Medicaid’s new community engagement requirements expose a broader challenge for digital government: how to verify facts across fragmented systems. A better model combines data-first verification with portable, privacy-preserving, standards-based digital evidence.
Government programs routinely ask people to prove facts that another trusted institution already knows: where they work, how much they earn, whether they are enrolled in school, whether they completed community service, or whether they qualify for an exemption. The new Medicaid community engagement requirements make this longstanding problem especially visible because states will need to verify information across millions of individuals and many different sources, often without a single authoritative system that contains everything they need.
We recently submitted recommendations to the Centers for Medicare & Medicaid Services on how states could approach that immediate implementation challenge. Those recommendations focus on maximizing ex parte verification, creating additional reliable evidence pathways when existing data is insufficient, and ensuring that digital options remain voluntary.
The Medicaid rule raises a broader question for digital government: how should people and institutions exchange trustworthy evidence when the relevant information is distributed across many systems?
The best verification process is often one that does not require the individual to do anything at all. If an agency can reliably establish a fact using authoritative information it already has access to, it should do so before asking someone to locate and submit additional documentation.
This is the basic logic behind ex parte verification, and it matters because documentation is not free. Every additional request creates work for the individual, the organization that holds the evidence, and the government worker responsible for reviewing it. At scale, those requests can also create procedural failures that have little to do with whether a person actually satisfies the underlying requirement.
A modern verification system should therefore begin with a data-first model: use reliable government and other authorized data sources wherever possible, automatically apply supported determinations, and reserve beneficiary-submitted evidence for cases that cannot be resolved through existing information.
That approach will not solve every case. Information about a person’s work, income, education, service, or exemption status may live with employers, payroll providers, educational institutions, health care providers, platforms, community organizations, or other government programs. Some of those sources may not be connected to the eligibility system at all, which creates a familiar infrastructure problem: the relevant fact exists, but the agency that needs to verify it cannot readily access it.
Government has traditionally addressed this problem by connecting systems directly. Agency A needs information from Agency B, so the two organizations establish a data-sharing agreement, define an interface, build an integration, and maintain it over time. The same process happens again when Agency A needs information from Agency C.
Direct integrations can be the right solution for high-volume, stable exchanges, but they do not scale elegantly when relevant evidence may come from thousands of employers, providers, schools, platforms, nonprofits, and government entities. In those cases, an alternative is to make the evidence itself portable and verifiable.
A trusted organization can issue a digitally signed record attesting to a fact, and an individual can then present that evidence to another organization. The receiving system can verify where the information came from and whether it has been altered, without requiring the issuer to build a bespoke technical connection to every organization that may eventually need to verify it.
This changes the architecture of evidence exchange. Instead of assuming every trusted source must integrate directly with every relying system, it allows the individual to participate in moving trustworthy information between systems.
There is limited value in replacing a paper form with a PDF and calling the process modernized. The more meaningful opportunity is to make evidence structured, verifiable, reusable, and capable of disclosing only the information required for a particular transaction.
Consider an exemption determination. A receiving agency may need to know that a person qualifies for a particular exemption and how long that exemption remains valid, but it may not need the underlying medical record, detailed case notes, or other sensitive information used to reach that determination. A properly designed digital attestation can communicate the necessary fact without transferring the full underlying record.
The same pattern can apply to employment, education, community service, professional status, or determinations made by another government program. This is where standards-based digital credentials become useful: not simply because they are digital, but because the receiving system can verify the issuer and integrity of the evidence while limiting the data exchanged to what the transaction actually requires.
Portable evidence is only one part of the model. Individuals could also authorize certain trusted sources to make limited information available directly to an agency when it is needed.
For example, someone might authorize a payroll provider or another trusted service to provide a defined set of information for a specific eligibility purpose. When the agency conducts a later review, the information could already be available without requiring another action from the individual, creating a bridge between traditional ex parte verification and manual document submission.
