Frequently Asked Questions

Background

Montana state leadership, including the Governor and State Legislature, has long demonstrated its commitment to implementing the community engagement requirement.

In 2025, the Department communicated initial plans for Montana’s 1115 waiver-driven implementation of work requirements. However, this waiver is still pending approval from CMS. In 2026, CMS advised Montana that it could implement the community engagement requirement under H.R. 1 (the One Big Beautiful Bill Act) through a State Plan Amendment, following CMS definitions for specified excluded individuals and mandatory exclusions.

This history is a key reason Montana is among the first states in the country to implement the community engagement requirement.

What is the new community engagement requirement?

The community engagement requirement requires non-excluded adults on Medicaid Expansion, aged 19-64, to participate in community engagement activities to keep their health coverage.

The community engagement requirement includes:

• 80 hours a month: You must spend at least 80 hours each month doing certain activities. 
• You can meet these hours through: 
  • Working at a job
  • Community service or volunteering with a not-for-profit organization
  • Participating in an approved state or federal workforce training or job readiness program
  • Doing an internship or apprenticeship
  • Going to school
  • Combining activities (for example, you could work 60 hours and complete 20 hours of community service)

The community engagement requirement applies to you if:

• You are between the ages of 19-64. 
• You are covered under the Medicaid Expansion (low-income adults). 
• You are not excluded.

Montana went live with implementation of the community engagement requirements for the Medicaid Expansion population on July 1, 2026. This means that:

• For new applicants: All new applications for Medicaid Expansion on and after July 1, 2026, will be required to meet the community engagement requirement through qualified activities, unless they have a verified exclusion.
• For existing clients: All clients will not immediately need to demonstrate compliance on July 1; rather, compliance will be required at your next scheduled redetermination. Cases with a redetermination date of August 31, 2026 will be the first to be required to meet the community engagement requirement.

What is the “hold harmless” period?

From July through September 2026, DPHHS will have a hold harmless period for the community engagement requirement. During these months, applications will be reviewed for compliance with the community engagement requirement, but clients will not be denied coverage for noncompliance with the new requirement as long as they meet all other conditions of eligibility. 

Starting in October 2026, the hold harmless period will end, and noncompliance with the community engagement requirement will be enforced with denial and disenrollment.

The benefits of the hold harmless period include:​

• Additional time for new and existing clients to become familiar with the requirement, with no adverse action taken.​
• A three-month period for DPHHS to evaluate operational and systems processes and make small adjustments if needed before adverse actions are taken.​
• Opportunity for DPHHS to collect data on implementation(e.g., use of exclusions, processing times) and make data-informed changes to policy decisions and the implementation approach, if needed.

Who has to meet the new community engagement requirement?

Adults aged 19-64 who are part of Montana’s Medicaid Expansion program must meet the community engagement requirement. These individuals must either meet the 80-hour requirement through community engagement activities or qualify for an exclusion.

Who is in the “Medicaid Expansion population”?

This refers to adults who are eligible for Medicaid under the Affordable Care Act expansion (income up to approximately 138% of the federal poverty level). 

What are the impacts to Presumptive Eligibility (PE)?

Beginning July 1, 2026, Qualified Entities must assess PE applicants who are eligible for coverage under Medicaid Expansion for the community engagement requirement. PE determinations for the community engagement requirement are based on self-declaration (i.ge., QEs do not verify documentation or work hours – Montana Department of Public Health and Human Services will verify later at full application). DPHHS will review existing data sources and verify eligibility information, if needed, during the full Medicaid application process. Additional information and resources can be found on the Presumptive Eligibility webpage.  

How do I know if I am excluded?

Some individuals are excluded from the community engagement requirement. Individuals who meet an approved exclusion are not required to meet the community engagement requirement for one or more months. 

There are two different ways you may be excluded from the community engagement requirement, and they work differently:

• If you are a specified excluded individual, the requirement does not apply to you at all.
• If you have an exception or a short-term hardship, you are treated as meeting the requirement only for the months that the exception or hardship applies to you. At redetermination, if you cannot show that you had an exception or short-term hardship for three of the months since your last redetermination, you will need to meet the community engagement requirement through approved activities to keep your Medicaid coverage.

Specified Exclusions apply to your current situation. You may be excluded if one or more of the following options apply to you at the time of your application or redetermination:

• American Indian/Alaska Native
• Children aged 18 or younger
• Former Foster Youth under age 26 who was on Medicaid and in foster care when they turned 18
• Inmate of a public institution (e.g., jail, prison)
• People with a medical condition or health needs that impact their ability to work or do other community engagement activities (for more information on this exclusion, please reference the Medically Frail webpage)
• Parent, guardian, caretaker relative, or family caregiver of a dependent child under age 14 or a disabled individual
• People in a drug or alcohol rehabilitation or treatment program
• People who meet TANF work requirements, or receive SNAP and are subject to SNAP work requirements
• Women who are pregnant or postpartum (up to 12 months)
• Veterans with a total (100%) disability rating

Exceptions and short-term hardships may fulfill part or all of the community engagement requirement for the months that they apply to you:

• People eligible for Medicare
• People incarcerated in the last three months
• People experiencing the following short-term hardships:
  • Receiving inpatient services
  • Residing in a county with an emergency disaster declaration
  • Residing in a county with high unemployment (Note: Montana will not be implementing the high unemployment exception at this time)
  • Person or dependent who must travel outside of their community for medical services for a serious or complex medical condition

At application, you must show that an exception or short-term hardship applied for the month before your new application. 

