Editor’s Note: This is the second installment in our blog series, “Decoding H.R.1: What It Actually Means for CHWs and CBOs.” (Click here to read the previous.) Check back each month as we examine the impact “One Big Beautiful Bill Act” and Medicaid eligibility have on the workflows of the community health workforce nationwide. 

The conversation about Medicaid community engagement requirements has largely focused on the requirement itself: certain Medicaid beneficiaries will need to demonstrate that they are working, participating in qualifying activities, or meet an exemption to maintain coverage.

But there’s another part of the equation that may prove just as consequential, and far less visible.

What happens when Medicaid eligibility becomes a monthly assignment in most states?

Under the provisions of H.R. 1, certain Medicaid expansion adults will generally need to demonstrate at least 80 hours per month of qualifying community engagement activities, such as work, education, community service, or certain caregiving activities, or else prove monthly income equivalent to at least 80 hours at federal minimum wage (an income of $580 per month). States will be responsible for determining how those requirements are implemented and verified.

That means the challenge won’t simply be whether someone is working or otherwise qualifies.

It will be whether they can prove it, submit the right information, understand what is being asked of them, and respond when something is missing.

For millions of people navigating Medicaid, that distinction matters.

Eligibility isn’t the same as coverage

Consider someone working part-time whose hours fluctuate from month to month. Or a caregiver whose responsibilities qualify for an exemption. Or someone experiencing a health condition that limits their ability to work. Or a person who meets the requirements but doesn’t have easy access to pay stubs, employer documentation, or reliable internet.

They may qualify. But qualification alone doesn’t guarantee successful navigation of the process.

As states develop their approaches to implementing the new requirements, Medicaid beneficiaries may face new reporting, verification, and documentation responsibilities. States are also expected to conduct outreach and provide information to beneficiaries about the new requirements and how to comply.

This creates a new kind of health coverage risk: administrative noncompliance.

And we have already seen how powerful administrative barriers can be.

The Medicaid unwinding demonstrated that people can lose coverage not necessarily because they are no longer eligible, but because they don’t successfully complete a renewal or provide information requested by the state. The lessons from that experience should inform how states, health plans, providers, and community organizations prepare for the next major wave of Medicaid administration.

Where CHWs become essential

Community health workers are uniquely positioned to help bridge the gap between policy and practice.

A CHW can help a Medicaid member understand a notice, identify whether they may qualify for an exemption, determine what documentation they need, connect them to community resources, and help them follow through when an application or verification request is incomplete. Just as importantly, CHWs can identify barriers that aren’t visible in administrative data.

A member may technically have a job, but inconsistent transportation may make it difficult to maintain required hours. A caregiver may qualify for an exemption but not realize that their circumstances count. Someone experiencing housing instability may struggle to keep track of paperwork or receive time-sensitive notices.

These aren’t simply eligibility problems. They’re navigation problems. And navigation problems are precisely where CHWs excel.

Medicaid support can’t be reactive

Health plans, providers, and CBOs shouldn’t wait until a member receives a termination notice to begin helping.

The organizations serving Medicaid populations can begin building proactive workflows now:

• Identify: Determine which members are likely to be affected and which populations may face the greatest administrative burden.
• Educate: Make requirements understandable and actionable; not simply provide members with a link to a government website.
• Assess: Help identify potential exemptions, qualifying activities, and documentation needs.
• Document: Help members understand what information they need to provide and how to obtain it.
• Follow up: Create processes to identify incomplete submissions, missed deadlines, and unresolved issues before coverage is terminated.
• Connect: Bring CHWs into the workflow alongside care managers, case managers, and other frontline professionals rather than treating them as a referral destination after a problem occurs.

The importance of coverage navigation

For years, we have talked about CHWs as trusted navigators who help people overcome barriers to care. That role is becoming even more important.

As Medicaid becomes more administratively complex, CHWs may increasingly find themselves helping people navigate not only how to access health care, but how to remain eligible for the coverage that makes that care possible. That is a significant expansion of the frontline workforce’s role—and an opportunity for health care organizations to rethink how they deploy CHWs.

Because if Medicaid eligibility becomes a monthly assignment, the question shouldn’t be whether people can navigate it alone. The question is whether we’ve built a system that gives them someone to navigate it with.