Beginning January 1, 2027, states must condition Medicaid eligibility for the adult expansion group on 80 hours of qualifying activity per month. The pathways are familiar by now: paid work, community service, participation in a work program, half-time enrollment in an educational program, or any combination. An income equivalent also qualifies, and is verified against payroll data the same way paid work does.
On paper those pathways look alike; however, inside an eligibility system they are not alike at all. Three of them can be checked against data a state already holds, while one cannot, and that asymmetry is where most of the operational risk in this requirement now remains.
The interim final rule directs states to attempt ex parte verification first, using information already available to the agency before asking an applicant to produce any documentation themselves.1 For most of the pathways, that instruction is achievable on day one.
Paid work can be checked against payroll data, state and local agency records, and federal information available through the electronic service the Secretary of Health and Human Services maintains. Educational enrollment can be checked against institutional records, with the rule’s preamble pointing states to the National Student Clearinghouse. Participation in a work program can be checked against the administering agency’s own records, since the state or one of its partners is usually the administrator.
None of that infrastructure was built for H.R. 1. It already existed, since income and enrollment verification have long been part of Medicaid and SNAP eligibility. The community engagement requirement gave states a new reason to query systems they were already relying on.
The rule defines community service as unpaid work, completed voluntarily or under court order, with a structured program that is completed for the direct benefit of the community under the auspices of a public or nonprofit organization.1 Read as an operations problem rather than a policy one, it does two things.
First, it leaves the state with no historically standard data source to query; no national system records who volunteered where, for how long, under whose supervision. Where paid work has payroll data behind it, community service has historically appeared to be decentralized, so the state has to ask the individual for documentation and then evaluate whatever arrives. The rule does offer one protection: an agency may not deny or terminate eligibility solely because a person cannot produce documentation that does not exist or is not reasonably available. It does not create a general right to attest to volunteer hours.
Second, the rule sets out what the host organization must have in place. The organization has to provide oversight of the activity, which must not serve a partisan purpose, and “have a process in place to track the community service completed by individuals, including the type of community service activity, dates and hours the community service is completed, and a point of contact who can confirm the hours completed.”1
That is a systems requirement written into a Medicaid regulation. Every qualifying host organization, in every county, needs a way to record activity type, dates and hours, and a named person who can confirm them. An organization that cannot do that cannot host qualifying services.
This creates a second challenge: making sure qualifying opportunities exist. Someone has to host the work, make it easy for beneficiaries to find and join, and be able to document it to a federal standard. For paid employment, employers create both the opportunity and the payroll record as a matter of course. For community service, that does not happen on its own, and no state agency has previously been responsible for ensuring that a qualifying, properly documented opportunity exists within reach of every adult enrollee in every county, rural ones included. That is a new operational function, rather than an extension of an existing one. Closing the community service loop means both making opportunities available and making sure they are properly tracked, because a state that addresses only one of these has not solved the problem.
This is not only a state observation. The Center on Budget and Policy Priorities reviewed the vendor products being offered for work requirement implementations, based on demonstrations and conversations with the vendors. Of the products it describes, one has a dedicated volunteer verification tool, and it works by uploading documentation of community service hours, which then introduces a dependency for case workers to manually verify those claims. Several others accept volunteer hours through general activity-reporting portals, but none is described as operating an inventory of volunteer opportunities. The review also finds that most vendors “have not yet shared specific designs for helping with ex parte renewals,” which is the mechanism the rule leans on hardest.2
Set those findings beside the rule’s ex parte-first obligation and a conclusion can be drawn: community service is the least solved of the four pathways. A state can receive a claim of 80 volunteer hours. However, in most environments it cannot originate the opportunity, confirm the hours occurred, or clear the renewal without a fresh action from the beneficiary.
Work requirements are not new. The section 1115 demonstration era tested them, and the main shortcoming that era exposed was not fraud but reporting friction. States that lived through it, and the vendors serving them, drew the correct lesson and invested in the intake and adjudication layer: portals, document handling, income verification feeds, caseworker queues, notice generation. That work was necessary and it is largely done.
However, the remaining risk did not disappear; it shifted to the one pathway with no data behind it.
Arkansas remains the clearest precedent, and it is worth being precise about what happened there.
In 2018, the first year of implementation, 18,164 people lost coverage, roughly one in four of those subject to the requirement. By early 2019, only 11 percent had reapplied and regained it.3
The cause was not unemployment. Among non-exempt enrollees who did not report 80 hours in a given month, nearly 99 percent reported zero activities, which points to confusion or deterrence rather than idleness. National estimates put the share of Medicaid adults potentially subject to such a requirement who either were already working or would qualify for an exemption at nine in ten in 2021, and at 92 percent in 2023.3 4
This suggests that the reporting mechanism itself was the barrier. Account setup was required before hours could be reported at all, and one participant needed more than ten hours simply to establish an account. The portal was also routinely unavailable during parts of the day. Arkansas ranked near the bottom nationally for broadband access when the requirement took effect.3 5
Two pieces of context matter before drawing lessons from this. The first is that the requirement applied to ages 30 to 49 at launch, extending to 19 to 29 in January 2019, so H.R. 1 reaches a substantially larger population. Second, the implementation of this requirement did not run its course. A federal court vacated the approval in March 2019 as arbitrary and capricious, the D.C. Circuit affirmed unanimously the following year, and a second round of disenrollments scheduled for that April never occurred.
