12 States Are Already Solving the Benefits Cliff. Is Yours One of Them?
By Scott C. Miller
For years, the benefits cliff has been the problem everyone acknowledged and no one legislated. That changed on January 6, 2026, when Senator Jon Husted introduced the Upward Mobility Act—a bipartisan-framed bill that would create a five-year pilot allowing states to combine funding from 10 federal anti-poverty programs into a single stream and design graduated benefit phase-outs. Meanwhile, 12 states are already running their own cliff mitigation pilots. The policy landscape is moving. The question is whether your organization is ready to operate in it.
What the Upward Mobility Act Would Do
The bill would let five pilot states combine funding from SNAP, TANF, Section 8, Rural Rental Assistance, Public Housing, the Child Care Development Fund, LIHEAP, CDBG, and WIOA Dislocated Workers into a single flexible funding stream with graduated benefit reductions. Congressman Blake Moore introduced companion legislation in the House. The Alliance for Opportunity and multiple state-level organizations have endorsed the approach.
This is the first serious federal legislative vehicle for benefits cliff reform with real political momentum. Even if it doesn't pass this session, it establishes the framework that future legislation will build on—and states aren't waiting.
Key Statistic
A parent with two children earning $32,000 can face an effective marginal tax rate exceeding 80%
Meaning an additional dollar earned costs more than 80 cents in lost benefits. — FREOPP analysis of single-parent households
12 States Are Already Moving
Colorado, Connecticut, DC, Maine, Massachusetts, New Hampshire, Ohio, Rhode Island, Tennessee, Utah, Vermont, and Washington are piloting benefits cliff mitigation across Child Care, HUD, LIHEAP, Medicaid/CHIP, SNAP, and TANF. Washington, DC's $17.7 million pilot with roughly 600 families showed employment rates rising from 35% to 41% in early results. Rhode Island's Post-Employment Benefits Program, launching June 2026, will provide $200 per month for up to 12 months for those exiting TANF—a concrete graduated phase-out model.
These pilots are generating real data about what works. If your state isn't one of them, you should be watching what they're learning. If your state is, you should be part of the conversation.
The ACA Cliff Is Back
The enhanced ACA premium subsidies expired on January 1, 2026. Enrollees whose household income exceeds 400% of the Federal Poverty Level by even one dollar now lose all premium tax credits. This isn't a gradual phase-out. It's a cliff—and it affects families at higher income levels who may not realize the cliff applies to them until they file their taxes.
The Metrics Problem
Current WIOA performance metrics incentivize exactly the wrong behavior. Combined with limited funding, workforce boards are encouraged to exit workers from programs once they obtain any job—regardless of wage or sustainability. A workforce board that exits someone into a $12/hour job and calls it a “placement” has hit a metric. But if that placement triggers a benefits cliff that makes the family financially worse off than before, the system has failed.
The Upward Mobility Act's framework essentially requires the kind of coordinated, long-horizon case management that measures trajectory, not just placement. The policy world is catching up to what frontline staff have known for years: you can't measure success at the point of exit. You have to measure it 12 months later.
What This Means for Your Organization
- If your state is selected as an Upward Mobility Act pilot or pursues its own cliff mitigation, can your organization deliver graduated benefit management across 10 programs simultaneously?
- Do your workforce and benefits teams share data, or do clients have to tell their story twice?
- Are you measuring “placement” or “trajectory”? Because the policy landscape is moving toward the latter, and your funding will follow.
- When a funder asks “how do you handle the benefits cliff?”—is your answer a philosophy or a system?
The Path Forward
Benefits cliff legislation is moving at both the state and federal level. Whether the Upward Mobility Act passes this session or not, the direction is clear: graduated, coordinated approaches are replacing the cliff-and-cut model. The organizations that build integrated data systems, modeling tools, and case management workflows for this reality now will be positioned when the policy catches up. The ones still running parallel tracks for workforce and benefits will be scrambling.
The 12 pilot states are proving that cliff mitigation works. The federal bill is establishing the framework. The only question left is organizational: are you building the system, or waiting for someone else to?
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Sources
- Senator Husted, “Upward Mobility Act” Press Release (Jan 2026)
- Congressman Blake Moore, Companion Legislation Press Release (2026)
- APHSA, Benefit Cliff Dashboard—State Pilot Tracker
- benefitscliff.com, DC Pilot Results and RI Post-Employment Benefits Program
- CNBC, “ACA Subsidy Cliff Tax Bills” (Jan 2026)
- FREOPP, “Fixing the Broken Incentives in the U.S. Welfare System” (analysis of single-parent households)
- National Skills Coalition, “Cuts Disguised as Reform”—WIOA performance metric analysis (2026)
- Alliance for Opportunity, “Piloting Change: Upward Mobility in a Reformed Safety Net”
This analysis reflects legislation introduced as of February 2026. The Upward Mobility Act has been introduced but not yet passed. State pilots are at various stages of implementation. Early results cited are preliminary and lack control groups.
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