Montana Medicaid Work Rules Are in Effect. What Enrollees Need to Do Before October

Montana began implementing a new community-engagement requirement for certain Medicaid Expansion adults on July 1, 2026. The state is reviewing compliance during July, August and September, but the Montana Department of Public Health and Human Services says it will not deny coverage or disenroll someone solely for failing to meet the new requirement during that hold-harmless period.

Beginning in October, noncompliance may lead to denial of coverage or disenrollment after DPHHS reviews the case and sends an official notice. The requirement is based on federal changes in H.R. 1, which DPHHS identifies as the source of the new Medicaid Expansion rules. It does not apply to every Montana Medicaid enrollee.

Who must meet the 80-hour requirement

The requirement generally applies to non-excluded adults ages 19 through 64 enrolled through Montana Medicaid Expansion. Those enrollees must complete at least 80 hours each month of approved activities unless they qualify for a specified exclusion or a documented short-term hardship.

Qualifying activities include paid employment, community service or volunteering with a nonprofit organization, approved state or federal workforce training or job-readiness programs, and school. Activities may be combined, such as 60 hours of work and 20 hours of volunteer service, according to Montana DPHHS guidance.

For new applicants, DPHHS says the requirement applies to Medicaid Expansion applications filed on or after July 1. Existing enrollees generally first demonstrate compliance at their next scheduled redetermination. DPHHS says cases with an August 31, 2026, redetermination date are the first existing cases expected to be reviewed under the new requirement.

July through September is a hold-harmless period

During July, August and September 2026, DPHHS is reviewing compliance with the community-engagement requirement. The department says applicants and existing members will not be denied coverage or disenrolled solely for noncompliance during those months if they meet all other eligibility conditions.

That protection ends in October. The DPHHS Medicaid Changes FAQ says noncompliance will then be enforced through denial and disenrollment. The action is not described as automatic: DPHHS will review applications and redeterminations, and an adverse decision should be communicated through a Notice of Adverse Action.

The hold-harmless period also gives DPHHS time to evaluate its systems and processing procedures. Montana Public Radio and Montana Free Press have reported concerns from providers, advocates and lawmakers about implementation readiness and how exemptions will be identified and processed. Those reports describe concerns about the rollout, not an established statewide system failure.

Specified exclusions are different from short-term hardships

Montana distinguishes between specified exclusions, which remove the requirement when a person meets the applicable criteria, and exceptions or short-term hardships, which count only for the months they are documented.

DPHHS lists specified exclusions for American Indian and Alaska Native people; children ages 18 or younger; certain former foster youth under age 26; people incarcerated in a public institution; people with a medical condition or health needs that affect their ability to work or perform other qualifying activities; parents, guardians, caretaker relatives or family caregivers of a dependent child under age 14 or a disabled person; people in qualifying drug or alcohol treatment programs; people who meet TANF work requirements or are subject to SNAP work requirements; pregnant or postpartum women for up to 12 months; and veterans with a total, 100% disability rating.

A medical diagnosis alone does not automatically establish an exclusion. DPHHS’s medically frail framework covers specified categories of conditions that significantly impair a person’s ability to comply, and the department accepts provider documentation or an allowed self-declaration process. DPHHS says it expects additional guidance and clarification from the Centers for Medicare and Medicaid Services and may update its approach.

Short-term hardships may include inpatient care, living in a county covered by an emergency disaster declaration, or travel outside the community by the enrollee or a dependent for serious or complex medical care. Montana says it is not implementing the high-unemployment exception at this time. The FAQ also lists Medicare eligibility and recent incarceration among exceptions that may satisfy the requirement for applicable months.

At application, DPHHS generally looks at the month before the application. At redetermination, the agency generally looks at at least three months since the prior redetermination, and the months do not have to be consecutive. If an exception or hardship applies for only one or two months, the enrollee generally must document qualifying activity for the remaining months.

What documentation to keep

DPHHS says enrollees should retain records that match the activity or exclusion they report. Examples include pay stubs, school schedules or transcripts, signed volunteer logs, workforce-training forms, provider records, facility documentation, veteran records and program records.

The department’s Verification Matrix lists documentation for different categories. For example, employment may be reported through the Medicaid community-engagement reporting form with supporting verification such as pay stubs; community service may require a signed service or verification form; workforce training may require a Labor and Industry participation form; and education may require a school schedule or transcript.

Some self-declarations are accepted only in specified circumstances. DPHHS says information submitted through self-declaration may later be checked through available data or other verification methods.

What Montana enrollees should do now

• Confirm whether your coverage is through Medicaid Expansion and whether you are ages 19 through 64.
• Review whether a specified exclusion or short-term hardship applies to you.
• If no exclusion applies, track 80 hours of qualifying activity for each month and save supporting records.
• Report medical conditions, caregiving responsibilities and other possible exclusions through the process described by DPHHS.
• Keep your mailing address, phone number and email current in the Medicaid Self-Service Portal.
• Read every DPHHS notice carefully.
• If DPHHS takes an adverse action, follow the appeal instructions in the Notice of Adverse Action and meet the deadline stated in that notice.

The July-through-September hold-harmless period provides time to organize records and report exclusions. It does not eliminate the need to prepare for possible enforcement beginning in October 2026.

Sources

• Montana DPHHS, Changes to Medicaid
• Montana DPHHS, Medicaid Changes FAQ
• Montana Public Radio, Groups take to the state Capitol to rally against Medicaid rule changes

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