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Montana Medicaid and the new work rules
Montana HELP Plan — Medicaid Expansion, called ACA Adult Medicaid in state eligibility policy is run by Montana Department of Public Health and Human Services (DPHHS) — benefits through the Health Resources Division, with applications, renewals and the community engagement requirement run by the Human and Community Services Division through the Offices of Public Assistance and apply.mt.gov. Montana expanded Medicaid on January 1, 2016, which is why the new federal work requirement reaches this state — and why what you do now matters.
From July 1, 2026, most adults have to show 80 hours a month
The requirement applies to adults aged 19 to 64 covered through Medicaid expansion — around 73,895 people in Montana. It is not only about paid work: study, job training, volunteering and a mix of them all count , and earning at least $580 a month satisfies it on its own.
Montana checks first and asks second, and it has deliberately minimized self-declaration. DPHHS says it "carefully evaluated each category excluded from community engagement requirements and avoided reliance on self-declaration wherever possible." Employment is checked against Department of Labor wage data. American Indian and Alaska Native status, caregiver status for a dependent child, SNAP and TANF work-requirement participation, Medicare entitlement and age are checked against the CHIMES eligibility system. From October 1, 2026 medical frailty is checked against twelve months of Medicaid claims history, matched to a Medically Frail Condition List of diagnosis codes built by the department's State Medical Officer on a two-tier framework — conditions that fit the five federal categories, plus frailty indicators. If any of those checks succeeds you are excluded automatically and never get a letter. If they do not, you are asked: pay stubs or tax returns for work, a school schedule or transcript for education, a signed verification form for community service, provider documentation for addiction treatment, a Veterans Affairs statement for a disability rating, facility records for incarceration, or a self-declaration form where nothing else is reasonably available. Documentation is optional when you first apply; the request comes afterwards if the data checks come up empty.
If your hours swing from month to month, say so. The rule is written per month, which is the wrong shape for farm and fishing work, construction, tourism and seasonal retail — a good month and a dead month average out to a living, but the dead month is the one that fails. Federal law has a provision for exactly this: a seasonal worker can satisfy the requirement using their average monthly income over the previous six months instead of hours worked in the month being checked. It is at 42 CFR 435.552(a)(7), and the law defines who counts as seasonal by pointing at the tax code rather than listing jobs, so do not decide for yourself that it misses you. If your work is seasonal or your hours are irregular, tell the state that when you report, and ask for the six-month average to be used.
That is the state's own estimate of how many will lose coverage.
This is Montana's own figure, from the state's September 2025 1115 waiver application, and it is the only state-published projection available. DPHHS assumed roughly 78,000 expansion enrollees, estimated that about 65% were already exempt or compliant, and projected that half of the remaining non-exempt third — 17.5% of the whole expansion population, about 13,650 people — would disenroll because of community engagement, half in 2026 and half in 2027, with a further 1.5% to 2.5% leaving because of the premiums the same application sought. The application's own enrollment tables put the gap starkly: 66,201 enrolled in 2027 with the waiver's provisions against 81,151 without them. Because that projection bundles community engagement together with premiums Montana is not currently charging, the work-rule share of it is the 17.5% figure rather than the whole gap. No CBO, CMS or HHS projection specific to Montana was found.
Most of that is expected to be paperwork rather than people becoming ineligible. Which is the whole reason to sort out your address and your proof now rather than at the last minute.
You do not have to prove anything if any of these describe you
Exemptions are meant to be applied by the state automatically from records it already holds, but records are imperfect. If one of these fits you and you still get asked to report hours, say so and ask them to check — don't assume the notice is right.
What you can earn and still qualify
Monthly income, before tax, for the whole household. These are the state's own published figures, which is what its caseworkers actually apply. If you are close to a line, apply anyway — some income does not count, and only the agency can run the calculation for your situation.
Adults 19 to 64133% of the poverty line
- 1 person
- $1,769
- 2 people
- $2,398
- 3 people
- $3,028
- 4 people
- $3,658
- 5 people
- $4,287
- 6 people
- $4,917
- 7 people
- $5,546
- 8 people
- $6,176
Pregnant157% of the poverty line
- 1 person
- $2,088
- 2 people
- $2,831
- 3 people
- $3,574
- 4 people
- $4,318
- 5 people
- $5,061
- 6 people
- $5,804
- 7 people
- $6,547
- 8 people
- $7,290
Source: Montana DPHHS Combined Medicaid eligibility policy manual, Table of Standards ACA-FMA 007 (ACA Adult Medicaid / ACA Adult Income), effective April 1, 2026, read alongside ACA-FMA 004 (Pregnancy), ACA-FMA 005 (Healthy Montana Kids and HMK Plus) and ACA-FMA 003 (Parent Caretaker Relative), and ABD 008 and CMA 001 and 002 for aged, blind and disabled standards. A note on precision: Montana states its expansion limit two different ways in two different kinds of document, and both are correct. We publish the state figure.
