Accessing SNAP Data Can Reduce Coverage Losses and Administrative Burdens From Medicaid Work Requirement

While the Medicaid work requirement in the 2025 reconciliation law is going to take away and block eligible people from health coverage, states are required by federal law and regulations to adopt a critical strategy for reducing coverage losses: establishing cross-program data-sharing to help determine whether individuals must comply with the work requirement or are exempt. Data-sharing between Medicaid and the Supplemental Nutrition Assistance Program (SNAP) can be especially effective.

The federal rule detailing how states should implement the work requirement directs them to access data from other programs, including SNAP, when determining compliance and exemptions. Federal Medicaid law requires data sharing, and the rule explicitly requires state agencies to coordinate with each other to ensure eligibility systems can share data, which is essential for reducing administrative burden.

Using data to verify eligibility improves accuracy, reduces the need for clients to compile and submit paper documentation, and lessens the paperwork states must process. Effective data sharing between programs will help streamline verification processes and ensure that eligible people can keep their health coverage without interruption.

Individuals are excluded from meeting the Medicaid work requirement if they’re a member of a household that receives SNAP and aren’t exempt from the SNAP work requirement. (They’re also excluded if they satisfy the work requirement in the Temporary Assistance for Needy Families program, or TANF.) To make this determination, the rule requires states to maximize reliance on electronic data sources before requesting information from an individual, including using information from their SNAP agency.

States that have already integrated their SNAP and Medicaid programs into the same eligibility and enrollment systems are well positioned to share these data between programs. But the rule’s requirement means states that have not integrated these programs must establish connections to SNAP systems or implement manual procedures that allow them to use the information from those systems to determine if people comply with the Medicaid work requirement. Ideally, Medicaid agencies in those states will share relevant information back to SNAP and other programs to streamline eligibility determinations for those programs as well.

As states work to share data between programs, they should:

1. Identify linkage points. State agencies should identify areas of overlap between SNAP and Medicaid involving work requirement compliance and exemptions. For example, a pregnant adult who reports their pregnancy to SNAP and thus is exempt from the SNAP work requirement should also be exempted from the Medicaid work requirement, since the two programs’ pregnancy exemption criteria are the same.
2. Leverage SNAP Employment & Training (E&T) programs. Forty percent of Medicaid-covered adults also receive SNAP benefits. State SNAP agencies have SNAP E&T programs, for which the state receives a 50 percent federal funding match. These activities help individuals meet the SNAP work requirement, and those who meet the SNAP work requirement are automatically excluded from the Medicaid work requirement. Although federal Medicaid dollars can’t be spent on activities that help individuals meet the Medicaid work requirement, identifying opportunities to leverage federal SNAP funds to connect individuals enrolled in both programs with SNAP E&T activities can help people meet the work requirements and retain access to benefits in both programs.
3. Comprehensive staff training across programs. In many states, eligibility workers determine households’ eligibility for multiple programs. In these cases, it’s essential that caseworkers be trained to determine accurately when the compliance activities or exemption for a member of a household that receives multiple benefits meets the requirements of each program, and coordinate across the programs.

Designing Medicaid systems capable of sharing and receiving data for determinations may require states to upgrade their eligibility and enrollment systems. But states can claim federal funding that will cover 90 percent of design, development, and implementation costs and 75 percent of the costs for ongoing maintenance and operations.