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Alliance Alert: The Alliance for Rights and Recovery remains deeply concerned about the ongoing implementation of new federal SNAP and Medicaid work requirements and the harmful impact these policies will have on low-income ����������ers, people with disabilities, and individuals living with mental health and substance use challenges.

Recent reporting shows that nearly 43,500 ���������� City residents are currently at risk of losing SNAP benefits as new work requirements take full effect today, despite massive outreach efforts by city agencies and community organizations. Those benefit losses alone could remove more than $100 million annually from the pockets of low-income ����������ers who rely on food assistance to survive. At the same time, states across the country are now scrambling to prepare for Medicaid work requirements scheduled to begin January 1, 2027, with implementation costs projected to reach tens of millions of dollars per state.

What is becoming increasingly clear is that states are being forced to divert enormous amounts of funding, staffing, and administrative resources toward compliance systems, paperwork verification, technology upgrades, and eligibility monitoring instead of directly investing those dollars into the services and supports people actually need.

Rather than expanding supported employment programs, peer support services, education opportunities, housing supports, healthcare access, and voluntary workforce development initiatives, states are spending millions building bureaucratic systems designed primarily to determine who should lose benefits.

Research and prior implementation efforts in other states have already shown that these policies do not meaningfully increase employment. Instead, they often result in eligible people losing healthcare and food assistance because of paperwork barriers, reporting challenges, unstable work schedules, limited internet access, language barriers, or difficulty navigating complicated systems.

Many people receiving Medicaid and SNAP are already working, attending school, caregiving, volunteering, or managing serious health conditions. Others face major barriers to employment because of disabilities, housing instability, transportation limitations, or lack of available jobs. Punitive requirements do not address these realities.

As several state officials noted in the reporting, the cost of implementing and maintaining these systems may offset much of any projected savings while simultaneously increasing uncompensated healthcare costs, food insecurity, crisis system involvement, hospitalization, and long-term instability for vulnerable communities.

We do appreciate the extensive work being done by ���������� City and state agencies to reduce harm through outreach efforts, automatic exemptions, and attempts to streamline compliance processes wherever possible. Those efforts have likely prevented thousands of people from unnecessarily losing benefits already.

Going forward, the Alliance will continue to:

• Monitor implementation of both SNAP and Medicaid work requirements
• Advocate for the most seamless and least harmful Medicaid compliance system possible
• Push for increased investment in supported employment, volunteer opportunities, peer support, education, and workforce development programs that help people meet requirements while pursuing their own goals and recovery
• Advocate for protections and exemptions for people with mental health and substance use challenges
• Keep our community updated as more information becomes available regarding implementation strategies and eligibility requirements

����������ers deserve systems that support health, recovery, stability, and opportunity, not policies that create additional barriers to food, healthcare, and basic survival. See below for recent reporting.

SNAP Work Rules May Cut More Than $100M in Benefits to ����������ers
By Amanda D’Ambrosio | ���������’s Healthcare | May 29, 2026

Nearly 43,500 city residents are at risk of losing their food assistance starting June 1 — as new federal work requirements begin to impact ����������ers’ nutrition benefits, city data shows.

The dropoff comes amid the implementation of new work requirements for enrollees of the , or SNAP, which provides benefits to 1.7 million people in ���������� City. The rules, implemented as part of President Donald Trump’s wide-ranging domestic policy legislation, H.R. 1, stand to cut meal assistance for low-income ����������ers and exacerbate food insecurity.

Approximately 40% of enrollees at risk of losing SNAP benefits are adults under 30, according to data shared with ���������’s by the Department of Social Services, which administers SNAP benefits. Young adults are less likely to have medical conditions that could exempt them from the rules, which could explain why the population skews younger, DSS Commissioner Erin Dalton said. Almost two-thirds of the individuals at risk of falling off are single adults.

DSS initially estimated that more than 340,000 residents risked losing their SNAP benefits once new work requirements took effect. Officials spent months conducting outreach and helping enrollees find exemptions for the rules, significantly reducing the total impacted population.

Still, 43,478 are at risk of losing benefits — taking more than $100 million per year out of beneficiaries’ pockets, Dalton said. “No matter what excellent government work we do, no matter how many outreach partners we have… the impact is and still will be dramatic,” she said.

