF), and Medicaid can instantly exempt all clients who are meeting SNAP or TANF work requirements from having to meet Medicaid work requirements. Data could get auto-populated in eligibility systems, with exemption reasons clearly marked and applied to the case in order of which reason is the most durable. 

Leaning on data sources to streamline eligibility is not a new strategy. The ex parte process, through which states use existing data to automate eligibility determinations, has been a requirement in Medicaid for over a decade. H.R. 1 requires states to attempt data matches to see if clients are meeting Medicaid’s reporting requirements before contacting them. However, the wide range in ex parte rates among states shows that how states implement data matching matters. Vendors will offer many data sources (and data products) to states navigating these changes. States should evaluate all options critically—and with evidence rooted in data—in order to protect their investments and make the most of the opportunity.

States should start planning data sharing agreements now

While guidance and regulations have not yet been fully released for the new work requirements, states can start to establish data sharing agreements for those exemption and compliance categories detailed in the law.  This running list of data sources can be used to demonstrate exemption or compliance for SNAP and Medicaid work requirement reporting.

2. Use the moment for improvement, not just compliance

The major systems changes required to implement H.R. 1 mean that states must change their eligibility and enrollment systems and a variety of client-facing forms, notices, and communications. Systems are typically difficult to change, so this usually only happens when absolutely necessary. The present moment is an opportunity to go beyond mere compliance and instead pursue overall improvement. For SNAP, states have an additional incentive to make systems changes as soon as possible, because states’ share of the program’s administrative costs will increase by 50% in October 2026. 

Innovation can be simple: make your notices easy to read and take action on, and communicate consistently across your website, social media, and text messages. Clear communications build trust in government and results in clients being more likely to self-serve, act in a timely manner, and fulfill what is asked. Prioritize the following forms and notices for human-centered work reporting:

• Medicaid’s “Notice of Noncompliance”
• SNAP notices that explain that a client has used a countable month
• Exemption, compliance, or good cause/hardship reporting form
• Renewal forms
• Application forms

Resource: Medicaid Work Requirements Explainer

Medicaid work requirements will be completely new to states, and will require implementing the existing statute on a quick timeline. Our Medicaid Work Requirements Implementation resource breaks down the new rules from an implementation perspective and introduces a starting point for planning system changes. Even though regulations and guidance have not filled in all the missing pieces, states can begin planning and building now to ensure systems are ready.

3. Build a coalition across agencies, community-based organizations, and implementors

Now is the time for state agencies to harness their networks of partners—both internal and external—who are aligned and ready to work on the changes mandated in H.R. 1. Even though work reporting policy differs between SNAP, Medicaid, and TANF, states can reduce burden on clients and staff by coordinating across programs to make the most out of their resources. This moment provides an opportunity to embrace collaboration across the ecosystem. Community-based organizations that play an essential role in supporting clients and beneficiaries can provide feedback on initial designs and processes. Civic tech organizations are ready to assist with all aspects of H.R. 1 implementation, from doing discovery work on the highest leverage points of intervention to assisting on service delivery improvements and technical integrations. Finally, agencies in all states are facing similar challenges, and sharing lessons learned and work in progress across state lines can yield significant benefits.

How government meets this moment matters

States are under tremendous pressure from the scale and timeline of the new changes introduced by H.R. 1, and these big changes are coming at a moment when state budgets are constrained. The choices states make now can result in vastly different outcomes for clients and agencies in the coming years. Approaching these changes in thoughtful and human-centered ways can make all the difference.

Code for America stands ready to help states meet this moment and work through these policy changes in a human-centered way. We know that together, we can navigate this complex time and create systems that effectively serve all.

Do you represent a state agency or community organization working on implementing work requirements under H.R. 1? We want to know how we can help. Get in touch.