Recently, Montana issued new rules on work and community engagement requirements for some Medicaid recipients.
Beginning July 1, 2026, Montana introduced new rules affecting some adults who receive health coverage through Medicaid Expansion. These rules are commonly described as “Medicaid work requirements.” That description is understandable, but it is incomplete. A person does not necessarily have to hold a paid job to meet the new requirement. Montana officially calls it a “community engagement requirement” because employment, education, workforce training, community service, and nonprofit volunteer work may all count.
It is equally important to understand that the new requirement does not apply to every person receiving Medicaid. It primarily applies to adults between the ages of 19 and 64 who receive coverage through Montana’s Medicaid Expansion program and who do not qualify for an exclusion. Children, older adults, many people with disabilities, and people covered through other Medicaid eligibility categories are not necessarily subject to the requirement.
There has been particular confusion concerning Montana Medicaid for Workers with Disabilities, commonly called MWD, which is a separate Medicaid program that allows eligible people with disabilities to work while retaining Medicaid coverage, subject to the program’s existing employment, income, and other eligibility rules. According to the Montana Department of Public Health and Human Services, people already enrolled in MWD are not subject to the new Medicaid Expansion community-engagement requirement. The rules they already follow concerning employment and income remain in place. In other words, MWD participants should continue complying with the requirements of the MWD program, but they do not have to satisfy this new 80-hour community-engagement requirement merely because it took effect in July 2026.
For Medicaid Expansion participants who are subject to the new rule, the basic requirement is 80 hours of approved activities during a month. Eighty hours is approximately 20 hours per week, although the state evaluates the requirement on a monthly basis. A person may meet all 80 hours through one qualifying activity or combine different activities.
Paid employment counts. Community service or volunteer work with a nonprofit organization may also count. Attendance at school can qualify, as can participation in an approved state or federal workforce-training or job-readiness program. A person could, for example, work 60 hours during the month and complete 20 hours of qualifying volunteer service. The combined total would satisfy the 80-hour requirement for that month.
Completing the hours is only part of the process. Medicaid participants may also have to provide proof. Depending on the activity, acceptable documentation might include pay stubs, an official school schedule or transcript, documentation from a workforce program, or a signed record of volunteer hours. Montana may verify some information by matching Medicaid records with information already held by other state programs. When the state cannot verify the information electronically, the participant may need to report it and submit supporting documents.
The timing of the verification depends on whether the person is applying for Medicaid Expansion or renewing existing coverage. A new applicant generally must show that the requirement was met, or that an exclusion applied during the month before the application. At redetermination, an existing participant generally must demonstrate compliance for at least three months during the review period. Those three months do not have to be consecutive.
Existing Medicaid Expansion participants did not all have to report 80 hours immediately on July 1. Instead, the requirement is considered as their individual cases reach a scheduled redetermination. Montana also established a temporary “hold harmless” period from July through September 2026. During that period, the state reviews whether applicants and participants meet the new requirement, but it will not deny or terminate coverage solely because of noncompliance with the community-engagement requirement if the person satisfies the other Medicaid eligibility rules. Beginning in October 2026, however, failure to meet the requirement or establish an applicable exclusion may result in denial of an application or termination of coverage.
Beginning in January 2027, most affected Medicaid Expansion participants will undergo an eligibility redetermination every six months. During redetermination, the state will review whether the person continues to meet income and other Medicaid eligibility requirements and whether the community-engagement requirement or an exclusion has been satisfied. American Indian and Alaska Native participants generally remain subject to a 12-month redetermination schedule.
The exclusions are a crucial part of the new system. A person should not assume that the rule applies simply because that person is between 19 and 64 or has received a notice concerning Medicaid. Some people are completely excluded from the community-engagement requirement because of their status or circumstances. Others may receive an exception for particular months because of a temporary hardship.
People who may qualify for an exclusion include American Indians and Alaska Natives; former foster youth under age 26 who were receiving Medicaid and in foster care when they turned 18; certain incarcerated individuals; pregnant people and those within the 12-month postpartum period; people participating in drug or alcohol treatment; and veterans with a total, or 100 percent, disability rating. A parent, guardian, caretaker relative, or family caregiver responsible for a dependent child under age 14 or for a person with a disability may also qualify for an exclusion. A parent caring for a person with a disability may qualify regardless of the disabled person’s age.
People who satisfy work requirements through Temporary Assistance for Needy Families, or TANF, may also be excluded. Certain people receiving Supplemental Nutrition Assistance Program benefits, commonly called SNAP, may qualify when they are already subject to SNAP work requirements.
