States Must Align Marketplace Pathways With Medicaid Work Rules
State Health and Value Strategies examines how states must coordinate Marketplace-based Medicaid applications with new federal work reporting requirements taking effect January 1, 2027, under Section 71119 of H.R. 1 and a related CMS interim final rule. Because the ACA's "no wrong door" framework lets people apply for Medicaid through State-Based Marketplaces or HealthCare.gov, states using account transfer processes or integrated eligibility systems must ensure these applicants are evaluated for work requirement exemptions or compliance without filing a separate application. The brief outlines how states are updating applications, eligibility system logic, verification processes, notices, and operational workflows to incorporate work reporting determinations into existing Marketplace-to-Medicaid transfer pathways ahead of the 2027 deadline.