As of March 1, beneficiaries who do not have disabilities or children under 14 years old in their household were required to document 80 hours of work, school or volunteering each month in order to receive cash assistance. People who are unhoused and veterans are among the populations that must meet the new rules. Previously, states could waive the federal work documentation requirement under certain conditions such as high unemployment.

The work requirements took effect on March 1, but enrollees have a three-month grace period to comply with the rules, making the first cutoff date June 1. Beneficiaries can still reach out to DSS to comply with the work rules after June 1, and the city will continue its outreach efforts, according to the agency.

City workers have helped people stay enrolled by conducting extensive outreach, including knocking on enrollees’ doors, and documenting exemptions for every beneficiary who is eligible.

The social services agency has leveraged data from the city’s public hospital system to identify potential exemptions. DSS and ���������� City Health + Hospitals forged a data-sharing agreement ahead of the new work requirements to identify beneficiaries eligible for exemptions on the back end, without requiring enrollees to submit documentation or proactively apply. Exemptions may include anything that limits an individual from working, such as a chronic condition, drug treatment or pregnancy, Dalton said.

The agency is also working on a data-sharing agreement with CUNY to identify potential enrollees who may be able to fulfill work requirements through education.

The city also conducted external outreach efforts, which included use of the Mayor’s Public Engagement Unit and partnerships with community-based organizations. But Dalton said the number of beneficiaries at risk was too vast to rely solely on outreach efforts, prompting the city to come up with ways to identify potential exemptions and keep eligible beneficiaries enrolled.

“You don’t fight a systemic attack on the social safety-net on the backs of door knockers and community-based organizations alone,” Dalton said.

The SNAP work requirements take effect as the federal government prepares to roll out new Medicaid work requirements on Jan. 1 of next year. Dalton said the rollout of SNAP work requirements have helped officials prepare for what’s to come with Medicaid, but said the new eligibility requirements taken together are “extraordinarily devastating, even with the efforts that we’re taking.”

Mayor Zohran Mamdani criticized the federal work requirements, adding that the city’s efforts to reach enrollees will not end on June 1.

“Food stamp work requirements don’t create jobs, they create hunger,” Mamdani said in a statement. “If the federal government wanted to help people find work, it would invest in public jobs programs and guarantee a living wage. Instead, it’s punishing people who are already struggling to survive.”

States Balk at The High Price of Medicaid Work Requirements Amid Budget Crunch
By Robert King and Alice Miranda Ollstein | Politico | May 30, 2026

The One Big Beautiful Bill Act signed into law in July 2025 called on all Medicaid expansion states to implement work requirements by Jan. 1, 2027. States say they will have to find millions to update their systems to implement the law.Samuel Corum/Getty Images

The Trump administration is counting on Medicaid work requirements to save the government . But well before the rules formally go into effect Jan. 1, they’re costing already-strapped states millions or tens of millions to implement.

State health departments are having to funnel resources into hiring more staff, paying for overtime, and upgrading their aging technology systems so they can determine which low-income residents are working, volunteering, caregiving, or studying enough hours to keep their Medicaid coverage. They are also building new systems to determine who is sick enough to qualify for an exemption.

Democratic state officials, most of whom oppose the policy, say it’s an unfair burden at a time when many states can least afford it – amid drops in tax revenue and federal funding as a result of other policies in last year’s One Big Beautiful Bill Act. The work requirements in that party-line law apply only to states that expanded Medicaid under the Affordable Care Act, and only to people enrolled in that expansion, who typically make more money than those covered by traditional Medicaid.

Even state Republicans who back the work requirements and have positioned the new policy as a way to fight fraud — a centerpiece of the GOP midterm campaign strategy — acknowledge it is stressing their budgets and prompting painful cuts in other areas, including health care and education.

North Carolina, for example, is  — even those not subject to the work requirements — to pay more out of pocket for services. And Arizona’s legislature is  over a state budget that would slash spending on Medicaid, food stamps, state universities and other programs in order to meet state obligations, including $14 million to implement Medicaid work requirements.

