November 5, 2025 • 4 Min Read

The forthcoming expansion of Medicaid work‑requirement programs puts millions of members at risk—not because they aren’t compliant, but because their data systems aren’t. Analysts estimate that 5.2 to 14.9 million enrollees could lose coverage by 2027 if reporting and verification systems remain fragmented. In 2018, for example, the Arkansas program disenrolled 18,000 people due to reporting failures—not actual non‑compliance.

What’s changing:

• Work‑requirement states demand monthly verification of employment and activities.
• Employment, SNAP/TANF, workforce, and Medicaid data live across separate silos.
• The Centers for Medicare & Medicaid Services (CMS) is sharpening audit requirements for error‑free evidence trails.
• Many low‑income, rural, elderly and non‑digital populations struggle with portal access, raising the risk that procedural gaps—not behavior—drive coverage loss.

A New Way to Think About Integration

Integration is how you protect members and manage risk. Treat data integration as a continuous program, not a one‑time project:

• Translate every work‑requirement rule into structured “user stories” with audit evidence.
• Stand up governance frameworks that ensure consistent definitions across all programs (Medicaid, SNAP/TANF, workforce).
• Build dashboards to monitor verification events, disenrollment triggers, and audit exposures in real‑time.
• Establish sprint‑based assurance cycles—rather than annual audits—to surface failures early.

When done right, integration protects coverage, supports providers and safeguards compliance.

The Risks of Waiting

Delaying means you face:

• Mass disenrollments driven by system error, not non‑compliance.
• CMS audit sanctions and contract risk.
• Provider disruption as disenrolled members lose access and return to uncompensated care.
• Disproportionate adverse impact on vulnerable populations—raising equity concerns.
• Operational cost escalation as manual workarounds proliferate.

The real danger is a reactive loop: resources drained, trust eroded, financial exposure mounting.

Where to Start

There’s still time to transition from fragmented systems to a unified compliance platform before the major verification and audit pressures fully land. Key actions for payers:

• Build an audit‑ready data infrastructure and governance framework that spans Medicaid, SNAP/TANF, workforce and employment data.
• Modernize processes to enable continuous verification, early disenrollment risk detection and proactive outreach.
• Align your integration efforts with provider stability, member access and value‑based care imperatives.
• Leverage flexible talent, technology and analytics to scale during peaks (redeterminations, external audits).

When executed strategically, data integration doesn’t just reduce risk, it creates a competitive advantage in the Medicaid market.

Want to learn more? RGP can help. Contact our experts today to see how to get started.