Most importantly for the disability community, a person whose physical, mental, intellectual, developmental, behavioral, or other health condition substantially interferes with the ability to work or participate in other approved activities may qualify for a medical exclusion. Montana’s public information refers to this in plain language as having “a medical condition or health needs that impact the ability to work or do other community-engagement activities.” Federal regulations use the more technical term “medically frail.”
A person does not necessarily have to be completely unable to perform any activity to qualify. The relevant question is whether the person has a qualifying condition that significantly impairs the ability to comply with the community-engagement requirement. This may include a physical, intellectual, or developmental disability that significantly affects activities of daily living; a disabling mental disorder; a substance-use disorder; blindness or disability as defined under federal law; or a serious or complex medical condition.
Montana currently accepts provider documentation or a self-declaration to verify medically frail status at both the initial application and redetermination. This is an especially important protection because a person should not lose coverage merely because the state’s records do not automatically identify a disability or serious health condition. People who receive Supplemental Security Income, or SSI, or Social Security Disability Insurance, or SSDI, do not have to satisfy the new community-engagement requirement.
Some circumstances are treated as exceptions or short-term hardships rather than permanent exclusions. These may include receiving inpatient medical services, living in a county covered by an emergency disaster declaration, or having to travel outside the community for treatment of a serious or complex medical condition affecting the participant or a dependent. A person who has recently been incarcerated or who is eligible for Medicare may also be treated as satisfying the requirement for applicable months. Montana has identified high unemployment as a possible exception under federal rules but has stated that it is not presently implementing that exception.
The distinction between a continuing exclusion and a temporary exception matters. A person who qualifies as a specified excluded individual is not subject to the 80-hour requirement while that exclusion applies. A temporary hardship, by contrast, generally counts only for the month or months during which the hardship existed. At redetermination, a person relying on a short-term exception may need to establish that it applied during at least three months of the review period. If it applied for only one or two months, the participant may need to show qualifying activity during additional months.
Medicaid participants should carefully read every notice they receive from DPHHS. They should also keep their mailing address, telephone number, email address, household information, income information, and employment or education status current. A person who believes an exclusion applies should report it and provide the requested form or documentation instead of assuming that the state already has the necessary information.
Changes may be reported through Montana’s online Self Service Portal at apply.mt.gov, by calling the DPHHS Public Assistance Helpline at 1-888-706-1535, by visiting a local Office of Public Assistance, or by mailing the information to the Human and Community Services Division, P.O. Box 202925, Helena, MT 59602-2925.
If DPHHS decides that a person is not eligible or has not complied with the community-engagement requirement, the participant should receive a formal Notice of Adverse Action. Medicaid participants have the right to appeal an adverse eligibility decision through the fair-hearing process. The notice should explain the decision, the deadline for requesting a hearing, and the steps required to appeal. Because appeal deadlines are important, a person who disagrees with a decision should seek assistance promptly.
The most important message is that Montana has not imposed a universal work requirement on every Medicaid beneficiary. The new rule applies mainly to non-excluded adults ages 19 through 64 who receive Medicaid Expansion coverage. Even within that group, paid employment is not the only way to comply, and numerous exclusions and temporary exceptions are available. People with disabilities should pay particular attention to the medical exclusion and should not assume that they must work or volunteer when a health condition prevents them from doing so.
The safest course is to read all Medicaid notices, respond before the stated deadline, keep copies of submitted documents, record qualifying work or volunteer hours, and formally request any exclusion that applies. Understanding the difference between Medicaid Expansion, MWD, approved community-engagement activities, and exclusions can help people protect their health coverage under this complicated new system.
This article provides general educational information and does not constitute legal advice. Medicaid rules and administrative guidance may change. Current information, reporting forms, and official instructions are available from the Montana DPHHS Medicaid Changes webpage and its Frequently Asked Questions.
About Living Independently for Today & Tomorrow (LIFTT): LIFTT is a Montana 501(c)3 corporation organized as a Center for Independent Living (CIL). With team members based in Billings and Glendive, LIFTT provides people with disabilites and aging indivduals with programs, services, resources and advocacy that help empower them to break down the physical, bureaucratic, and cultural barriers that prevent them from being fully independent participants in their lives and communities throughout 18 counties in southeastern and south-central Montana: Big Horn, Carbon, Carter, Custer, Dawson, Fallon, Garfield, Golden Valley, McCone, Musselshell, Powder River, Prairie, Richland, Rosebud, Stillwater, Treasure, Wibaux, and Yellowstone. For more information, please visit liftt.org
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