Turning Policy into Practice: What We’re Learning from our Local Demonstration Sites

December 22, 2025

Across Lutheran Services in America, we often talk about the need to bridge policy and practice. The Results Innovation Lab (RIL), in partnership with the Strengthening Families Initiative (SFI), is doing exactly that by turning national policy priorities into real-world learning through local demonstration sites.

At a time when Medicaid policy, child welfare systems, and community-based organizations are all under pressure, these sites are helping us answer a critical question: What does prevention actually look like on the ground—and what does it take to make it work?

Our demonstration sites are showing that prevention is not a single program or service, but a way of working across systems. It shows up in addressing basic needs early, coordinating care more effectively, and reducing the likelihood of crisis before families reach child welfare or emergency systems. Making prevention work requires strong cross-sector collaboration, clear shared populations, and the ability to test small changes, learn quickly, and adapt.

From Policy Signals to Practice Experiments

RIL’s focus on outcomes, equity, and leadership development is now directly shaping how we design and support local demonstration sites alongside health care. Rather than starting with abstract policy ideas or top-down models, we are using small, practical tests of change to learn what collaboration actually looks like on the ground, under real-world conditions.

This approach allows us to:

  • Focus on clear outcomes at the intersection of Medicaid and child welfare
  • Build cross-sector “muscle memory” for collaboration
  • Document prevention strategies that align with federal priorities and are feasible for overburdened local systems

This matters in the current policy environment. The White House’s 2025 Executive Order emphasizes family stability, timeliness, upstream investment, and cross-system coordination. Through RIL and SFI, Lutheran Services in America is effectively operating a living lab for what that policy vision looks like in practice.

What We’re Learning from the Demonstration Sites

In Pennsylvania and Virginia, the demonstration sites are surfacing several consistent lessons with clear policy implications.

Identifying shared populations is harder than expected—but essential.
Even when organizations serve the same families, health plans, schools, and child welfare systems often define populations differently. The work of aligning around a shared group of children or families takes time, trust, and data—but it is foundational to any meaningful partnership.

Small tests of change are the right scale for this moment.
Rather than launching large pilots, sites are using Plan-Do-Study-Act (PDSA) cycles to test ideas quickly. These small tests help partners stay engaged, surface barriers early, reduce risk, and generate evidence that can inform future investment. This is exactly the kind of learning federal and state leaders look for when identifying promising prevention approaches.

Basic needs are the gateway to deeper engagement.
Across sites, food access, transportation, hygiene supplies, and mental health supports consistently emerge as high-impact entry points. Addressing these needs improves appointment attendance, engagement in services, and trust with families—outcomes that matter to both child welfare and Medicaid systems.

Workforce capacity matters as much as program design.
Burnout and turnover can undermine even the strongest ideas. RIL’s emphasis on resilience, listening, and curiosity is helping organizations adapt while protecting staff capacity, an often overlooked but critical component of prevention.

Why Medicaid Matters for Children, Youth, and Families

Medicaid has become one of the largest funders of prevention. Families interact with health systems far more frequently than they do with formal child welfare systems, making Medicaid a powerful lever for upstream support.

Our demonstration work with UnitedHealthcare highlights several truths:

  • Many organizations involved in children, youth and family work already do Medicaid-relevant work, even if they do not bill Medicaid directly
  • Prevention lives in the gaps between health care, social care, and child welfare systems
  • Managed care organizations are still expected to address social needs and improve outcomes, even amid federal policy shifts

Lutheran Services in America members are uniquely positioned to bridge these gaps by stabilizing families, improving care coordination, reducing avoidable involvement, and delivering trusted, community-rooted support. In many ways, this is exactly what policymakers are asking systems to do. The demonstration sites are helping show the “how.”