Two other changes land on the same day
Renewals get more frequent, and back-dated coverage gets shorter.
P.L. 119-21 §71112, amending 42 U.S.C. §1396a(a)(34). Applies to applications submitted on or after January 1, 2027.
Montana has a law that could put expansion at risk if federal funding falls
Coverage here is tied by statute to how much the federal government pays.
Who this reaches. The law covers adults 19 through 64 covered through Medicaid Expansion — 73,895 people in March 2026, including 12,981 American Indian and Alaska Native Montanans.
Montana Code Annotated 53-6-1313, Reduction in federal medical assistance percentage. If the federal medical assistance percentage for the expansion group is set below the level in 42 U.S.C. 1396d(y)(1), the continuation of coverage under the HELP Act is contingent on (1) the appropriation of additional state general fund money or other action by the legislature, (2) the department's ability to raise premiums under 53-6-1307 to pay the difference, or (3) a combination of legislative action and premium increases sufficient to cover the increased state match.
This is a soft trigger — a contingency clause rather than a guillotine, and the difference is worth being precise about. It does not terminate expansion automatically and it does not set a date. What it does is make continuation conditional: if the 90% federal match falls, coverage carries on only if the Legislature appropriates more money or takes other action, or the department raises premiums enough to cover the gap, or both. That still puts Montanans' coverage in the hands of a body that meets for 90 days every other year, and it is the reason Montana's expansion has always been read as hostage to the Legislature rather than to Washington. There is a second, practical complication: route (2), raising premiums, is not currently available to the department. CMS required Montana to phase expansion premiums out after December 31, 2022 and the request to reinstate them, filed in September 2025, is still pending. So if the match fell today, the statute's escape valve would be legislative action, and essentially only legislative action. Georgetown's Center for Children and Families has flagged a question that applies here as much as to the harder triggers elsewhere: whether a per-person cap on federal funding, as distinct from a cut to the matching rate, would engage a provision written in terms of the rate. Nobody has answered it. Expansion costs Montana roughly $89 million to $95 million of state money a year against a total program cost of around $1 billion, so the sum the Legislature would have to find is not small.
Unexercised, and the sunset that sat beside it no longer exists. Montana's Medicaid expansion has no termination date in statute for the first time since it was created, and the 2025 Legislature removed the date rather than postponing it, which is why this is a repeal and not another extension. The contingency clause at 53-6-1313 remains on the books and has never been exercised: the expansion matching rate has not fallen, coverage has run without interruption since January 1, 2016, and no Montanan has lost coverage through it. The Legislature has not given up its leverage, and the bill's own sponsor said so — Buttrey noted that lawmakers retain the power to end or change the program in future sessions even without a sunset cliff. What changed is that doing nothing no longer ends it. A reader who remembers the 2025 fight should know the fight is over and the program won.
Nothing has changed, and this is not a reason to delay applying. It is a reason to keep your contact details current, open everything the state sends, and not assume coverage renews itself.
Do this now
Update your address and phone number first. Everything about the new rules arrives by mail, and a stale address is the most common reason people lose coverage they are still entitled to. Then check whether an exemption applies to you.
About the phone numbers: The two main lines do different jobs and it is worth getting this right before you dial. Use 1-888-706-1535 — the Public Assistance Helpline — for anything about applying, a redetermination, an address change, or reporting your community engagement hours or an exclusion. That is the number that matters for the work rules. Use 1-800-362-8312 once you are enrolled and need to ask about benefits, copays or finding a provider. Both run Monday to Friday, 8am to 5pm Mountain only; there is no evening or weekend line. If you need an interpreter, say so when the call connects.
Deaf, hard of hearing or speech-impaired: 711.
