As states implement new requirements under HR1, Medicaid and Supplemental Nutrition Assistance Program (SNAP) teams face significant changes to how they verify eligibility and continued participation. The statutory requirements of the two programs are different, and each agency must continue to make determinations according to its own rules. Yet much of the information needed to make those determinations overlaps. Both programs may need to establish facts about a person’s employment, income, participation in qualifying activities, or exemption status.
That overlap creates an opportunity for states to reduce duplicative verification without collapsing important distinctions between programs. If a SNAP agency has already received trustworthy evidence of someone’s employment, for example, that does not mean Medicaid should inherit SNAP’s determination or apply SNAP’s rules. It does raise a different question: should the person have to find and submit the same evidence again?
The distinction matters. Sharing evidence is not the same as sharing eligibility decisions. States can preserve program-specific policy while making the underlying process of establishing trustworthy facts more reusable across their health and human services infrastructure.
Eligibility verification involves several different steps that are often treated as one process. An agency needs to obtain evidence, understand where it came from, determine whether the source is authoritative, verify that the information has not been altered and is still valid, and connect it to the right beneficiary. Only then does the program apply its own policy to determine what that evidence means for eligibility.
The latter step is necessarily program-specific. The earlier ones often are not.
Consider employment evidence provided by an employer. Medicaid and SNAP may have different definitions, thresholds, reporting periods, or exceptions that determine how they use that information. Those differences should remain intact. But both programs still need confidence that the employment record came from the organization it claims to come from and that the information is authentic and current.
This is where states can begin to think beyond Medicaid- or SNAP-specific verification solutions. Common infrastructure can handle the acquisition, validation, and exchange of trustworthy evidence, while existing eligibility systems remain responsible for applying the appropriate program rules. Over time, the same infrastructure could support other programs that need to establish overlapping facts, including Temporary Assistance for Needy Families (TANF), workforce programs, and child care assistance.
The result is not a single eligibility system or a universal set of rules. It is a shared trust layer underneath distinct programs, allowing each agency to make its own decisions without requiring residents and agencies to repeatedly establish the same facts from scratch.
Once evidence and eligibility decisions are treated as separate layers, states have more options for reducing repetitive verification. Evidence collected for one program can potentially be useful to another without requiring the second program to accept the first program’s determination.
Consider someone working variable hours at a hospital. Their employer could provide a digitally verifiable record of employment, wages, and hours worked. Medicaid might evaluate that evidence against its community engagement requirements, while SNAP could use the same underlying information as part of an income or work-requirement determination. Each program applies its own definitions, thresholds, and exemptions, but the person does not necessarily need to obtain a new record from the employer every time they need to establish the same underlying facts.
The same model could apply to other common forms of evidence. A community college could provide proof of enrollment or participation in an eligible education program, while a workforce agency could provide evidence of job training. Rather than requiring residents to repeatedly track down documentation, these trusted records could remain available for them to use when another authorized program needs to establish the same fact.
Over time, this could function as a kind of benefits passport: a user-controlled collection of trustworthy evidence that residents can present across interactions with public programs. The passport would not contain a universal determination that someone is “eligible for benefits,” because eligibility remains specific to each program. Instead, it could hold evidence about the facts that programs repeatedly need to establish, with the resident deciding when and where to present it.
This approach also preserves an important responsibility for the receiving program. Medicaid would still determine whether a record satisfies Medicaid requirements, just as SNAP would evaluate it according to SNAP rules. What becomes reusable is the trustworthy evidence underneath those decisions.
For residents, that can mean fewer requests to upload another pay stub, obtain another letter, or prove the same activity again. For states, it creates a path toward cross-program benefits verification that does not depend on every program independently collecting and validating the same information.
States can enable some of this reuse through direct data integrations, and where authoritative data sources already exist, those connections should remain an important part of the verification process. But relying exclusively on point-to-point integrations becomes harder as the number of programs and evidence sources grows.
Medicaid might need information from workforce agencies, employers, educational institutions, or other sources. SNAP may rely on many of those same sources, as might Temporary Assistance for Needy Families (TANF) or child care assistance programs. If every exchange requires the two parties to establish and maintain a dedicated integration, cross-program verification can quickly become a growing web of connections.
A benefits passport offers a complementary model. An employer, school, workforce program, or government agency can provide trustworthy evidence directly to the resident in a form that other authorized programs can independently validate. The resident can then present that evidence where it is needed, rather than requiring the original source to build a technical connection to every program that might eventually need its data.
This does not mean replacing existing integrated eligibility systems or valuable direct data connections. It means giving states another way to move trustworthy information across organizational and technical boundaries, especially where a direct integration does not exist or would be costly to build. The goal is an infrastructure in which trustworthy evidence can travel more easily than it does today, while the resident retains greater control over how that evidence moves between contexts.
Making evidence portable requires common infrastructure underneath individual programs. States can share a trust registry that identifies authoritative issuers, validation services that confirm evidence is authentic and current, standard formats that allow different systems to understand the evidence, and consent infrastructure that governs how residents present it.
For example, when a resident presents employment evidence from their benefits passport, Medicaid should not need a custom integration with that employer to determine whether the record is trustworthy. Shared infrastructure can establish who issued it, whether that issuer is recognized for that type of evidence, and whether the record remains valid. Medicaid’s existing eligibility system can then apply its own program rules.
This allows states to modernize the trust layer without replacing their integrated eligibility systems or building separate verification stacks for every program.
Cross-program interoperability is sometimes treated as a data-sharing problem: connect more agency systems so each program can retrieve information held by the others. Those integrations can be useful, but broader access to beneficiary data should not be the price of reducing administrative burden.
A user-controlled benefits passport offers a different model. Instead of giving Medicaid broad access to another agency’s records, a resident can present the specific evidence Medicaid needs. The program can validate that evidence without receiving unrelated information or gaining ongoing access to the system where it originated.
This makes data minimization part of the architecture. Residents have greater visibility and control over what they share, while agencies still receive trustworthy evidence they can independently evaluate. Direct authoritative data checks and nondigital pathways will remain important, but interoperability does not have to mean centralizing more data or moving it between agencies without the beneficiary’s involvement.
HR1 is creating immediate implementation work across both Medicaid and SNAP. If states approach those requirements as entirely separate projects, they risk procuring separate solutions for problems that share much of the same underlying infrastructure.
The opportunity is not to combine Medicaid and SNAP eligibility logic. It is to identify the capabilities beneath those rules that a state should only have to build once: establishing trusted sources, validating evidence, enabling residents to reuse it, and exchanging it with existing eligibility systems. That investment can extend beyond the immediate requirements of HR1. The same trust infrastructure can support other benefits programs and new verification needs over time, turning a near-term compliance effort into a more durable foundation for integrated benefits delivery.
If your Medicaid and SNAP teams are planning HR1 implementation separately, SpruceID can help identify where verification infrastructure can be shared.
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