Understanding CMS’s “Emmy” Medicaid Work Requirement Tools

As states work to implement the federal Medicaid work requirement on a rapid timeframe, they are facing a number of challenges including cost pressures, a lack of guidance from the Centers for Medicare and Medicaid Services (CMS) on key decision points, and the need to make multiple changes to their eligibility systems. Although implementing the work requirement will inevitably lead to coverage loss, resources CMS is developing may help states with elements of work requirement implementation, including verifying income, enrollment in education, and status as a veteran with a full disability rating.

CMS recently announced it is developing a suite of resources to support states in implementing the Medicaid work requirement (which takes effect in most states in January 2027), including technical products that can help states streamline the income-verification process. CMS is offering states two products — the open source, consent-based verification (CBV) tool Emmy and the Emmy API (Application Programming Interface, or data connection) — as well as technical assistance on integration, procurement, and operational planning. Emmy is CMS’s shorthand for “Eligibility Made Easy.”

Emmy (the CBV tool) can help states improve income verification by using consent-based verification, a newer form of income verification that relies on users logging into their personal payroll, bank, or other accounts and consenting to share their income information with the Medicaid agency. Emmy is one of many CBV tools (such as SteadyIQ and Truv) available to states to verify income for traditional eligibility determinations and to confirm work requirement compliance. For an overview of work requirement implementation considerations and vendor products, see our paper, “Assessing the Medicaid Work Requirement Vendor Landscape.”

CBV can only verify income for people who actively provide consent, and not everyone impacted by the work requirement will do so. However, CBV provides a lower-cost alternative for traditional W-2 workers to verify their income in order to show they meet the work requirement. Additionally, it enables income verification for types of workers whose income is not available in traditional sources like quarterly wage data or commercial databases, like The Work Number. This includes 1099 or gig workers, like Uber and Lyft drivers, and self-employed workers. While CBV is a useful tool, it only addresses a part of work requirement implementation. States will need to consider how CBV fits into the larger system changes needed.

Key features of Emmy (the CBV tool) include:

• Open Source Codebase: Emmy’s underlying code is public. This allows states and vendors to review, adapt, and integrate the tool more easily and transparently.
• Verification for Varied Worker Types: Emmy supports income verification for traditional payroll workers as well as gig workers. Unlike some private‑sector CBV tools, Emmy does not access banking data.
• Applicant Review and Context: Applicants can review their generated income report before it is submitted to the state, and they can add comments or context — an important safeguard for workers with inconsistent earnings or multiple income sources.
• Flexible Integration Options: Emmy can be fully integrated into a state’s online application process, accessed through a standalone link sent by text or email, or incorporated through a paper‑notice workflow.
• Public Benefits‑Centered Design: Emmy is built specifically for public benefits agencies and Medicaid populations, with insights from policy experts at CMS.

Although Emmy is still in its pilot phase, CMS plans to expand the tool over time to include verification of additional work requirement activities, including volunteer hours.

In addition to offering Emmy for CBV, CMS is also developing Emmy API — a separate standalone resource that allows states to access a set of data sources through a single endpoint. Emmy API functions similarly to, but is distinct from, the Federal Data Services Hub (an electronic data conduit that supports federal and state programs that need to verify eligibility data).

Emmy API will provide a single point of access for data sources relevant to the new Medicaid work requirement, such as the National Student Clearinghouse for education enrollment data and Veteran Affairs API, which provides data on veteran disability rating. APIs like this are particularly valuable because they streamline access to several data sources, reducing agency workload and accelerating launch times for state developers. They also allow for more effective automation of data verification which, when applied with effective policy, can reduce administrative burden for applicants and keep eligible people enrolled. Emmy API also offers a document uploader that can help states process incoming verification documents.

Emmy API is system-agnostic, meaning it can be integrated into any vendor platform or directly into a state’s eligibility system through standard API calls, whether or not the state uses Emmy (the CBV tool). Unlike Emmy, states can access the data sources in the Emmy API without direct interaction from Medicaid applicants or enrollees.