The lesson for 2027 is a specific one: when compliance depends on a person successfully reporting their hours, the reporting process itself effectively becomes an eligibility requirement.
A standalone reporting portal falls short in four ways:
Each gap adds administrative cost, creates due process risk, and increases the chance that eligible people lose coverage.
Regardless of which vendor a state works with, the core components are well understood.
A state with all five can verify community service the way it verifies wages. A state missing any of them will likely have to rely on self-attestation, which is difficult to defend on appeal or audit.
At this point in the calendar year, the harder question is not which components are required, but how they get added to an environment that is already built, already contracted, and already budgeted.
Golden serves more than 50,000 organizations, among them nonprofits, government agencies, healthcare systems, schools, food banks and more, and has over a decade of proven experience serving as volunteering infrastructure for local, remote, and mission-critical community-based organizations (CBOs). The platform is mobile first, is SOC 2 certified and HIPAA compliant, and offers branded portals and mobile apps, so the program remains branded and integrated as the state’s digital property, rather than perceived as a third party by beneficiaries, while also allowing eligible organizations to begin adopting the technology for their own internal use for free and in seconds.
It is designed to extend an existing environment rather than replace one. Verified hours automatically flow back into the eligibility and enrollment systems a state already runs, through API access and native connectors. Host organizations adopt it directly and run their own programs on it, which is how they get the tracking capability the rule now requires of them without having to manually enter data into each system or require caseworkers to manually verify the volunteer work. That matters because the number of available opportunities grows through relationships with community organizations rather than through a separate contract with each one.
None of this removes a state’s obligation to conduct its own legal, privacy and IT review. It does mean the community service pathway can be treated as a solved problem rather than an open one. States can also be up and running well ahead of the January 1, 2027 deadline, with the potential to reduce Medicaid, SNAP and TANF error rates and the caseworker time spent on manual verification.
The community engagement requirement was issued as an interim final rule. The comment period closed on July 31, 2026, and CMS has said it expects to issue further guidance, including on the use of reliable data sources and on the role of managed care plans.1 6 States should plan for the standard to become more specific rather than less.
A state that closes the community service loop now is not only meeting its January 1 obligation; Rather than adjusting to meet standards once enrollees are already in the program, a state with a closed community service loop is building to the standard that the next round of guidance is likely to set.
If your state is working through this within an existing eligibility and enrollment environment, we would be glad to spend 30 minutes with your team. This is not a product demo, but a working conversation about your current systems and where verified community service hours would enter them.
Anish Das,
Chief of Staff
anish@goldenvolunteer.com
1. Medicaid Program; Community Engagement Requirement for Certain Individuals. Centers for Medicare & Medicaid Services, Federal Register, June 3, 2026. Accessed September 1, 2026. https://www.federalregister.gov/documents/2026/06/03/2026-11094/medicaid-program-community-engagement-requirement-for-certain-individuals.
2. Assessing the Medicaid Work Requirement Vendor Landscape. Center on Budget and Policy Priorities, 2026. Accessed September 1, 2026. https://www.cbpp.org/research/health/assessing-the-medicaid-work-requirement-vendor-landscape.
3. Pain But No Gain: Arkansas’ Failed Medicaid Work-Reporting Requirements Should Not Be a Model. Center on Budget and Policy Priorities. Accessed September 1, 2026. https://www.cbpp.org/research/health/pain-but-no-gain-arkansas-failed-medicaid-work-reporting-requirements-should-not-be.
4. February State Data for Medicaid Work Requirements in Arkansas. KFF. March 25, 2019. Accessed September 11, 2026. https://www.kff.org/medicaid/state-data-for-medicaid-work-requirements-in-arkansas/.
5. Lessons from Launching Medicaid Work Requirements in Arkansas. Urban Institute. Accessed September 1, 2026. https://www.urban.org/research/publication/lessons-launching-medicaid-work-requirements-arkansas.
6. Preparing for Medicaid Community Engagement Requirements: Key Steps and Opportunities for States and Plans. Health Management Associates, 2026. Accessed September 1, 2026. https://www.healthmanagement.com/blog/preparing-for-medicaid-community-engagement-requirements-key-steps-and-opportunities-for-states-and-plans/.
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With January 1, 2027 this close, a new procurement won’t land in time. The community service pathway can be added to a state’s existing eligibility and enrollment system as a layer, not a replacement. Here’s what that layer has to do, how it integrates, and how its cost may qualify for a 90 percent federal match.
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