House Resolution One (H.R. 1) brings major changes to Medicaid and SNAP programs. And it gives states a relatively short window to put them into practice. For Medicaid, states have until January 1, 2027 to stand up new community engagement requirements under H.R. 1. CMS’s interim final rule (effective July 31, 2026), tells them how: verify work-requirement compliance first through existing state data, wage records, Medicaid provider payment data, encounter data, higher-education enrollment, before asking a member to prove anything on paper.
Starting with renewals on or after January 1, 2027, Medicaid eligibility for expansion adults will need to be reviewed every six months instead of once a year. Further, states must screen enrollees against the Social Security Administration’s Death Master File quarterly and run cross-state enrollment checks monthly, alongside monthly address validation.
SNAP is on a parallel track. Work requirements now reach able-bodied adults age 18 to 65, including parents of children 14 and older, with far fewer waivers available to states with weak local job markets. Residency verification, using a mortgage statement, lease, or utility bill, has been required since February 9, 2026. And starting in FY2028, states with higher SNAP payment error rates will have to shoulder a larger share of the program costs with state funds.
Read all of that together and a pattern emerges. H.R. 1 signaling a massive data challenge. States will need to determine whether records from different systems and programs belong to the same person. And do it accurately, repeatedly, and at much greater scale. This new matching problem, layered across two of the largest benefit programs in the country, will put a price tag directly on getting the match wrong, all on a compressed timeline and with fewer federal resources to do the work.
Ex parte verification only works if the “parte” is the same person
CMS wants states to verify Medicaid compliance using data the state already has, rather than paperwork from the member. That’s the right call operationally. It’s also a much harder identity problem than it sounds.
Ex parte verification means matching a Medicaid enrollee against payroll data, encounter data, provider payment records, and education enrollment files. These come from systems that were never built to share an identity key. A wage database identifies someone by SSN and employer-reported name. A Medicaid eligibility system identifies the same person by a case number and however their name was typed in at last year’s renewal. An encounter dataset might have neither, just a member ID and a service date.
If those records don’t resolve to the same person with confidence, the state has two bad options. Match too loosely, and someone else’s work history gets attached to a member’s case. Or a compliant member gets flagged as non-compliant because the data behind them didn’t connect.
Match too conservatively, and the state falls back to asking members for paperwork. That’s the exact administrative burden ex parte verification was supposed to eliminate.
Either failure can have serious consequences. An eligible person loses coverage, or a state can’t demonstrate compliance verification actually happened.
Six-month redeterminations, and checks that now run monthly and quarterly
Cutting Medicaid expansion redeterminations from twelve months to six doesn’t just double the workload. It doubles the number of moments where a state’s identity infrastructure has to get the match right under time pressure.
Layer in the new cadence of federally mandated checks and the exposure compounds further. Quarterly Death Master File screening means a state must reliably match its own enrollee records against a federal file. That means reconciling names, dates of birth, and SSN combinations that are never formatted quite the same way twice.
Monthly cross-state enrollment checks pose a similar challenge. To catch someone drawing benefits in two places at once, states must match a resident against every other state’s enrollment file. This fails immediately if a maiden name, a moved household, or a transposed digit breaks the link. Monthly address validation depends on the same underlying question: is this the current, correct address for this specific person, not someone who shares their name.
Each of those checks is a small identity resolution problem on its own. Run monthly or quarterly, at the scale of a state Medicaid population, they become a sustained operational load that a fragmented identity layer cannot keep up with indefinitely.
SNAP adds a second front, and a direct financial stake
SNAP’s expanded work requirements bring a larger and more varied population into scope. This now involves able-bodied adults 18 to 65 and parents of teenagers, many of whom move, change jobs, and change households more often than the eligibility system tracking them. The new residency verification requirement means a state must confirm not just who someone is, but where they currently live, using documents that arrive in inconsistent formats from a landlord, a utility company, or a mortgage servicer.
What makes SNAP different from Medicaid’s compliance exposure is that the financial consequence is explicit and immediate. The payment error rate that determines a state’s cost share is a direct function of how often the state’s records say one thing and reality says another. That’s exactly the outcome duplicate, fragmented, or badly matched identity data produces. A state sitting above the 10% error threshold isn’t facing an abstract audit risk. It’s facing a 15% cost share on its entire SNAP benefit allotment. This is calculated from an error rate that identity fragmentation helped create, at the same moment federal administrative funding to fix it has been cut in half. Things are not looking good, currently 4 states are at or above the 10% error rate and almost all of them (41 states) are already over the 6% error line.
The mandate is one problem wearing two program names
Strip away the program-specific language and Medicaid and SNAP are asking states to solve the same problem from two directions. Both need a state to know, with confidence, whether records across multiple systems belong to the same person. That includes the person applying for benefits, the person in the wage file, the person in another state’s enrollment system, the person on the Death Master File, and the person at the address on record. Duplicate participation detection, cross-state matching, deceased-status screening, and ex parte verification are all identity resolution problems wearing different program names.
Verato Referential Matching® is built for exactly that kind of matching. It resolves records across independent systems without requiring the systems to share a common key or clean, complete data going in. Paired with native identity enrichment, it gives states a single, trusted resident record to run every one of these checks against, monthly, quarterly, or at redetermination. Contrast this with a set of disconnected files a caseworker has to reconcile by hand each time a new federal deadline lands.
States already sit on over 2,000 separate government health datasets, most with independent identifiers.1 H.R. 1 didn’t create that fragmentation. It put a hard deadline, and in SNAP’s case a hard dollar figure, on states having to resolve it anyway, across two programs, on cycles that now run monthly instead of annually.
What this means before the deadlines land
States have roughly three months, from the July 2026 CMS rule taking effect to the January 1, 2027 Medicaid implementation deadline, to prove they can verify compliance from data they already hold rather than paperwork they have to collect. On the SNAP side, the FY2028 cost-share exposure is already being shaped by the error rates states are posting right now. In FY2025 and FY2026, states can choose which year’s rate applies.
The states that get there cleanly will be the ones that treated identity resolution as the foundation underneath ex parte verification, deceased screening, cross-state matching, and error-rate accountability. These are not four separate problems bolted onto eligibility systems that were never built to sustain this cadence.
If you’re a state Medicaid or health and human services leader trying to figure out whether your current systems can hold up under H.R. 1’s new verification cadence, that’s a conversation worth having now, not in December 2026.
Talk to Verato about what a trusted, unified identity foundation would take to stand up across your Medicaid and SNAP populations before the deadlines land. Learn how states like Mississippi are leveraging the Verato MDM Cloud™ to address these and other use cases with highly accurate identity resolution, at scale, and in real-time.
1Datavant and HHS.
This post reflects publicly available information on H.R. 1 and CMS implementation guidance as of September 2026. Requirements, thresholds, and timelines are subject to further federal rulemaking and state-level variation.
Verato® and Verato Referential Matching® are registered trademarks of Verato, Inc.