Building Toward Scale and Sustainability

The learning from these sites is already shaping how Lutheran Services in America will strengthen practice across the network. Key areas of focus include:

  • Organizational readiness for Medicaid-aligned partnerships
  • Clearer demonstration of value through outcomes and data
  • Stronger cross-sector relationships with health plans and states
  • Meaningful integration of lived experience leadership
  • Framing prevention in terms of cost containment and avoided crises

Together, this work helps Lutheran Services in America members meet the current policy moment while staying rooted in mission. By grounding policy aspirations in practical learning, the demonstration sites are not just testing ideas, they are helping build a roadmap for prevention that can scale.

Renada Johnson is Senior Director of Children, Youth & Family Initiatives at Lutheran Services in America.

CMS Issues Initial Guidance on Medicaid Work Requirements

December 11, 2025

On December 8, the Centers for Medicare and Medicaid Services (CMS) issued initial, new guidance to states to inform implementation of the new Medicaid community engagement provisions (aka: work reporting requirements) included in H.R. 1.  The new law includes multiple sweeping changes to the Medicaid program, with more guidance expected to follow.  In issuing this initial guidance, CMS officials outlined four principles guiding policy development:  

  1. connect members to work and community;
  2. offer states flexibility;
  3. promote alignment with existing requirements for other programs such as SNAP and TANF; and
  4. protect taxpayers. 

CMS reiterates the statutory deadline of January 1, 2027, for states to implement the new community engagement requirements, while outlining a process for the Secretary to grant temporary compliance exemptions ending on December 31, 2028 or before to states experiencing hardships but demonstrating good faith efforts to comply.  The agency will also issue grants to help states establish new or updated systems to comply with the new requirements.   

What’s New?

While the guidance focuses primarily on restating in plain language the requirements from H.R. 1 across key areas of focus, as enumerated below, there are a few new pieces of operational direction as noted.  For example, CMS has offered new interpretations related to compliance verification, potential sources of “reliable information” for those verifications, and the role of managed care organizations (MCOs).  Deeper analysis is also available from our partners in the Modern Medicaid Alliance.   

Applicable individuals: 

  • Only individuals who are 1) aged 19-64, not pregnant, not eligible for or enrolled in Medicare, and not eligible for Medicaid via other mandatory group; or 2) eligible to enroll in Medicaid under a waiver and who meet the first set of criteria.  
  • NEW in this guidance: CMS clarifies that the requirements will NOT apply to states that 1) have not expanded Medicaid AND 2) do not have a 1115 waiver offering minimum essential coverage (MEC); and 
  • Looking ahead: CMS notes that it will continue to evaluate which existing state section 1115 demonstration populations meet the definition of an “applicable individual.” 

Activities which meet the community engagement requirements (per month): 

  • 80 hours of work 
  • 80 hours of community service 
  • 80 hours of work program participation 
  • 40 hours of enrollment in an educational program 
  • A combination of 80 hours in any of the above 
  • A monthly income not less than $580 
  • Seasonal work with average monthly income over the preceding 6 months of not less than $580 

Exclusions to the requirements: 

  • Former foster youth up to age 26 
  • A person who is an Indian (including Urban Indian, California Indians, or individuals otherwise determined eligible as Indians for the Indian Health Service) 
  • A parent, guardian, or caretaker relative of a disabled individual or dependent child under the age of 13 
  • A veteran with a total disability rating 
  • A person who is medically frail or otherwise has special medical needs 
  • A person who is complying with any requirements under the SNAP program or who is a member of a household that receives SNAP and is not exempt from work requirements 
  • Participants in drug addiction or alcoholism treatment and rehabilitation programs 
  • Inmates of public institutions 
  • Individuals who are pregnant or entitled to postpartum medical assistance 
  • NOTABLE in this guidance: CMS opted NOT to include the definition of “medical frailty” as described in the legislation in this initial guidance.  

