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May 5, 2026executiveMedicaid work requirementsstate plan amendmentsOBBBAexecutive

Iowa and Montana file state plan amendments to implement Medicaid work requirements by July and December 2026

Iowa and Montana file state plan amendments with CMS in early May 2026 to implement Medicaid work requirements before the federal January 2027 deadline, following Nebraska's lead. Iowa proposes a July 1, 2026 start date with a 100-hour monthly requirement, phased in six months after certification. Montana proposes a December 1, 2026 start date with an 80-hour monthly requirement, with additional exemptions. South Carolina files an application conditioning expanded Medicaid for parents and caretakers on 80 hours of monthly work activity. The three filings signal that Nebraska's early implementation is the beginning of a wave, and that CMS guidance — expected in June 2026 — will define the boundaries for dozens of other states required to act by 2027.