Policy & Practice | Fall 2026

By Justin Stolzenberg from our partners

Permission, Not Paperwork: Rewiring Eligibility Verification for the People Human Services Serves

T he job of an eligibility caseworker has not changed much in recent years. A household applies. The case worker has 30 days, or 7 for expedited cases, to verify income, employment, household composition and, some times, assets. Most states have moved past paper-only methods and lean on the dominant employer database. But it isn’t comprehensive. Part-time work, gig income, and self-employment fall outside its scope, and the data it does return can be weeks out of date. Out come the pay stubs, the employer verification forms, the bank state ments, or requests for them. The result entails high verification costs, deci sions made on incomplete information, and a workload that still falls back on manual paperwork. This process supports tens of millions of households and hundreds of billions in benefits. It was built for a workforce that no longer exists. More than 60 million Americans now do some form of independent work each year, according to MBO Partners, piecing together income from W-2 jobs, gig platforms, side busi nesses, and seasonal work. Household finances have multiplied too, spread across banks, neobanks, prepaid cards, and peer-to-peer wallets. The eligibility systems behind the Supplemental Nutrition Assistance Program (SNAP), Medicaid, Temporary Assistance for Needy Families (TANF), child care subsidies, the Low-Income A WorkforceThat Has Changed Faster Than Our Systems

Home Energy Assistance Program (LIHEAP), Supplemental Security Income (SSI), and dozens of state programs were not designed for house holds juggling multiple employers, irregular hours, gig platforms, and fragmented accounts. The mismatch shows up everywhere — in procedural denials, in tens of billions of dollars in improper payments flagged by the U.S. Government Accountability Office each year and, most painfully, in the Medicaid unwinding, where roughly two-thirds of disenrollments were pro cedural rather than substantive. Under H.R. 1, states with elevated SNAP payment error rates face direct cost-share exposure beginning in fiscal year 2028. Modernizing verifica tion has shifted from an operational priority to a fiscal one. From Inquiry to Permission For decades, eligibility verifica tion has been inquiry based. Agencies

ask, then piece together answers from employer outreach, third-party databases, and applicant-submitted documents. The applicant’s role is to produce paperwork. Consent-based verification (CBV) reverses that. The applicant grants explicit, time-bound consent for an agency to receive their income, employment, and asset data directly from the source. The data are current, structured, and certified by the applicant. Data quality improves when agencies see the full structure of someone’s earnings, not a static snapshot. Coverage improves when modern direct-source connectivity reaches roughly 96 percent of the U.S. work force, including 25+ gig platforms and thousands of financial institutions. The legacy employment database returns a match for only about a third of inqui ries. And the applicant moves back to the center. A common objection is that

Illustration by Chris Campbell

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Policy & Practice Fall 2026