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19 September 2025

Medicaid Work Reporting Requirements: Verifying Compliance And Exemptions Toolkit

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Manatt, Phelps & Phillips LLP

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Support for this toolkit was provided by the State Health and Value Strategies program, a grantee of the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the Foundation.
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Support for this toolkit was provided by the State Health and Value Strategies program, a grantee of the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the Foundation.

H.R.1's mandatory work reporting requirements expressly direct states to use an ex parte process, relying on reliable information to verify compliance and mandatory exemptions, and avoiding requests for additional information from individuals whenever possible. To meet the aggressive timeline required by federal law to implement mandatory work reporting requirements, states will need to quickly assess which data sources are currently available and which data sources require new state builds and/or data matching processes.

In this toolkit, prepared for the Robert Wood Johnson Foundation's State Health and Value Strategies program, Manatt Health Partner Kinda Serafi, Partner and Senior Advisor Lisa Sbrana and Counsel Elizabeth Dervan lay out the federal statutory definitions for qualifying activities and mandatory exemptions, describe whether the criteria can be verified via an ex parte review using data sources that are currently available or would require new state builds, and whether a state needs to add a new question to its single streamlined application.

To view the full toolkit, click here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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