Medicaid Work Reporting Requirements Toolkit - State Reporting Requirements Outlined in the Paperwork Reduction Act

Sep 12, 2026

Upload by Sage

Toolkit prepared by Manatt Health explaining state obligations under CMS’s June 1 interim final rule for Medicaid work reporting requirements. CMS requires states to submit new data to CMS effective January 1, 2027, for monitoring eligibility and enrollment operations and potential integrity concerns. The guide summarizes PRA-driven changes impacting T-MSIS, Medicaid and CHIP Eligibility Processing (EP), and Performance Indicator (PI) reporting, including new monthly data metrics, data elements, and system/process updates needed to ingest and report required information.

LanguageEnglish

CategoryPresentations

FormatPDF

Pages7

Reading Time3 min

AccessFree to download

State Reporting Requirements

Federal deadlines and CMS intent

Data submission scope

Transformed Medicaid Statistical Information System (T-MSIS)

New monthly reporting requirements

PRA zip materials and state implications

Eligibility Processing (EP)

New renewal data metrics (9-13)

PRA materials provided and required EP changes

Performance Indicator (PI)

Additional monthly metrics and required PI updates

State Reporting Requirements Outlined in the Paperwork Reduction Act for Medicaid Work Reporting Requirements Prepared by Manatt Health July 2026 The Centers for Medicare & Medicaid Services’ (CMS) June 1 interim ﬁnal rule (IFR) on Medicaid work reporting requirements requires states to submit data to CMS, eﬀective January 1, 2027. In the IFR’s preamble, CMS states that it intends to use the data to monitor ongoing eligibility and enrollment operations and to identify potential program integrity concerns. CMS also indicates in the IFR that, to the extent possible, it will “develop a community engagement report using existing data elements reported by States through the PI, EP, and T-MSIS data collection eﬀorts [ .]” However, CMS’ subsequent Paperwork Reduction Act (PRA) listing 1 outlines substantial new changes that states will need to make to their systems and processes to collect and report new data elements to CMS. This toolkit summarizes the changes that states will need to make to their existing CMS reporting for Transformed Medicaid Statistical Information System (TMSIS), Medicaid and Children’s Health Insurance Program (CHIP) Eligibility Processing (EP) data, and Medicaid and CHIP Performance Indicator (PI) data based on the PRA listing. Comments on both the work reporting requirements IFR and the corresponding PRA listing are being accepted through July 31, 2026 (see this CMS webpage for more information) . | Data Source | Overview of PRA Materials | Implications for States | | --- | --- | --- | | Transformed | • CMS is establishing new monthly T-MSIS reporting requirements that states will need to collect when | • States must design, build, and | | Medicaid | determining eligibility, intended to show: | test system changes that will | | Statistical | o How Medicaid expansion adults (and applicable section 1115 demonstration participants) | ingest enrollment data from the | | Information | qualify for Medicaid and in which enrollment categories. | Medicaid Enterprise System | | System | o Reasons enrollees are disenrolled from Medicaid. | (MES) and update the T-MSIS ﬁle | |
(T-MSIS) | o Disenrollments related to work reporting requirements eligibility veriﬁcations.
o Individuals enrolled in an applicable section 1115 demonstration. | submission format to incorporate the new data. | 1 Relevant PRA listing zip ﬁles are as follows: CMS-R-284 for T-MSIS Data, CMS-10434 \#66 for Eligibility Processing Data, and CMS-10398 \#35 for Performance Indicator Data. | Data Source | Overview of PRA Materials | Implications for States | | --- | --- | --- | | | • CMS provides the following T-MSIS materials in the PRA zip ﬁle:
o Supporting Statement.
o Data Dictionary Crosswalk.
o Data Dictionary.
o Record Segment Deﬁnitions and Relationships.
o Valid Value Lists Crosswalk.
o Valid Value Lists.
• CMS indicates it will release T-MSIS reporting guidance, including new segment speciﬁcations and data elements, in advance of January 1, 2027. | • States will need to review the TMSIS PRA zip ﬁle for further instruction as well as any forthcoming guidance from CMS. | | Eligibility Processing (EP) | • CMS is adding ﬁve new renewal data metrics that states will need to report monthly:
o Metric 9 : “Of the beneﬁciaries included in metric 5(a), the number renewed who are determined to be a speciﬁed excluded individual.”
o Metric 10 : “Of the beneﬁciaries included in metric 5(a), the number renewed who are applicable individuals and either demonstrated community engagement or were deemed to have demonstrated community engagement by meeting a mandatory exception.”
o Metric 11 : “Of the beneﬁciaries included in metric 5(a), the number renewed who are applicable individuals and were deemed to have demonstrated community engagement by meeting a short-term hardship exception.”
o Metric 12 : “Of the beneﬁciaries included in metric 5(b), the number determined ineligible due to not meeting the com

FAQs

When do states need to begin submitting work reporting data to CMS under the interim final rule?

Data submission is required effective January 1, 2027, with the rule requiring states to submit data to CMS following CMS’s interim final rule framework.

Which CMS reporting systems are covered by the PRA-driven changes summarized in the toolkit?

The toolkit covers Transformed Medicaid Statistical Information System (T-MSIS), Medicaid and Children’s Health Insurance Program (CHIP) Eligibility Processing (EP) data, and Medicaid and CHIP Performance Indicator (PI) data.

What major system and process updates are expected for states?

States must design, build, and test system changes to ingest enrollment and eligibility data, update the T-MSIS file submission format, and adjust EP and PI reporting processes to pull and report newly required data elements and metrics.

Sep 12, 2026

Upload by Sage