Montana is preparing to roll out its community engagement rules for Medicaid July 1, and Arkansas is soft-launching its requirements that same day.
HR 1 outlined how low-income, nonpregnant adults ages 19 to 64 must work, perform community service or attend school — or some mix of these — for at least 80 hours per month to retain Medicaid coverage. On June 1, CMS finalized the framework for these rules.
States have until Jan. 1, 2027, to launch these requirements, but some are getting a head start. Nebraska, for instance, kicked off its efforts May 1.
Montana has provided a “verification matrix” to define qualifying activities and what proof is needed to confirm requirements are met. The state also laid out advice for students and those with seasonal employment.
Come July 1, the Arkansas Department of Human Services will start running automated processes to determine exemptions, as well as who is fulfilling or not meeting the requirements. Full implementation will take place in 2027, in line with when other starts must begin. There will not be any penalties for 2026.
Arkansas DHS will reiterate work requirements to beneficiaries by issuing notices and sending emails and texts. The state has already run five town halls to inform the affected populations. The state estimated about 210,000 people are in the targeted Medicaid program.
“The [Arkansas Health and Opportunity for Me] Community Engagement and Work Requirement is a key program that will help our beneficiaries advance their careers and become self-sufficient, and we look forward to a successful implementation,” Arkansas DHS Secretary Janet Mann said.
Arkansas had already been planning a work requirement program in 2025 prior to HR 1. In previous years, Montana had also attempted to implement a work requirement.
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