A new tool for implementing Medicaid work requirements

Download Civilla’s user-tested application templates and resources for Medicaid work requirements.  

Monica has her paperwork ready.

She's a mother of two, managing her own medical challenges and caring for a son with autism. Because of her health condition and her son's care needs, she is self-employed and works from home. Like many other Medicaid recipients, Monica wants to comply with Medicaid’s new work requirements, but compliance can be complicated.

Monica is doing everything right, but when compliance requires extra steps and documentation, life can get in the way. Work obligations, caring for young children, and unreliable mail can cause people like Monica to lose benefits their family needs. 

That's the implementation challenge states face as they prepare for H.R. 1 Medicaid work requirements taking effect January 1, 2027. Millions of residents already meet the criteria or are exempt, but without state leaders making the right design and policy choices, residents risk losing coverage anyway.

Civilla has been working with residents across the country to develop and test application templates that can reduce this burden. Our new report makes those templates available to states, along with the policy guidance needed to put them to work. 

Download the report and the full set of templates. 

Here's what our research shows:

1. collect work requirement information in the application, not as a separate step

Every additional step in a benefits process causes applicants to lose coverage, no matter how well-designed that step is. States should collect work requirement information through the application—whether Medicaid-only or an integrated application—rather than by adding a post-application step.

By including work requirement and exemption questions in applications, residents can provide all necessary information in one go, and eligibility workers can process cases fully and accurately without having to add another follow-up step with residents. Reducing the number of forms, deadlines, and follow-ups eases the experience and will reduce churn for eligible residents. 

2. make policy choices that reduce the paperwork burden

The design of the application matters, but so do the policy decisions behind it. States have meaningful choices to make, and the right ones will significantly reduce burden on both residents and caseworkers. States should:

• Choose a 1-month lookback period for reporting work activities to reduce complexity
• Request and adopt all state-optional exemptions to protect eligible people who are facing hardships from losing coverage
• Accept self-attestation wherever federal rules allow to reduce administrative burden and procedural denials

For residents like Monica, these policy decisions will enable her to accurately tell the government about her disability and the needs of her family without having to jump through hoops that put her coverage at risk.

3. use applications to gather data, not teach policy

Residents filling out an application are focused on one thing: answering the questions correctly so they can get covered. They are not looking to learn new policy frameworks or assess their own eligibility against regulatory requirements.

States should focus their application instructions and design on collecting the information needed to make a determination. Applications do not need to explain how each piece of information connects to a policy or exemption. Education about the new rules and exemptions belongs in outreach materials: notices, texts, and portal messages sent before and after application. This will help people fully understand the new requirements without adding length, confusion, and errors to the application itself.

resources and guidance for state leaders

Monica shouldn't have to carry a packet of medical documentation just to prove she's eligible for coverage she qualifies for. How states design these requirements, and the policies they adopt, will decide which residents keep coverage and which lose it to paperwork.

User-centered application templates and policy choices will meaningfully improve the experience for residents like Monica while reducing the workload for eligibility workers at the same time.

Civilla's new report gives leaders the tools to do both. Download it to access:

• A paper application template for collecting exemptions and work activities
• An online application template for state Medicaid or integrated applications
• A policy and question guide mapping each template question to the applicable policy group
• Implementation guidance in the report that works whether you adopt the full templates or just the plain language questions

Download the report and the full set of templates. 

If you have questions about this report, need implementation support, or want to talk through your state's approach to H.R. 1, we'd love to hear from you. Reach the team at hello@civilla.org.