One Law, Two Programs: Coordinating Medicaid and SNAP Implementation

Issue

Stemming from new federal changes, states are undertaking significant updates in both Medicaid and SNAP at the same time, with substantial overlap in the populations affected. Nationally, about one in five adults subject to the new Medicaid work requirements also receives supplemental nutrition assistance program (SNAP),meaning states must stand up new eligibility and verification processes for many of the same people—simultaneously. Historically, Medicaid and SNAP agencies have operated largely independently when implementing new federal requirements. The overlap in affected populations creates a new urgency for cross-agency coordination.

Under the new federal requirements, state Medicaid agencies must verify that enrollees complete at least 80 hours per month of qualifying activities—such as work, community service or a work program—at application and at each six-month renewal. States are expected to rely as much as possible on existing data sources to complete these checks automatically. The law also creates a direct link between Medicaid and SNAP: individuals who are members of a household that receives SNAP are deemed to meet Medicaid’s requirements, requiring coordination across programs. Further, certain individuals are excluded from Medicaid work requirements, including those who are medically frail.

Under CMS’s Interim Final Rule, the Medicaid medical frailty exclusion is now more closely aligned with SNAP’s exemption for individuals who are physically or mentally unable to work. Although the Medicaid and SNAP standards are not identical, CMS interpreted medical frailty to require that an individual’s medical condition or special medical needs significantly impair their ability to comply with the Medicaid work requirements. As a result, there is now substantial overlap between the two health-related exemptions and individuals identified as exempt from SNAP work requirements because those who are physically or mentally unable to work are also likely to qualify for the Medicaid medical frailty exclusion.

At the same time, the new federal law makes significant changes to SNAP. Work requirements for able-bodied adults without dependents (ABAWDs) now extend up to age 64, and the caregiver exemption is narrowed to individuals caring for children under age 14.

The financial stakes to implement the new eligibility changes accurately are high on both sides. For Medicaid, beginning in FY 2026, states face reduced federal funding if payment error rates for ineligible individuals exceed 3%. For SNAP, beginning in October 2027, states with payment error rates at or above 6% will be required to pay a share of benefit costs for the first time in the program’s history. State benefit costs will be determined on a sliding scale and will be up to 15% for states with error rates of 10% or higher. USDA’s current data show only nine states currently meeting the required error rate of below 6%, and many states are near or exceeding the Medicaid threshold, creating compounding financial risk.

Although key implementation deadlines are rapidly approaching, states are likely to implement these changes in phases, and it is not too late to incorporate Medicaid-SNAP coordination into implementation plans and prioritize additional alignment through iterative system, policy and operational changes over time.

A Call for Coordination

All of this calls for tightly coordinated operational planning across Medicaid and SNAP agencies. While program policies will remain intentionally distinct—states will need to coordinate verification processes and workflows to support shared populations (KFF calculates an 80% overlap between Medicaid and SNAP recipients). Just as important, eligibility workers will need clear guidance and training on where program rules diverge to ensure accurate and consistent determinations. Without this level of coordination, states risk duplicative processes, increased error rates and unnecessary coverage loss.

Based on our work supporting states with H.R. 1 implementation, the following are examples of important areas where states may want to immediately commence cross-agency coordination.

