Series 5: Why Employer Roles and Labor Realities Will Define Success in the New World of Work Requirements
Medicaid work requirements will make employers key players in healthcare access, demanding flexible policies that reflect real-world labor and verification challenges.
Medicaid work requirements are reshaping the employer-employee relationship, making businesses unexpected partners in the social safety net. Starting in 2026, millions of workers will rely on employers to verify hours for healthcare eligibility, creating new responsibilities and risks, but also strategic opportunities. Forward-thinking companies can turn compliance into competitive advantage by automating verification, offering flexible scheduling, and partnering with Social Determinants of Health platforms to address barriers like childcare and transportation. While small businesses face unique challenges, collaborative solutions and technology can ease the burden. Employers who approach this shift as a workforce investment, not just an administrative task, can unlock benefits like reduced turnover, improved productivity, and stronger employee well-being.
This shift, however, doesn’t look the same for every employer. The 18.5 million workers subject to work requirements are employed across a highly diverse landscape from Fortune 500 corporations with advanced HR systems to small businesses operating on razor-thin margins, unionized industries with multi-employer arrangements, and public sector organizations constrained by procurement rules. Each segment faces distinct challenges and opportunities: large employers can invest in automation and navigation tools, while small businesses need simple, low-burden solutions. Taft-Hartley plans and public agencies offer centralized support models but require tailored strategies. Recognizing this diversity is crucial as uniform solutions will fall short. Policies and employer practices must be flexible and tailored to these differences to avoid coverage gaps and ensure fair, equitable outcomes.
At the same time, meeting the 80-hour monthly requirement is far more complicated than simply being employed. Unstable schedules, seasonal fluctuations, and part-time caps make hours unpredictable, forcing many workers to juggle multiple jobs or informal work that lacks documentation. High turnover and probationary periods add gaps that monthly verification systems treat as failures while compliance also hinges on employer participation, a role most never agreed to take on. Large companies may automate verification, but small businesses face real burdens, and fears about immigration enforcement, liability, and data privacy often lead employers to ignore requests. Unionized workers face additional challenges: multi-employer arrangements, seasonal work, and apprenticeship programs complicate compliance even as unions maintain precise hour records through hiring halls and benefit funds. Connecting these systems to state verification processes could transform compliance from fragmented and inequitable to streamlined and fair. Ultimately, whether work requirements succeed will depend on designing systems that reflect the realities of both employers and workers, rather than punishing those who fall through the cracks of outdated assumptions.
Read Syam Adusumilli’s Series 5 articles for a detailed look into employer liability concerns, union-based verification solutions, and practical strategies to navigate Medicaid work requirements without leaving workers behind.
Read Series 5 here:
5A: Employers as Safety Net Partners: The Private Sector's New Role
5B: The Employer Segmentation Challenge
5C: The Unstable Employment Reality
5D: Employer Liability and Reluctance
