The One Big Beautiful Bill Act, signed into law in July 2025, has generated plenty of debate about who gains or loses benefits. For state agencies, preparation of new processes to streamline eligibility determinations based on the new requirements is becoming increasingly important.
Here's what's changing, what it means operationally, and how Truv's client-permissioned verification platform has been built and refined to help agencies stay ahead.
HR1 Requirements at a Glance
Starting January 1, 2027, most adult Medicaid beneficiaries must complete at least 80 hours per month of qualifying community engagement — work, volunteering, education, or job training — to maintain coverage. States must also conduct semi-annual eligibility redeterminations for Medicaid, nearly doubling the redetermination workload.
For SNAP, work requirements now extend to able-bodied adults ages 18–65, including parents of children 14 and older.
On paper, these are eligibility policy changes. In practice, they are more labor intensive verifications at historic scale. At the same time, states are taking on a larger share of program costs with greater accountability. SNAP administrative costs are shifting from 50% to 75% state-funded, and benefit costs will be tied directly to payment error rates.
A Shift in the Workforce Demands a Shift in Verifications
Here's one of the challenges that the public sector is facing with verifications: the workforce that state agencies are being asked to verify is more dynamic and intricate compared to the workforce that existing verification systems were built to support.
Today, many applications increasingly include multiple part-time roles, supplemental income with gig or contract work, or frequent moves between employers. A single individual might work 20 hours a week at a retail job, pick up DoorDash deliveries on weekends, and take an online certification course — all of which could count toward the 80-hour monthly requirement, and all of which require different documentation and verification paths.
Manual processes — paper pay stubs, employer verification forms, documents uploaded and reviewed case by case — inherently result in longer timelines, whether it's an initial application or routine redetermination cycle. The verification systems in place have not evolved with the shift in how people work.
This is where the concept of procedural disenrollment is relevant: It refers to situations where eligible individuals lose coverage not because they don't qualify, but because the documentation process broke down somewhere along the way. While it's a known challenge in public benefits administration, it becomes more manageable when state agencies have the right verification infrastructure and systems in place to guide clients through the process smoothly.
The Hidden Coordination Problem
The relationship between SNAP and Medicaid verification is about to become critically important.
Under HR1, individuals who meet SNAP work requirements are exempt from Medicaid community engagement requirements. SNAP and Medicaid systems have historically operated in silos, with separate workflows, and often separate data systems. If those silos persist, states risk verifying the same individual twice, or risk failing to recognize an exemption that should have applied, potentially triggering churn.
The coordination gap isn't just an efficiency problem. It's a compliance risk and a cost risk simultaneously. And solving it requires something most states don't currently have: a shared, real-time view of verification data.
"What's underappreciated about HR1 is that it doesn't just increase verification volume — it changes the nature of what verification has to be," says Tommy Jayne, Vice President of Government Solutions at Truv. "You need a single source of truth that caseworkers can rely on. Without that, you're doing double the work with half the accuracy."
The Scale Problem Is Bigger Than It Looks
When you run the numbers, the operational reality is clear: There's tens of millions of Medicaid and SNAP beneficiaries. Plus semi-annual eligibility redeterminations. And now, community engagement verification spans different activity types, each requiring different documentation.
State agencies that rely on manual, outdated processes to absorb the increasing volume will likely feel the strain with longer processing times, increased pressure on caseworkers, and a higher likelihood of errors. That matters beyond the operational level, too. With benefit costs now tied to payment error rates, verification accuracy has a direct cost component, making the case for process modernization easier to build internally.
What Modern Verification Actually Looks Like
The state agencies best positioned to navigate HR1 are rethinking their verification stack — connecting to payroll systems, employer databases, and financial institutions directly, rather than waiting for clients to submit documentation for manual review or relying first on expensive, legacy solutions.
This shift will result in a range of benefits in the eligibility determination process, including improving the client experience with less friction, which is particularly important for populations that may face barriers to comprehensive document retrieval — people experiencing housing instability, those without reliable internet access, or those juggling multiple jobs with little administrative bandwidth. It also eliminates a significant category of error: documents that are outdated, misread, or tampered with.
Additionally, when verification data flows through a unified system rather than program-specific silos, caseworkers can see the full picture — across SNAP and Medicaid simultaneously — and ensure exemptions are met in real time, improving cross-program coordination automatically.
Where Truv Fits In
Truv's client-permissioned verification platform was built and refined to solve verification gaps for the public sector. By enabling connections directly to nearly 100 payroll providers and more than 2.3 million employers, gig platforms, benefits income, and self-employment income sources, Truv enables real-time verification of traditional wage earners, gig work, and part-time roles without requiring a single pay stub from clients. For self-employed individuals and seasonal workers, direct bank account connections verify income and work activity in real time. Volunteer hours and educational enrollment are covered within the same platform, delivering a seamless, client-centric experience in a single interface in a matter of minutes.
Through Truv's flexible, omni-channel deployment strategy, Truv's platform meets state agencies and clients where they are: the customer portal, the office, on their computer at home, or mobile on the go while agency staff get real-time visibility into the full range of community engagement verification data. Truv's approach streamlines data collection by improving accuracy and increasing efficiency with automated processes that can handle determinations without caseworker intervention. There's no complex data-sharing agreements. No duplicate verification workflows. No chasing documents.
"The goal shouldn't just be compliance with HR1. It should also be using this moment to fundamentally rethink how eligibility verification works," says Wesley Merritt, Public Sector Consultant, Truv. "States that approach this strategically will come out of it with infrastructure that's faster, more accurate, and more equitable. That's the real opportunity here."
Getting Started
Building verification infrastructure, training staff, updating workflows, and communicating new requirements to clients all take time even with an out-of-the-box, solution-ready partner like Truv.
As agencies put plans in place ahead of January 1, 2027, the opportunity is bigger than community engagement alone — platforms that cover income verification with community engagement verification will unlock greater cost and operational efficiencies for agencies navigating HR1 requirements.
Wesley Merritt, Public Sector Consultant at Truv, shares his closing thoughts: "There's no need to build separate systems for income and community engagement verification. Look for platforms that can handle the full picture with agency systems and workflows while delivering intuitive end-to-end experiences."
With $200 million in federal funding available in 2026, agencies have an opportunity to invest and implement strategically — in technology that scales, reduces error rates, and delivers a multitude of benefits for caseworkers, clients and the state at large.
Want to see Truv in action? Request a demo with our public sector team to learn how Truv supports state agencies in meeting HR1 verification requirements.
