Monitoring the implementation of work reporting requirements in Medicaid will be incredibly important to assessing the policy’s impact, identifying bottlenecks or glitches in the system, and enabling rapid response to address problems. We have a baseline of data from the Medicaid performance indicators, which have been in place since 2014, and were expanded to more closely monitor the renewal process during unwinding of the COVID-era Medicaid continuous enrollment provision. CMS continues to collect and report these data on a monthly basis, which are useful in tracking the status of state operations, as we post in our H.R. 1 Readiness Tracker. But the data currently published are not sufficiently granular to reflect the specific impact of H.R. 1 policy changes on Medicaid expansion adults (also known as Group VIII). And just like during the unwinding, we know that millions of eligible people are at risk of losing coverage due to administrative burden.
CMS officials have spoken in public forums about the need for data to monitor implementation of work reporting requirements, yet CMS has not announced any new data reporting requirements and whether the data will be posted publicly. Of note, CMS doesn’t need a new law to require states to report data; it already has that authority. Federal funding reimburses states 90% of eligibility system development and deployment, and 75% for ongoing operations – including covering the cost of workers who operate the systems. To receive enhanced funding, systems must produce “transaction data, reports, and performance information that would contribute to program evaluation, continuous improvement in business operations, and transparency and accountability” (42 CFR 433.112(b)(15)).
It is critical that data be disaggregated for Group VIII and to identify the underlying reasons for denial and disenrollment to address issues and concerns. As we all learned from the unwinding – a catch-all procedural disenrollment rate doesn’t provide the detail needed to identify where problems exist, take corrective action, and avoid inappropriate denials or disenrollments of eligible people.
To fully understand and take steps to prevent adverse actions when eligible people are denied at application or disenrolled at renewal for not meeting work reporting requirements, we need to go deeper. By standardizing and tracking a set of disaggregated denial and disenrollment reasons, we can better understand the policies and procedures that prevent adults eligible for Medicaid expansion coverage from successfully maneuvering the reporting process. By comparing data across states, we can identify those with better outcomes, learn from them, and identify when too many eligible people are losing coverage or states are overwhelmed by the need for assistance and backlogs of work.
Prior CMS administrations have collaborated with stakeholders on data and monitoring, but so far there have only been casual mentions of establishing metrics. Does CMS plan to hold states accountable for collecting and reporting the data needed to monitor implementation and enable rapid response to issues that will inevitably arise from the rushed timeline, complexity of the law, and administrative burden imposed on states and individuals? And will the data be publicly available with a minimum lag in reporting?
Even if CMS chooses not to require reporting or decides against making the data publicly available, states can collect and report data themselves. In its January 2026 meeting, MACPAC presented findings from interviews with stakeholders about what existing data and new metrics are needed to monitor implementation and impact; and I’m sharing my thoughts in the list below. Let’s put our heads together and promote a list of performance metrics that will help policymakers and stakeholders mitigate harm as states implement the onerous H.R. 1 policy changes.