• Eligibility Systems Changes and Data Verification. The statutory link between SNAP and Medicaid work requirements cannot function unless the two programs’ systems can communicate eligibility and exemption status. States with integrated systems should confirm that these connections work for these new use cases. States with separate systems will need to establish formal data-sharing processes ahead of implementation, which is effective January 1, 2027. Federal SNAP administrative funding will be reduced as of October 1, 2026—so state work should be well underway to maximize available funds. At the same time, SNAP eligibility rules are more restrictive than Medicaid’s in several key respects. States must ensure Medicaid implementation is driven by Medicaid’s own federal requirements—not default to SNAP policies where the two programs diverge. For example, to avoid coverage loss, where states have flexibility to accept auditable self-declaration for Medicaid eligibility, they should not impose additional documentation requirements solely because SNAP requires verification in similar circumstances.
• Outreach and Engagement Strategies. The new federal law requires Medicaid agencies to notify all potentially affected enrollees at least three months before work requirements take effect. Medicaid and SNAP agencies should consider designing outreach together, drawing on both programs' enrollment data to identify shared caseloads, coordinating messaging so households receive consistent information about changes in both programs, and aligning investments in community-based outreach partners—health centers, enrollment assisters, food banks, faith-based organizations—that are already reaching affected populations across both programs.
• Worker Training and Policy Alignment. Eligibility workers are where policy becomes practice—and the new law’s cross-program interactions, particularly the SNAP-exempts-Medicaid rule, require workers in both programs to understand how the other program's determinations affect their own. Inconsistent training creates direct error risk, so agencies should establish shared training curricula and policy alignment protocols so that a SNAP worker who identifies a relevant exemption status knows how to flag it, and a Medicaid worker knows how to act on it.
• Financing Alignment. SNAP’s administrative financing changes are not just a program-specific budget issue—they have cross-agency resource implications. For example, if the reduction in federal SNAP administrative funding leads states to cut eligibility worker capacity or call center capacity, those decisions will have direct downstream effects on Medicaid accuracy, processing timeframes and work requirement verification—particularly in states where workers or systems serve both programs. Medicaid and SNAP agency leadership need to model these cross-program resource dependencies together, not within each agency's appropriations process in isolation.
• Partnership Alignment. As states seek to minimize coverage disruption under H.R. 1 and build longer-term administrative efficiencies, they can leverage existing partners and investments to strengthen alignment between Medicaid and SNAP. Medicaid managed care plans and providers that are already supporting Medicaid eligibility and enrollment efforts could expand those workflows to help individuals navigate SNAP eligibility and enrollment. Similarly, electronic health record (EHR) vendors and health information exchanges that are modifying workflows and data capabilities to support Medicaid medical frailty determinations could consider how those same investments could support identification and verification of SNAP exemptions. Aligning these efforts can reduce duplicative processes, maximize existing infrastructure and make it easier for individuals who interact with both programs to maintain the benefits for which they are eligible.

Looking Ahead

The simultaneous implementation of major Medicaid and SNAP changes presents states with both an immediate operational challenge and an opportunity to build stronger connections between programs that serve many of the same people. With key implementation deadlines approaching, coordination cannot wait until policies and systems are fully developed. Medicaid and SNAP agencies should begin now to identify shared populations, establish data-sharing and verification processes, align systems investments, coordinate outreach and worker training and understand where program rules must remain distinct. These efforts can help states reduce administrative duplication and financial risk while minimizing unnecessary coverage and benefit losses during implementation. Just as importantly, the infrastructure states build now can provide a foundation for more integrated eligibility and enrollment processes well beyond H.R. 1, making it easier for eligible individuals and families to access and maintain the health care and nutrition assistance for which they qualify.

We are already supporting states in navigating these and other cross-agency implementation issues, including identifying opportunities for Medicaid and SNAP alignment, developing coordinated policy and operational approaches, and working through the systems, data, workforce, and communications implications of the new requirements. This work has reinforced that states do not need to have every implementation decision resolved before beginning cross-agency planning—and that early coordination can help identify practical opportunities and challenges before they become embedded in policy, systems, and operations.

For questions about these issues or how we are supporting states with implementation and coordination, please reach out to .

H.R. 1, 119th Cong., Pub. L. No. 119-21, 139 Stat. 72 (2025).

 (March 2026). 

Supra note 1.

Supra note 1.

Medicaid Program; Community Engagement Requirement for Certain Individuals, 91 Fed. Reg. 33,348 (June 3, 2026).

Supra note 1.

(June 24, 2026). 

(July 23, 2006).

 (June 26, 2025).