“We don’t have a bunch of extra money to go around,” said Republican Sen. Brad Hudson of Missouri, which  in 2020. “We had to make cuts this year. We’re probably going to have to make cuts next year. And, after a while, you can get into cutting some things that are pretty close to what all of us agree are essential services.”

An  by the health research organization KFF found that 92 percent of working-age adults on Medicaid either work full time, attend school, care for a relative or have an illness or disability. The remaining 8 percent included many who were retired or unable to find work.

The only states to run pilot versions of work requirements in recent years — Arkansas, an expansion state, and Georgia, a partial expansion state — saw many working residents become uninsured because they couldn’t navigate the bureaucracy. Both states also  to implement the rules and saw  as a result.

But neither that record nor the current high price tag have blunted many conservatives’ enthusiasm for the policy.

Hudson said that while the “additional cost” of enacting work requirements is causing “consternation” in his state, he expects the policy to eventually yield dividends when large numbers of beneficiaries are dropped from the rolls for noncompliance. He and other Republicans argue the rules will encourage people to find jobs with private health insurance benefits.

“I think in the long run we’ll be in better shape,” he said.

Other state lawmakers and health department leaders, as well as national experts, were less confident the policy would generate long-term savings.

States and the federal government would theoretically save money if the requirements cause millions to drop off the Medicaid rolls, as predicted. However, state officials fear any state savings will be offset or even cancelled out by expenditures to enforce the rules, as well as other impacts of the One Big Beautiful Bill Act passed last summer.

“I’m looking at the operational, I’m looking at the programmatic, and I’m looking at the fiscal challenges associated with the implementation of this bill, and it’s taking a significant amount of financial resources away from a system that people depend on,” said Marvin B. Figueroa, the Virginia Secretary of Health and Human Services.

Making tradeoffs
POLITICO asked officials in 37 states that expanded Medicaid through the Affordable Care Act, and the District of Columbia, how much they are spending to implement work requirements by the Jan. 1 deadline, and how much the federal government is helping to pick up that tab. Twenty-one responded, reporting upfront costs of between $4 million and more than $30 million that must come from state coffers. Some had also calculated ongoing annual costs, while others had not.

Only Nebraska is already enforcing the rules, which apply to working age adults on the expansion — including parents of children age 14 or older — who are not deemed “medically frail.” Montana is expected to do so starting in July.

While the One Big Beautiful Bill Act included $200 million in federal funds to be divided between expansion states to help pay for implementation costs, several officials said it won’t be nearly enough to cover them.

North Carolina, for example, got $1.9 million in federal funding to implement the work requirements, but expects it will need to spend an estimated $31.2 million annually to enforce them and conduct the biannual eligibility checks Congress mandated. The state is considering several avenues to make up the cost, including raising the tax on premiums for privately run managed care plans that run the Medicaid program for the state.

Pennsylvania Democratic Gov. Josh Shapiro proposed a $7.8 million outlay to update the state’s IT systems before the 2027 deadline, on top of $6.5 million in federal grants the state is expecting to help with the tech upgrades.

Pennsylvania expects it needs to hire nearly 400 hundred people to implement the work requirements and other parts of the megabill.

“Instead of focusing on programs to help Pennsylvanians achieve and maintain health, this law has forced our teams to focus on programs that will help people complete paperwork,” said Valerie Arkoosh, Pennsylvania’s secretary of health and human services.

Ohio, meanwhile, estimates that it needs $28 million over two years for the work requirements to update systems, staff and outreach.

New Mexico estimates it will cost the state $24 million in state funds over 18 months to make changes to its Medicaid system and to include changes to the IT system for the SNAP food program. The One Big Beautiful Bill included changes to the exemptions for work requirements which already exist under SNAP, which serves low-income people.

The Centers for Medicare and Medicaid Services said in a statement it is helping states beyond the $200 million in funding. This includes in-person and virtual sessions to help states engage with tech vendors and give them ongoing technical assistance.

The added cost of enforcing the new work rules is just one stressor for states.

A study from the think tank RAND s are expected to decline by a collective $664 billion through 2034 — a blow to both expansion and non-expansion states.