At redetermination, you must show that an exception or short-term hardship applied for at least 3 months since your last redetermination. The months do not need to be consecutive. If you have an exception or short-term hardship for one or two months, you must complete the remainder of the community engagement requirement by reporting qualifying activity hours.

If I am a parent of someone with a disability, do I have to follow the community engagement requirement?

If you are the parent of a person with a disability who requires your care, you do not have to follow the new community engagement requirement. This is true no matter how old your child is.  

I am in the Montana Medicaid for Workers with Disabilities program. Does the community engagement requirement apply to me?

No. If you are already in this program, you do not need to worry about these new requirements. You just need to keep following the same rules you already use for your job and your income. Nothing has changed for you.  

Are older adults subject to the community engagement requirement?  

No, only Medicaid Expansion adults aged 19-64.  

Are people receiving Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) subject to the new rules?

No. If you receive SSI or SSDI disability payments, you do not have to follow the community engagement requirement. People with disabilities do not have to meet the new requirement.  

How do I show I meet the community engagement requirement or have an exclusion?

DPHHS has a verification matrix that shows what proof is needed for each qualifying activity and exclusion. You will need to provide documents or other proof needed to verify the specific activities and exclusions that apply to you. Please reference the verification matrix for additional information.

How often do I need to show verification of community engagement activities or exclusion from those activities?

Most people will need to show verification at application and at each redetermination.

• At time of application, the community engagement requirement forms (Appendix A and B) and supporting documentation are optional. DPHHS will first attempt to verify that you meet this requirement or qualify for an exclusion using existing data sources. If verification cannot be completed, you may be asked to provide additional documentation. You must show that you met the community engagement requirement or had an exclusion for the month prior to your application.
• Similarly, at redetermination, DPHHS will first attempt to ex parte you using existing data sources. If verification cannot be completed, you must complete the community engagement requirement forms (Appendix A and B) and provide supporting documentation to maintain your coverage. You must show you that you met the community engagement requirement or had an exclusion for three months of your redetermination review period (does not need to be three months in a row).

How does someone with seasonal income verify they met the community engagement requirement?

Members with seasonal income can meet the community engagement requirement by completing 80 hours in a month. Members can show they met this requirement by checking if their average monthly income over the past 6 months is at least $7.25 per hour for 80 hours. If they do not complete 80 hours of seasonal work, they can combine activities such as volunteering and school to reach the monthly total.

How does a student verify they met the community engagement requirement?

Members enrolled in a college, career and technical education program, or high school/GED program and attending at least half-time can meet the requirement by providing a transcript or school schedule showing half-time or full-time attendance. If the transcript does not specify attendance level, 13 hours per month will count for each 1 credit completed. If needed, students can also combine school with other activities, such as work or volunteering, to meet the monthly requirement.

Once I’m determined eligible for Medicaid, how often am I required to redetermine my coverage?

Beginning January 2027, most people must redetermine coverage every six months. At that time, to keep your health coverage, you must show that you still qualify and meet the community engagement requirement. This does not apply to American Indian/Alaskan Natives, as they must redetermine coverage every 12 months.

What happens if I can’t verify that I’ve met the community engagement requirement?

From July through September 2026, DPHHS will review community engagement for applications and redeterminations, but people will not be denied coverage or disenrolled for not meeting the requirement during this time.

Starting in October 2026, DPHHS will continue to review community engagement for applications and redeterminations, and people who do not meet the requirement may be denied coverage or disenrolled.

Can individuals appeal eligibility decisions related to the community engagement requirement?

Yes. Members can appeal decisions by following the instructions on their Notice of Adverse Action. Montana’s appeals process will be outlined in official notices and on the DPHHS website. 

How will notice and communication work?

DPHHS will send updated notices indicating whether members need to meet the community engagement requirement, how they can comply, and how to verify they have completed them. Members are encouraged to create an account on the Self Service Portal and opt-in to email communications. 

Is there a way for providers to see whether a client is eligible/enrolled in Medicaid Expansion vs. Traditional Medicaid?

Today, there is not a way for a provider to determine whether an individual is eligible for Medicaid Expansion vs. Traditional Medicaid. Providers can still support members by reminding them that if they are eligible through Medicaid Expansion and do not have another exclusion, the community engagement requirement may apply to them. Providers can encourage members to keep their contact information with Montana Medicaid up to date and look out for mailed notices. Lastly, providers can always refer members to the Montana Medicaid Eligibility Changes website for more details.

How can providers help support clients with maintaining their coverage?

Providers can encourage members to keep their contact information with Montana Medicaid up to date and look out for mailed notices with information about their next redetermination date. A client’s redetermination date is not visible to providers.

Can a client submit the required verifications for the community engagement requirement before their redetermination?

DPHHS recommends that clients submit information with their redetermination to expedite processing and ensure information is up to date. However, clients can provide information to the department at any time, and information provided will be uploaded to their case record.