Montana DPHHS prints its language assistance and non-discrimination notice in fifteen languages besides English — Spanish, German, Chinese, Japanese, Tagalog, French, Russian, Korean, Arabic, Thai, Norwegian, Vietnamese, Ukrainian, Pennsylvania Dutch and Italian — and it promises free qualified interpreters, including American Sign Language, along with written material in other languages and accessible formats such as large print, audio and electronic copies. Spanish is the one language with its own paper application, which you can download from the member services page. There is no separate interpreter hotline to ring, because the way Montana does this is that you ask: ask when you call the Public Assistance Helpline on 1-888-706-1535 about your case, ask your caseworker for someone who speaks or signs your language, and ask at your doctor's office, because providers are required to arrange interpreting free of charge. One gap deserves naming plainly. No Montana tribal language appears on that fifteen-language notice — not Blackfeet, Crow, Assiniboine, Nakoda, Gros Ventre, Chippewa Cree, Northern Cheyenne, Salish or Kootenai — and no tribal-language Medicaid materials could be found. The promise of a free qualified interpreter is not limited to the languages on the list, so if you need one in a tribal language, ask for it by name, and the Offices of Public Assistance in Browning, Hardin, Lame Deer, Wolf Point and Polson are the nearest places to ask in person.
Most people who lose coverage lose it over paperwork, not eligibility
71% of the coverage losses recorded in Montana were procedural — a form, a deadline, or an address, rather than a real change in whether someone qualified. From July 1, 2026 that matters more, not less.
NOTICE OF ELIGIBILITY DETERMINATION
Case number: ███████
Date of this notice: 1January 12, 2027
Our records do not show that you met the community engagement requirement for the reporting period.
2If you believe this is incorrect, or if an exemption applies to you, contact us on or before February 11, 2027.
3Coverage for other members of your household is not affected by this notice.
What the federal data says about coverage here
Public federal data describes how each state runs its program. Almost all of it is written for policy analysts. Here is what those numbers mean if you are the person enrolled.
Of people who lost coverage here, this share lost it over paperwork rather than eligibility.
Open every letter. Keep your address current with the agency.
Provider supply here is around the national middle.
Book an appointment before you need one, not when you do.
Where you live in this state changes what coverage is worth. Montana is the fourth largest state and one of the emptiest, and distance is a coverage issue here rather than an inconvenience. DPHHS's own Rural Health Transformation Program plan states that "in 15 Montana counties representing 9% of the State's population, the average distance to a hospital is greater than 20 miles; in 4 counties, the average distance is over 40 miles," and that rural counties have 76.7 physicians of all types per 100,000 residents against 233.3 in Montana's five metropolitan counties. HRSA classes 51 of Montana's 56 counties as rural; by the six-people-per-square-mile test DPHHS uses operationally, 47 of the 56 are frontier, and the state's 2021 Rural Health Plan records designated frontier areas covering 133,133 square miles, 90% of Montana. Forty-nine of 56 counties are primary care health professional shortage areas, 51 are mental health shortage areas, and every county in the state is medically underserved in at least one discipline. Forty-nine of Montana's 66 licensed hospitals are Critical Access Hospitals, capped at 25 beds, and DPHHS reports that 89% of rural hospitals in the state are running a negative operating margin. Two practical consequences for the new work rules. Montana has not adopted the high-unemployment hardship exception it is permitted to use, which would have helped people in counties where work is simply scarce. But it has adopted the travel hardship: if you or a dependent must travel outside your community for an extended period for care for a serious or complex medical condition that cannot be treated where you live, that counts as meeting the requirement for those months — and Medicaid pays for non-emergency medical transportation, on 1-800-292-7114. Montana DPHHS, Rural Health Transformation Program Plan (dphhs.mt.gov/assets/ruralhealthtransformation/rhtp-plan.pdf) and Rural Health Transformation Program FAQs; Montana State Rural Health Plan, DPHHS Office of Inspector General, 2021; HRSA Maternal and Child Health Bureau state narrative for Montana; DPHHS Verification Matrix at dphhs.mt.gov/medicaidchanges/VerificationMatrix
You are exempt from the work requirement — and enrolling still matters
American Indians and Alaska Natives are fully excluded from the community engagement requirement — not exempt for a month at a time, but outside the rule altogether. This is federal law, section 71119 of P.L. 119-21 as implemented at 42 CFR 435.554, and Montana applies it: American Indian/Alaska Native is the first item on the specified exclusions list DPHHS publishes at medicaidchanges.mt.gov. Montana also keeps the twelve-month renewal cycle for American Indian and Alaska Native members when everyone else in the expansion group moves to six-month redeterminations on January 1, 2027, and the department's own eligibility manual says so in terms: "American Indian/Alaska Natives are not subject to the 6-month redetermination requirement and only need to be redetermined annually or when changes are reported." The scale of this in Montana is larger than almost