States face data integration challenges as they prepare to verify Medicaid recipients’ education status under H.R. 1

States preparing to implement new Medicaid eligibility requirements under the One Big Beautiful Bill Act may be able to rely on a national database of college enrollment records to determine whether some beneficiaries qualify for an education-based exemption from the law’s work requirements. 

The National Student Clearinghouse, a nonprofit that maintains more than 130 million verified education records and receives data from nearly 3,700 colleges and universities across the country, is working with federal agencies, states and third-party vendors to develop a process for verifying student enrollment ahead of the Jan. 1 implementation deadline. 

Melba Amissi, chief strategy and operations officer at the National Student Clearinghouse, said the organization is preparing to provide states with access to verified education records through an existing application programming interface.

“With our coverage, it really allows us to provide that real-time verified data,” Amissi said in an interview. “We have so many people coming directly to us because we are the only entity that has that level of coverage for post-secondary [education data], and for those institutions that get Title IV funding.” 

Under H.R.1, certain Medicaid recipients can satisfy the law’s community engagement requirements by enrolling at least half-time in an eligible educational program. However, state Medicaid agencies will need reliable ways to determine whether beneficiaries meet the enrollment criteria, adding another layer of data verification to already complex eligibility systems.

The organization expects to support verification as often as every six months, but Amissi said the biggest obstacles for states are likely to involve integrating education records into existing eligibility workflows, updating or establishing data-sharing agreements and resolving data privacy requirements. 

“It’s less about demand and more about some of the friction around implementation,” she explained.

States are approaching the process in different ways, with some exploring direct connections to the clearinghouse while others working through third-party “aggregators” that already provide Medicaid eligibility and verification services. Amissi said states with the technical resources to build direct integrations can use their API-based system that allows organizations to request education records.

The challenge is not necessarily finding the education data, but incorporating it into processes to determine Medicaid eligibility. Amissi said in her experience, enrollment has not traditionally been part of those workflows, which means agencies will need to make changes to accommodate the additional verification requirements.

“It really depends on what their data sharing agreements look like and their privacy around who’s eligible to see the records and how integrated their systems are,” she said. “We’re not privy to that type of information, but we do know most of the states have determined they want to go use the aggregators because it’s easy for them to use the systems that are already in place rather than trying to fix those systems themselves.” 

“Knowing the data is in a place where we can find it”

The effort comes as states are already working to overhaul Medicaid eligibility systems to accommodate more frequent renewals and additional reporting requirements under H.R.1. 

Danny Mintz, Code for America’s safety net policy director, described how states’ ability to automate eligibility determinations often depends on whether agencies can effectively integrate data from different sources into their existing systems.

In 2023, the organization analyzed the benefits systems of five states as part of its Safety Net Innovation Lab, an initiative to improve access to services in states where large numbers of residents are eligible for government assistance programs but have not claimed them. In recent years, particularly during the unwinding of pandemic-era continuous coverage, Mintz said, states have worked to improve those systems by analyzing where automated renewals break down.

“A lot of those factors have to do with how the data is integrated into their system [and] what are the specific worker processes for working through the data that’s available,” Mintz told StateScoop in April.

In Minnesota, for example, improvements to Medicaid renewal workflows helped reduce the average time caseworkers spent on a renewal from 70 to 11 minutes. More recently, Maryland partnered with Code for America, Civilla and Public Policy Lab to redesign Medicaid applications, notices and caseworker operations. 

Amissi said the clearinghouse anticipates that education enrollment verification will occur about every six months, based on the academic calendar and reporting schedules of participating institutions — colleges and universities typically submit enrollment information to the organization every 30 to 60 days. 

Though the clearinghouse has not analyzed how many of its student records correspond to Medicaid beneficiaries, Amissi said its broad coverage of institutions that receive Title IV federal funding should help states access the information they need. She cautioned that states will need to account for differences in their administrative structures, including the role of county agencies that help determine eligibility and administer benefits, and advised agencies to first map their existing workflows, identify where education verification needs to fit and coordinate with other organizations already working on implementation.

“[States] did have quite a short period of time to get ready, and that’s happened quite a lot over the last couple of years with a lot of the rules and regulations that have been rolled out,” Amissi said. “The one thing I’ve consistently heard is that ‘it’s great to know the data is in a place where we can find it.’”