Policy & Practice | Fall 2026

at the center of every determination. Queues are already over capacity, and policy changes ahead will only add to the load. What CBV removes is the friction around the determination. The pending cases waiting on a missing pay stub, the unanswered employer calls, and the document scramble before a federal deadline. Removing that friction does not shrink the work force. It returns caseworker time to the work only they can do, supporting the families in front of them. In modeled scenarios, that shift returns roughly 500,000 caseworker hours to higher-value work and produces $11 million in direct verifica tion savings annually, with error rate reduction adding as much as $115 million more. This is operating today in state benefits programs. The Opportunity in Front of Us State leaders do not have to start from scratch when evaluating this category. 17A’s Consent-Based Verification: A Buying Guide for State Medicaid and SNAP Programs 1 lays out the questions worth pressing on. Which payroll providers, gig platforms,

and financial institutions does the vendor cover today? What share of applicants offered CBV consent and complete it? Is client data auto populated into existing state systems, or does staff still re-key it? And what paper trail does the tool leave behind for audits and case notes? The directors I talk to are not looking for transformation as a concept. They want five minutes back in their day, a determination that holds up at audit, and a verification process that does not put their state on the wrong side of the new federal cost-share rules. That is what is now available and proven. 2 The question is no longer whether this category deserves serious consider ation. It is how agencies evaluate it responsibly, implement it thoughtfully, and use it to reduce burden without compromising trust.

consent flows add friction. The objec tion has it backwards. The current model lets states purchase access to applicants’ payroll data on the strength of a general authorization buried in benefits paperwork; the applicant rarely sees what was shared, with whom, or for how long. CBV replaces that with explicit, time-bound, revocable consent. WhatThis Looks Like at Scale For a hypothetical state running 3 million Medicaid and SNAP verifica tions a year, legacy methods match about 31 percent of inquiries. The remaining 2.1 million cases fall to manual review, consuming roughly 700,000 caseworker hours and $16 million annually. A waterfall that starts with CBV looks different. About 55 percent of applicants verify directly from the source in seconds. Another 20 to 25 percent resolve through optical character recognition (OCR)–based document upload. Only the residual cases fall to manual casework. None of this replaces eligibility caseworkers. Their judgment, empathy, and program expertise sit

Justin Stolzenberg is the Vice President at Argyle.

Reference Notes 1. https://drive.google.com/file/d/10YB GbyZN8A3dSnn1rFlksZsebgtQCq2T/ view?usp=sharing 2. https://www.argyle.com/blog/states-are moving-to-cbv-choose-a-partner-thats-proven

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Fall 2026 Policy & Practice