This model also creates an important design requirement: authorization should be specific, revocable, and limited to the information needed for the stated purpose. The goal should not be to create larger pools of personal data, but to make the minimum necessary evidence available through a trustworthy and user-authorized pathway.
The same underlying fact is often relevant to more than one government program. Someone may be asked to establish employment, income, enrollment, or another status separately for Medicaid, SNAP, TANF, workforce programs, licensing programs, or other public services.
Sometimes those programs apply different legal standards, and a determination in one program cannot simply be imported into another. That does not mean, however, that the underlying evidence has no value outside the system that originally collected it.
Where program rules align, one agency could issue a signed attestation that another program can evaluate under its own requirements. The receiving agency remains responsible for its own decision, but it may no longer need to collect the same underlying evidence from scratch.
Over time, this can support a more composable model of government service delivery. Rather than every program independently collecting, storing, and re-verifying the same information, trusted determinations can become reusable inputs where policy rules allow.
Many of the technical building blocks for this model already exist. Standards such as the W3C Verifiable Credentials Data Model, OpenID for Verifiable Presentations, the ISO/IEC 18013 family, and NIST’s Digital Identity Guidelines provide established approaches for issuing, presenting, and verifying digitally signed information.
The harder questions are institutional. Government agencies still need to determine who is authorized to attest that someone completed qualifying work, which providers can issue an exemption attestation, which claims must be included, how long an attestation is valid, how revocation or status is checked, what evidence must be retained for audit purposes, and what happens when electronic validation is temporarily unavailable.
These are trust framework questions, and they cannot be solved simply by choosing a credential format or buying a technology platform. Agencies need to define the rules that make digital evidence meaningful within a specific program, while open standards provide a way to implement those rules without tying the system to a single vendor, wallet, identity provider, or proprietary exchange.
Better evidence infrastructure can still create barriers if it is paired with unnecessarily rigid identity requirements. Not every transaction requires the same level or method of identity assurance, so systems should apply controls that are proportionate to the risk and allow multiple approaches that satisfy the required level of assurance.
Depending on the use case, those approaches could include appropriately assured government accounts, mobile driver’s licenses, or other mechanisms. What they should not do is make access to a public benefit depend on using a particular application, completing biometric verification, or owning a smartphone.
Digital systems should create additional pathways rather than eliminate existing ones. Paper, telephone, in-person, assisted, and other appropriate channels remain essential, especially for people who lack conventional identity documents, reliable connectivity, or the ability to complete remote identity proofing.
The same principle should apply when technology fails. A credential that cannot be electronically validated because a service is unavailable, a format is unsupported, or another technical problem occurs is not evidence that the underlying claim is false. Good verification infrastructure distinguishes between a failure to verify electronically and a determination that someone does not qualify.
The new Medicaid community engagement requirements create an urgent reason to confront these questions because states will need to verify a wide range of information across a very large population. But the underlying problem is not specific to Medicaid.
Government programs across benefits, licensing, workforce development, education, and identity services routinely need to establish facts held by other trusted institutions. Today, that often results in repeated document collection, manual review, one-off integrations, and large amounts of duplicated infrastructure.
A better model begins with authoritative data and automated verification wherever possible. When that is not enough, it gives people reliable ways to bring trusted evidence into the transaction. That evidence should be portable across systems, limited to the information actually needed, and verifiable without requiring every issuer and verifier to build a custom connection.
The technology to support this model is increasingly mature, but the harder work is designing the trust frameworks, governance, and program rules that allow it to operate responsibly. That is the broader opportunity behind the Medicaid implementation challenge: not simply to digitize a new documentation process, but to rethink how government verifies facts in the first place.
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About SpruceID: SpruceID builds digital trust infrastructure for government. We help states and cities modernize identity, security, and service delivery — from digital wallets and SSO to fraud prevention and workflow optimization. Our standards-based technology and public-sector expertise ensure every project advances a more secure, interoperable, and citizen-centric digital future.
