Executive Summary
The June 2026 work requirements IFR created many new implementation considerations for states. In this guide, the Benefits Tech Advocacy Hub (a joint effort of NHeLP, TechTonic Justice, and Upturn) builds on our January 2026 technical guide in response to the IFR, describing technical implementation considerations for automating verification of compliance and exclusion/exception status (including a list of potential data sources), as well as ways to increase transparency, effectively monitor systems, and navigate vendor issues. We also point out potential technical design issues and limitations of automation that could impact eligibility or continuity of coverage.
