Resource for Practitioners: Cost of H.R.1 Implementation Framework Worksheet
Nationwide
June 2026 - September 2026
Why This Matters for Families
The "One Big Beautiful Bill Act" (H.R. 1) signed into law during the Summer of 2025 makes significant changes to the administration of two of the nation's largest safety net programs. New work reporting requirements, more stringent eligibility processes, and changes to state financing structures have already taken effect in the Supplemental Nutrition Assistance Program (SNAP) and will begin for Medicaid in most states in 2027. These changes are directly impacting the work of program administrators, driving up costs in state budgets, and ultimately, putting pressure on the millions of families who rely on these programs. Since the bill’s passage, more than 5 million people have already lost SNAP, including an estimated 1.5 million children, more than double the Congressional Budget Office’s projections. Medicaid changes are expected to have similar impacts as households face processing delays, increased administrative burden, and changing eligibility parameters that may cause them to lose benefits even as they remain in need of assistance.
Implementation Challenge
The H.R. 1 requirements are driving new or expanded operational line items, procurements, and funding shifts in administrative costs at the state and federal levels. Despite the scale of these changes, there is no established, cross-state replicable framework for quantifying H.R. 1’s administrative cost implications or assessing whether those costs yield commensurate benefits to program efficiency or effectiveness.
The lack of reliable data around the cost to administer the safety net, in terms of both real dollars and state workforce burden (such as having to set other priorities aside, reallocate employees, or retrain contact center staff), leaves policy makers and program administrators with limited tools to understand the costs of adding complexity and the implications for program performance and outcomes. Grounding these debates in the cost and effectiveness of the current system, including differences across states, would create more opportunity for practical, outcome-driven problem-solving.
Past experience with work-requirement demonstrations under Medicaid in Arkansas and Georgia showed that the administrative cost and burden can be tens of millions of dollars - including to simply make beneficiaries aware of changes and needed action. The Government Accountability Office (GAO) found that these incremental administrative costs had very poor tracking and got little compliance attention. While the Centers for Medicare & Medicaid Services (CMS) will require states to submit additional eligibility and enrollment data as part of its Community Engagement Interim Final Rule, the required reports do not include administrative cost data.
Our Approach
The New Practice Lab (NPL) built on prior research into the cost of safety net administration by embarking on a five-month discovery sprint to build a framework that could help to structure costs at the state level of implementing H.R. 1.
Through a combination of desk research, expert interviews, state consultations, and independent analysis, we built a pilot measurement framework worksheet for states to capture the cost of the changes to SNAP and Medicaid in real-time, and anchor metrics of program success, including access, integrity, and efficiency, as well as longer-term impacts such for children and families.
OBJECTIVES
Examine the landscape of available administrative cost categories and potential data sources for both explicit (budget line) and difficult to capture “hidden” costs, such as reallocated staff, open-source software deployment, and “free” support from the civic tech community.
Build a measurement framework worksheet that could help states log and capture costs of H.R.1 implementation impacts for national and state legislators, senior state leaders, and peer learning.
Develop one state case study to capture cost in a way other states could react to and potentially replicate
WHAT WE DID
Reviewed historical administrative cost data from prior major program changes.
Conducted expert interviews with current and former state Medicaid and SNAP directors and agency heads, technology and implementation leads, federal budget analysts, academic and think tank researchers, and advocates across the political spectrum.
Built a framework with core, budgetary, beneficiary, operations, and outcome metrics.
Pressure-tested and refined the framework based on conversations with state HHS leaders.
What We Learned
States are working tirelessly to implement H.R. 1 requirements so they can avoid penalties written into the law and maintain sufficient funding to operate these critical safety net programs. As H.R.1 shifts administrative and benefit costs toward states, tools like this framework worksheet can help states navigate budget uncertainty by illuminating the full costs of implementation and spurring discussions with peer states about lessons learned and best practices.
A few of our takeaways from using this worksheet with states:
Most data needed to complete the framework are not publicly available. States will need to coordinate internally and dedicate staff time and resources to collecting and compiling their own data.
State-to-state differences in how contracts are written, budget lines are structured, and functions are staffed may make it challenging to identify specific costs and to compare spending and performance across states.
It is difficult to capture the full breadth of costs as those beyond direct state expenditures (“hidden costs”), such as in-kind civic tech support, can be difficult to quantify from a state perspective.
Even in the midst of these major changes and increased workload, states are eager to invest in capturing and better understanding their own data, learning more about their performance as compared to their peers, and digging into ways to leverage cross-state best practices.
At the same time, states are reluctant to be subject to comparisons that may gloss over important differences and that focus on rating or ranking states without tangible support for improvement.
There may also be tension within states as data reporting functions are spread among departments, each with their own internal data calls and program reports. States already track and report many of these metrics in other ways so getting buy-in to use an aggregate template, and even finding an owner to do that, will be contingent on clearly making the case for how it would provide direct and timely benefit to state leaders. A central office (a budget department, Governor’s office, or empowered Health and Human Services leader) may need to be the owner.
We welcome outreach from states interested in learning more about the framework or offering suggestions for how to make it more tailored to their needs.