anywhere. DPHHS's quarterly report to the Legislature put 12,981 American Indian and Alaska Native people in Medicaid Expansion in March 2026, out of 73,895 in the group — about one enrollee in six, in a state where American Indians are roughly 6% to 7% of the population. In practice the exclusion should mostly happen without your doing anything: DPHHS's verification matrix says American Indian/Alaska Native status is checked against the CHIMES eligibility system automatically, and if the check comes up empty you can establish it with a self-declaration form, a tribal enrollment number, or Indian Health Service documentation. The one thing worth doing is making sure the state has your status recorded, because an automatic check only works on data the state already holds. Enrolling in Medicaid still matters even if you get care free at an Indian Health Service or tribal clinic, and the reason is money that does not come out of Montana's pocket. When a Medicaid-enrolled patient is seen at an IHS facility or a tribally operated one under a 638 agreement, the federal government pays 100% of the cost — the state match is zero. That funding pays for the specialty referrals and services a clinic cannot provide on site, and it is why Medicaid payments to IHS and tribal facilities in Montana ran to more than $197 million in 2023 on the Montana Healthcare Foundation's count, about 40% of it for expansion enrollees. The 100% rate does not extend to the urban Indian programs, which draw Montana's ordinary match. Montana Medicaid also charges no copayments to an American Indian or Alaska Native member who has ever received, or is eligible to receive, a service from the Indian Health Service, a tribal health program or an urban Indian program, or through a referral from one — a self-attestation is enough, and the same attestation exempted members from the expansion premiums when those were still charged. Where to go: the IHS Billings Area Office, at 2900 4th Avenue North in Billings, covers Montana and Wyoming. IHS runs Blackfeet Community Hospital in Browning, the Crow/Northern Cheyenne Hospital at Crow Agency, Fort Belknap Hospital in Harlem, the Verne E. Gibbs Health Center in Poplar, and clinics at Heart Butte, Lodge Grass, Pryor, Hays, Wolf Point and Lame Deer. Flathead Tribal Health at St. Ignatius, Rocky Boy Tribal Health at Box Elder and the Little Shell Health Center in Great Falls are tribally operated. The urban Indian programs are the Billings Urban Indian Health and Wellness Center, the Helena Indian Alliance, All Nations Health Center in Missoula, the Indian Family Health Clinic in Great Falls and the Butte Native Wellness Center. Montana has seven reservations — Blackfeet, Crow, Flathead, Fort Belknap, Fort Peck, Northern Cheyenne and Rocky Boy's — and eight federally recognized tribal nations once the Little Shell Chippewa Tribe, recognized in December 2019 and without a reservation, is counted; DPHHS consulted "all eight tribal nations and Urban Indian Organizations" when it built its rural health plan. There are Offices of Public Assistance in Browning, Hardin, Lame Deer, Wolf Point and Polson, DPHHS has an American Indian Health Director and an IHS, Tribal 638 and Urban Indian Organizations section, and it holds formal Medicaid state-tribal consultations at least twice a year. One more thing specific to Montana law: section 53-6-1304(2)(b) lets the department serve people who live in a geographical area, including an Indian reservation, that would not be effectively or efficiently served through the HELP program by covering them through ordinary Medicaid instead. That provision dates from the years when expansion ran through a third-party administrator with its own network, and it is a reminder that which Medicaid category you are in is not always obvious — and the community engagement requirement reaches only the expansion group.
Questions people ask about this
Do the new Medicaid work rules apply to me in Montana?
How many hours a month do I have to work?
Who is exempt from the work requirement in Montana?
When do the Montana work rules start?
What is the income limit for Montana Medicaid?
How do I apply for Montana HELP Plan — Medicaid Expansion, called ACA Adult Medicaid in state eligibility policy?
How often do I have to renew Montana Medicaid?
Guides for neighboring states
The rules change completely at the state line. If you moved recently, or you're helping family somewhere else, start with their state rather than this one.
Montana's Medicaid work rules are not something arriving in January — they have been in force since July 1, 2026, and the grace period is over.
For the first three months DPHHS checked whether people were meeting the 80-hour community engagement requirement but did not deny or cancel anyone's coverage for failing it. That protection ended on September 30, so from October 2026 noncompliance can cost you your coverage. You are not tested on a fixed date: you are tested at your next redetermination, and the state looks at any three months since your last one. So the thing to do today is make sure DPHHS can reach you. Sign in at apply.mt.gov, or call the Public Assistance Helpline on 1-888-706-1535, and check that your address, phone number and email are right — because if the state cannot verify you from its own records, a letter comes, and from the date on that letter you have 30 days to answer. If you are American Indian or Alaska Native you are excluded from the requirement altogether, and you keep yearly renewals rather than moving to six-month ones in January.
Updating your address takes two minutes and protects everything else. Do that first, then check the exemption list above.
Go to apply.mt.gov →