Exceptions to the requirements for individuals experiencing short-term hardships including: 

  • Receiving various types of inpatient services 
  • Residing in a county in a state of emergency or disaster or in a state with a high level of unemployment 
  • Having to travel for an extended period to receive medical services unavailable at home 

Demonstrating and verifying compliance:  

  • New applicants must demonstrate compliance for one or more (not more than three) consecutive months immediately preceding the month of application 
  • Current enrollees must demonstrate compliance for at least one or more months during the period between the previous eligibility determination and the next redetermination 
  • NEW in this guidance: 
    • Beneficiaries are considered compliant if they demonstrate compliance during any part of the eligibility period, and states may not require compliance in specific or consecutive months. 
    • States must conduct redeterminations every six months for expansion populations. 

Use of reliable information:  

  • States are required to establish a process and first attempt to use reliable information available to them without requiring an individual to submit additional information to verify compliance 
  • NEW in this guidance 
    • CMS expands on potential sources of such reliable data 
    • The agency adds that states may not request additional information or documentation from individuals unless they are unable to establish compliance using reliable data.  

Non-compliance procedures when states cannot verify compliance: 

  • States must issue a notice of noncompliance and provide 30 calendar days to demonstrate compliance or qualification for exemption or exception. 
  • For current enrollees, states must continue to provide coverage during this 30-day period. 
  • In all cases, if compliance is not demonstrated, the state must deny coverage or disenroll the individual at the end of the month following the month in which the 30-day period ends. 

Outreach: 

  • States must notify beneficiaries about the requirements before they are implemented and periodically thereafter. 
  • States have a set period to begin outreach, and the outreach must be sent by mail and at least one additional method. 

Role of Managed Care Plans (MCOs):  

  • NEW in this guidance: states cannot permit MCOs to decide whether beneficiaries are compliant, but MCOs may perform supportive tasks.

What’s the Takeaway? 

CMS is expected to issue additional guidance, particularly with more detailed instructions for state operationalization.  H.R. 1 requires CMS to issue an interim final rule by June 1, 2026, though it is not yet clear whether outstanding questions will be addressed through that final rulemaking or through further subregulatory guidance beforehand. We will share more information as it becomes available.

Sarah Dobson is Senior Director of Advocacy and Public Policy at Lutheran Services in America.

Lutheran Services in America Partners with RRF Foundation for Aging to Elevate Rural Family Caregiver Voices

November 20, 2025

Fellowship Square Hosts National Housing Solutions Collaborative with Lutheran Services of America

November 20, 2025

How to Cultivate Rural Aging Partnerships through Whole-Community Mobilization

November 13, 2025

At the Grantmakers in Aging Annual Conference, Regan McManus, director of aging initiatives at Lutheran Services in America, presented “How to Cultivate Rural Aging Partnerships through Whole-Community Mobilization.”

In her session, Regan demonstrated the power of the Rural Aging Action Network (RAAN), an approach that looks beyond traditional aging partners and taps into the unique strengths already present in rural communities. By elevating lived experience, prioritizing cultural relevance, and activating local assets — from faith communities and schools to grocery stores and farmers unions — RAAN communities in Minnesota, Montana, North Dakota, and South Dakota are tackling social determinants of health, closing gaps in care, and advancing equity and belonging for older adults. RAAN taps into the unique strengths already present in rural communities, connecting residents, organizations, and local leaders to help older adults maintain their autonomy and independence.

For more than a century, Lutheran social ministries have been trusted in America’s rural communities. That tradition continues as our network equips local leaders with innovative, community-informed solutions that build on local assets and strengthen social connection.

At the GIA conference, Regan highlighted how RAAN amplifies practical solutions that demonstrate what works, why it matters, and for whom. This shared learning strengthens community partnerships and provides funders and decision-makers with clear examples of scalable approaches that deliver real impact.

As America’s population ages, and one in four older adults continues to call a rural community home, the lessons from RAAN demonstrate that the most effective solutions start within the community itself. Through whole-community mobilization, we’re charting a path toward better health and belonging for older adults in rural America.

TOGETHER,

we make life better for children, youth, and families today—and for generations to come.

Our shared Lutheran tradition of service to our neighbor is more vital than ever.

Join us as we work to ensure our network continues delivering essential services to all in need.