By 2027, states will be asked to operationalize new work and community engagement requirements across Medicaid and other safety-net programs, driven by changes in H.R. 1. At the same time, the broader shift toward tighter work verification expectations will pose a blunt implementation challenge: Can states verify participation week to week, at scale, without turning eligibility into an obstacle course?
Because the hardest part isn’t the policy argument about whether people should participate. It’s the operational question of whether public systems can confirm participation consistently, defensibly, and without breaking already stretched operations.
If states treat the coming requirements as a documentation problem, we’ll get the same outcome we’ve seen before: a predictable coverage cliff driven less by non-compliance than by friction. When verification depends on residents repeatedly logging in, uploading documents, chasing signatures, or navigating unclear rules, even people doing exactly what’s being asked of them fall off. Past work requirement efforts have repeatedly shown the same pattern: churn, administrative burden, and limited evidence of sustained employment gains, especially when reporting systems are clunky.
There’s another way to frame this moment. It’s less about enforcement and more about modernization.
In my conversations with state leaders across unemployment insurance, SNAP, and Medicaid, the same constraint keeps surfacing: Many of the data sources we rely on were not built for week-to-week program operations. Traditional wage databases often arrive with a lag because many employers report wages quarterly. Even newer commercial employment databases can be “near real time” in name only; depending on payroll cycles, updates can still lag by weeks. And as work becomes more variable, including gig work, contract work, and nontraditional schedules, states can end up with partial pictures that don’t match a weekly compliance standard.
You can see how this plays out inside verification workflows. Many programs rely on self-attestation in some cases, then use electronic sources to validate. When information isn’t “reasonably compatible,” the system effectively pauses eligibility and requests additional documentation. That’s a rational failsafe in a world where eligibility is determined annually and discrepancies can be resolved over time. But it becomes a churn engine when compliance is evaluated weekly and the consequences of delay are immediate.
When the policy requirement is weekly, and the best available data is delayed, incomplete, or contested, the system falls back on what it can measure today: manual proof.
So residents become compliance clerks, collecting documents, uploading forms, chasing signatures, and re-proving what the state might otherwise verify through better signals. And public servants become document processors, triaging paperwork, adjudicating edge cases, managing appeals, and absorbing the frustration when coverage gets disrupted for reasons that feel arbitrary. That isn’t modernization. It’s burden shifting.
The lesson isn’t that states shouldn’t verify. The lesson is that verification has to look like a modern system: structured, auditable signals that can move through state processes without requiring constant human review.
This is the shift states should make right now. Not, “How do we collect more documentation?” but, “How do we generate trusted, time-stamped participation signals that reduce paperwork and make continuity the default?”
And that’s where the most pragmatic opportunity sits, because one category of qualifying activity can produce clean weekly signals today: online education and training.
When someone enrolls in an approved pathway, engages weekly, makes progress, and completes milestones, that activity creates a time-stamped record. Those signals can be exported, aggregated, and audited. They can plug into reporting workflows. And crucially, they don’t require the resident to become their own case file or the caseworker to become a manual verification engine.
This won’t replace the need for employment verification. But it can solve a major part of the weekly participation problem for people meeting requirements through job search readiness, English language learning, digital skills, or industry aligned training. It can do so in a way that improves workforce outcomes instead of merely policing eligibility.
This is the part that too often gets missed. States tend to treat training as a programmatic add-on. But in a world of weekly verification, training can function as operational infrastructure.
The real value of modern learning platforms in this context isn’t only course quality, although that matters. It’s the ability to produce defensible participation records at scale, and to do it in a way that is low friction for residents and staff. Residents get an activity that counts and moves them forward. Agencies get auditable signals without building new bureaucracies. Legislators get compliance without the predictable headlines about eligible people losing coverage because a form was confusing or a database lagged.
And states have every incentive to get this right. Anyone who has spent time inside benefits administration knows that small frictions create massive downstream costs: phone queues, appeals backlogs, staff burnout, and avoidable churn. The same paperwork-first approach that feels safe on paper becomes expensive in practice, because the administrative burden shows up somewhere, whether or not it’s line itemed.
With verification expectations tightening, the safe move for states is not to wait. The safe move is to pilot now, starting where claimant volume is highest, so workflows are proven before requirements expand. That’s a more responsible posture than pretending the perfect data source is just around the corner. It’s also more honest than designing a system that “works” only when residents have unlimited time, stable internet, perfect documentation, and the ability to navigate complexity without help.
The goal shouldn’t be to get tough. It should be to get smart.
If the next era of work requirements becomes another paperwork cliff, we will have failed residents and exhausted public servants for no measurable gain. But if states invest in participation signals that are automatic, auditable, and low friction, and pair them with real skill-building pathways, 2027 could become a rare thing in government: a policy change that actually improves the citizen experience.
The choice is still ours.
Jonathan Hasak leads public-sector partnerships at Coursera, working with state and local agencies on AI upskilling and workforce transformation. He holds an MBA from UC Berkeley Haas, an Ed.M. from Harvard Graduate School of Education, and a B.A. from Bard College. His writing has appeared in The Washington Post, Forbes, Stanford Social Innovation Review, and EdSurge.
Leave a Reply
You must be logged in to post a comment.