Approximately 10 percent of the 18.5 million expansion adults facing work requirements lack high school diplomas or equivalents. Millions more have limited English proficiency restricting employment options to positions where language barriers can be accommodated. These foundational gaps are not compliance barriers alone; they are employment barriers that work requirements cannot address. Without basic literacy, numeracy, English fluency, or high school credentials, traditional employment remains inaccessible regardless of motivation or effort. GED preparation, ESL programs, and adult basic education represent essential infrastructure for enabling compliance among populations facing the steepest challenges, yet these programs operate with the least institutional infrastructure, the most fragmented delivery systems, and the greatest reliance on volunteer instructors.
Adult basic education operates through remarkably fragmented infrastructure. Community colleges offer GED preparation and ESL courses. Adult education centers operate independently or within school districts. Community organizations provide literacy programming. Faith institutions host ESL classes. Libraries offer tutoring. Workforce development programs include basic skills components. No single system tracks participation across this landscape. Someone attending GED classes at a community college, ESL sessions at a church, and literacy tutoring at a library might accumulate significant educational hours across three providers, none of whom communicate with each other or with Medicaid verification systems. The Adult Education and Family Literacy Act provides federal funding creating some coordination infrastructure, but AEFLA-funded programs represent only a portion of adult basic education provision. Programs operating outside this funding stream share no common reporting requirements or data systems.
Hour-counting introduces complexity that structured higher education avoids. Formal GED classroom instruction generates attendance records, but much GED preparation occurs through self-study, online coursework, and tutoring sessions lacking structured documentation. ESL programs face similar challenges as language learning increasingly occurs through apps, conversation circles, and informal immersion. The boundary between formal education and self-improvement becomes fuzzy in ways that verification systems struggle to accommodate. States should consider program-based rather than hour-based verification for foundational education, where enrollment in a recognized program counts as qualifying activity regardless of specific hours, similar to how full-time college enrollment satisfies requirements without tracking individual study hours.
The pathway function of foundational education has policy implications. GED preparation and ESL programs are not ends in themselves but gateways to further education or employment. Someone completing GED requirements achieves access to opportunities requiring high school completion. Someone developing English fluency gains capacity for employment that limited English previously precluded. The equity argument favors counting foundational education at parity with higher education, recognizing that participants are doing what they can from where they are. The accountability argument favors differential treatment, noting that GED preparation can continue indefinitely without completion. Time limits on foundational education credit or requirements for demonstrated progress could address this concern while maintaining access.
Limited English proficiency creates particularly complex dynamics. Immigrants and refugees with strong professional skills in their origin countries find themselves limited to positions where English fluency is not required. A former accountant works in a warehouse. A trained nurse provides home care. ESL programs offer pathways to employment matching actual capabilities, but progress takes time that work requirements may not accommodate. For immigrants without legal permanent resident status, public charge concerns may deter Medicaid enrollment regardless of eligibility, creating an additional barrier beyond language itself. States with large immigrant populations must design ESL provisions that account for both linguistic and administrative barriers.
Digital literacy emerges as a foundational skill prerequisite to both employment and compliance. Work requirement verification increasingly requires navigating online portals, electronic communications, and digital job searches. Expansion adults lacking digital literacy face compliance barriers regardless of work activity because they cannot navigate systems documenting that activity. Integration of digital literacy with GED and ESL programs makes both pedagogical and practical sense.
The bottom line is that states designing work requirement policies must view foundational education as essential compliance infrastructure. Counting GED preparation, ESL programs, and adult basic education as qualifying activities recognizes that participants are building the foundations that make traditional employment possible. Excluding foundational education effectively penalizes expansion adults for barriers they did not create while doing nothing to address those barriers. The choice is between policies that enable progress from wherever people start and policies that assume starting points not everyone shares.