c. Verifying Participation in a Work Program

In addition, as specified in section 1902(xx)(2)(C) of the Act, an applicable individual may demonstrate community engagement for a month by participating in a work program for at least 80 hours in such month, which we implement at § 435.552(a)(3). The definition of work program as defined at § 435.552(b) includes different types of work programs, as discussed in section II.C.3. of this IFC; thus, the specific qualifying work programs available to applicable individuals will vary by State. Because of this variance, we believe States are best positioned to identify available sources of reliable information about work program participation. However, we note that section 1902(xx)(9)(D) specifies that “work program” has the same meaning given to such term in section 6(o)(1) of the Food and Nutrition Act of 2008 and therefore aligns with SNAP work program requirements. We encourage State Medicaid agencies to consult the SNAP program in their State to identify any data sources SNAP relies on to verify participation in a work program and leverage those data sources where possible. For instances in which the State is unable to verify 80 hours of participation in a work program using reliable information available to the State, the State must seek information from the individual to verify hours that the individual participated in a work program. Beginning on January 1, 2028, if States are unable to verify 80 hours of participation in a work program using reliable information available to the State, States must require documentation when such documentation is reasonably available and must establish a process to accept other information when documentation is not reasonably available, as described in section II.I.3. of this IFC. States must also ensure the procedures implemented to verify work program participation hours produce an auditable record supporting the State's eligibility determination.