H.R.1, verification, and Mirza, in plain language.

Beginning January 1, 2027, certain Medicaid adults ages 19–64 must complete at least 80 hours per month of qualifying work, education, training, or volunteer activity as a condition of eligibility, unless they qualify for an exemption. States must determine who is subject, verify compliance from available data, run outreach and cure workflows for people at risk, and keep auditable records of every determination.

CMS-2454-IFC is the interim final rule implementing H.R.1's community engagement requirement: Medicaid Program; Community Engagement Requirement for Certain Individuals, published in the Federal Register on June 3, 2026. The regulation takes effect July 31, 2026, and states must apply the requirement beginning January 1, 2027.

Ex parte verification means confirming eligibility from reliable data the state or plan already holds (payroll records, income data, prior determinations) before asking a person to submit paperwork. Federal rules direct states to attempt it first. Mirza makes ex parte the default order of operations: check the data, apply exemption logic, and only then ask a member for a document.

Statutory exemptions include medically frail individuals, pregnant and postpartum women, certain caregivers, Tribal members, veterans with a total disability rating, and people already meeting SNAP or TANF work requirements. The hard part is identifying exempt members from available data before a disenrollment notice goes out, which is a core Mirza capability.

No. Mirza layers on top of the eligibility systems, plan workflows, and integrator-led programs you already run, adding the verification, exception, and compliance-record layer. Output is delivered as structured, audit-ready records to your system of record by API, file, or export.

A standard deployment takes about eight weeks, depending on data agreements and integration scope, layered on the systems you already run with no rip-and-replace.

Mirza spend is structured to be classifiable as QIA spend under federal MLR rules, tied to documented quality outcomes with a member-level audit trail. We provide quarterly HEDIS-mapped reports and an annual MLR QIA filing support package so your actuarial team can confirm classification before contract.