While many Montanans are busy planning for the Fourth of July, I’ve been thinking a lot about those who might be laying plans for the first — when Montana is set to officially become the second state in the nation to adopt federal community engagement requirements for those on Medicaid expansion plans.

Signed into law a year ago on July 4, federal bill H.R.1, better known as the One Big Beautiful Bill Act, mandates that states check to ensure that those enrolled in Medicaid expansion plans (part of the Affordable Care Act expansion for those who make up to 138% of the federal poverty level) meet 80 hours of community engagement requirements each month to retain their health care coverage.

The federal bill requires states to implement those requirements beginning in January 2027, but some states have opted to start them early. Nebraska broke the seal in May, and Montana will be the second to follow starting tomorrow.

A list of those who need to meet the requirements and those who are considered exempt can be found on the state health department’s website here, along with what activities qualify as community engagement requirements. State health officials are required to first use existing data to try and confirm a person’s eligibility, and will reach out to enrollees for documentation if they cannot.

Of the nearly 74,000 low-income Montanans enrolled in the Medicaid expansion program as of March this year, Flathead County has the third highest enrollment in the state at just under 7,000 adults.

According to a Montana Labor and Industry report last year, 71% of low-income Montanans enrolled in the Medicaid expansion program were employed, around 10% of enrollees were unable to work due to illness or disability, 7% were caring for a family member, and 4% were attending school.

While many Montanans are in favor of the work requirements, providers and health policy groups warn the state’s early adoption could result in the loss of coverage for eligible enrollees. They point to the around 60,000 Montanans who lost Medicaid coverage due to procedural reasons like incomplete paperwork or a wrong mailing address during the state’s post-COVID-19 pandemic redetermination process.

It’s important to note that while the state health department will begin reviewing community engagement applications and redeterminations in July, Medicaid enrollees will not be denied coverage or disenrolled for not meeting requirements until at least October. 

Health officials at the state’s Department of Public Health and Human Services (DPHHS) have spent the past month reviewing and updating the department’s regulations based on guidance the federal Centers for Medicare and Medicaid Services (CMS) released June 1. The federal rules dictate how states implement the work requirements, including how exemptions such as “medically frail” are defined.

The nonprofit Montana Budget & Policy Center and others have critiqued the federal definition for requiring individuals seeking a medical frailty exclusion to prove they are unable to work due to their health condition.

“CMS proposed rules were released just one month before the DPHHS implementation date,” Andria Schafer with the state policy nonprofit wrote. “This timeline raises red flags that early implementation will harm some of the most underserved populations in Montana, including those battling complex health conditions such as cancer, substance use disorders, and people with disabilities.”

Charlie Brereton, director of the state health department, said the department is prepared for tomorrow’s transition.

“The department is fully prepared for this transition, with trained staff, clear exemption processes, and systems ready to support members,” Brereton said in a prepared statement Tuesday. “We are focused on helping eligible Montanans keep their coverage while successfully meeting these new requirements.”

The department encourages Medicaid enrollees to log in to apply.mt.gov as soon as possible to verify their contact information and make any changes. State health officials say keeping information up to date is essential to maintaining coverage.

I’m Zoë Buhrmaster. Let’s see what else is in today’s Roundup.