State Health Department Begins to Prepare Medicaid Patients for New Work Requirements

As Montana nears its July 1 deadline to begin implementing new community engagement requirements for Medicaid expansion enrollees, the state’s Department of Public Health and Human Services (DPHHS) is hosting informational webinars to inform patients of the changes.   

During the first webinar Tuesday afternoon, Jessie Counts, human services executive director for the department, went through a series of slides covering who is affected by the changes, what activities qualify as community engagement, how the requirements will be verified, and next year’s six-month redetermination requirement. A second webinar is scheduled for May 13.

The changes are a part of H.R. 1, also known as the One Big Beautiful Bill Act, which the Trump Administration signed into law last year. Montana legislators have been working to add community engagement standards for Medicaid expansion enrollees for years, with the state passing a Medicaid reform bill that would have implemented them in 2019. However, the federal government at the time rejected the standards, which are more broadly known as work requirements.

Now, state officials are looking to make Montana a “national early adopter” of community engagement requirements from H.R. 1 with an implementation date of July 1, six months before the federally mandated deadline.

The new standards apply to Medicaid expansion enrollees, those individuals between the age of 19 and 64 who make less than 138% of the federal poverty level, which in 2026 is an annual income of $22,025 for a single adult.

Adults must spend at least 80 hours each month in community engagement activities. Qualifying activities include working, community service, volunteering, workforce training, job readiness programs, and going to college or vocational school. Counts said enrollees can use a combination of qualified activities to meet the requirements.

Those excluded from the requirements include Native Americans and Alaska Natives, individuals who are pregnant, parents and caregivers of children under 13 years old, caregivers of those with disabilities, former foster youth, and people who are deemed “medically frail.” Veterans with “total” disabilities, those enrolled in substance use disorder treatment, and those currently incarcerated or recently released are also exempt. Counts said state officials are still in the process of defining “medically frail” as it relates to Medicaid enrollment.

Those with short-term hardship events may also be temporarily excluded, including those receiving inpatient care in a hospital, a nursing facility, a psychiatric hospital, or a similar facility. People who live in a county where there is a federal emergency or disaster declaration, or in a county with an unemployment rate 1.5 times the national rate, which in March was 4.3%, may also be excluded as long as the circumstances persist.

Counts said state officials will verify work requirements and exclusions sometimes via “data matching, sometimes directly.” States are required to use existing data such as state income data, to confirm eligibility. If state officials cannot verify a patient has met the work requirements via existing data, officials will request documentation from patients. Applicable documents include pay stubs, official letters from schools, and signed volunteer logs with hours.

Those who are excluded may be required to provide documentation as well, Counts said. Caretakers of those with disabilities may be required to have the person receiving care complete an attestation form, and Native Americans and Alaska Natives may be required to provide identification.

Rather than reporting each month, enrollees will need to keep track of how they’ve fulfilled the community engagement requirements while they’re covered and provide documents when applying for the first time and at the time of renewal. Seasonal workers may be able to show that they’ve earned an average income that equals the federal minimum wage multiplied by 80 hours for each month over their last coverage period, Counts said, and “can mix activities to complete 80 hours per month.”

Starting July 1, new applicants will be required to show they’ve met the requirements the month before applying. Those renewing will need to show they’ve met the requirements or fallen under an exclusion for the past three months, which do not have to be back-to-back.

Starting in January 2027, enrollees must go through the redetermination process every six months, save for Native Americans. Retroactive coverage will also change from three months to one month.

Counts said the state is currently working with the Centers for Medicare and Medicaid Services (CMS) to determine whether enrollees must also report when there’s a change in community engagement requirements.

CMS is expected to give further guidance to states in June, and DPHHS officials said that details regarding the requirements are subject to change based on that guidance.

Counts recommended that Medicaid enrollees log on to or create an account on Montana’s self-service portal to see notices online, along with updating contact information to ensure they receive notices about their coverage. The state’s Medicaid website (found here) will also include the most up to date information, Counts said.

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