That’s because Republicans’ megabill put new limits on two tools states have long used to draw down federal dollars. One is a cap on the taxes states can charge health providers, which they used to help pay for their share of Medicaid. Hospitals haven’t minded the tax because they can get higher payment rates in return.

With reduced revenue, states will have less money to pay their share of Medicaid, and the amount of federal matching dollars they can claim will decline as well.

Congress also reduced the amount of money states can funnel to certain types of health care providers, such as those in rural areas.

Even states doing well financially, like Minnesota , are balking at the high price tag.

While Minnesota, which has a small budget surplus, expects to spend around $14 million this year to implement the work requirements, state lawmakers noted that amount doesn’t include a one-time $90 million infusion of funding for county governments to hire more workers and upgrade their technology.

“Most of the bureaucratic and administrative burden of this work requirement verification will fall on the counties,” said Democratic State Sen. Matt Klein, noting many of those county governments are “minimally staffed.”

Klein, a doctor, said he would have preferred spending the state’s surplus to cover more Minnesotans or improve their coverage, and worries the work requirements policy will have the opposite effect.

“The reason it saves money on Medicaid is because they know we’ll be kicking people off of health care,” he said, adding that both people who aren’t working and those who are employed but struggle to prove their work status will be targeted for removal. “And when people don’t have health care coverage, they will come in sicker, and they’ll come in later. Hospitals will be burdened with caring for them, regardless, and they’ll be uncompensated.”

The costs to states for Medicaid under the expansion is lower than for traditional Medicaid, with the federal government paying roughly 90 percent of costs and states about 10 percent. Costs for traditional Medicaid are split roughly 50-50.

A few states told POLITICO they do not yet have an estimated cost for implementation because they are awaiting key information from CMS.

The agency has until June 1 to issue pivotal guidance to states, including what conditions qualify someone for a “medically frail” exemption from the work requirement, and how to verify that someone is attending school instead of working.  began enforcing the work requirement before receiving this guidance.

States can fairly easily check if someone is working since they already have to verify a beneficiary’s income in order to sign them up for or renew their enrollment in Medicaid. States can use tools such as Equifax, a database for employers to submit employee information such as income.

States may struggle, however, to verify the income and work hours of people who are self-employed or rely on gig work or seasonal jobs. Some states plan to ask individual beneficiaries for permission to reach out to their employers or access their bank accounts to verify information, said Jennifer Tolbert, deputy director for Medicaid and the uninsured for the health research organization KFF.

Diving for discounts
One of the biggest expenses associated with the new rules, state leaders told POLITICO, is the hardware and software needed to process the new paperwork.

The federal government will cover 90 percent of the cost for a new IT system, with states picking up the rest of the tab. However, that declines to a 75 percent-to-25 percent split for ongoing costs like maintenance and operations of the IT systems.

In late January, CMS announced an agreement with ten tech companies — including major vendors such as Deloitte and Optum — to  and products to states to help with implementation.

A majority of the states that responded to POLITICO said they are looking into that program, but don’t yet know how much it will save them.

Pennsylvania, for example, hasn’t opted into any free services “due to lack of clarity from those vendors on ongoing maintenance costs and system compatibility issues, among others,” the state’s health department said. Instead, leaders there are looking into discounts within its existing contract with its primary IT vendor.

Contracting with another company in order to get the federally-negotiated discount could violate those existing contracts, according to Tolbert at KFF, which did a survey of states affected by the work requirements.

Connecticut told POLITICO the discount program won’t work for them because their eligibility system is older and “not well suited for making complex changes.”

The state is also wary of making costly modifications because of the “uncertainty around future federal policy changes.”

South Dakota’s health department said the state isn’t aware of any free or discounted products by vendors working with CMS that are compatible with its eligibility system.

Others, including Arizona, say they have gotten a break through the program. But lawmakers worry it won’t be enough to offset the other burdens from the One Big, Beautiful Bill Act.

“The struggle we are experiencing right now, as we’re trying to negotiate a budget, is with the tax impact of [the megabill] leading to lessened revenue on top of these additional costs of compliance,” said Arizona Sen. Priya Sundareshan, the leader of the chamber’s Democratic caucus. “It really makes it hard to fund any of the rest of the services that Arizonans rely on.”