Frequently Asked Questions
Starting on July 1, 2026, under new federal law (often referred to as H.R. 1 and the One Big Beautiful Bill Act), Montana will introduce community engagement requirements for certain Montana Medicaid members.
This FAQ reflects information known as of the publish date and can change as updates from CMS become available.
The FAQ below covers the following topics:
- Implementation timeline and key dates
- Overview of community engagement requirements
- Who is affected by the community engagement requirements
- Who is exempt
- Compliance and verification
- Interaction with other programs
- Six-month redetermination
- Appeals and coverage protections
- Eligibility worker operations and state systems
- Stakeholder engagement and updates
- Broader policy and impact
When do the community engagement requirements start?
Montana plans to implement the community engagement requirements in July 2026. These requirements will apply to you if:
- You are between the ages of 19-64.
- You are covered under the Medicaid Expansion (low-income adults).
- Your application is received by DPHHS on or after July 1, 2026 or you are renewing your coverage.
Who is affected by community engagement?
Adults ages 19-64 who are part of Montana’s Medicaid Expansion population will be impacted by the new requirements. This includes both new applicants and current members at renewal.
When will current Montana Medicaid members need to verify they have met the new community engagement requirements?
Current Montana Medicaid members will need to verify they have met the new requirements beginning July 1, 2026.
What to Expect:
- The 80-hour rule: When you apply or renew, you must show that you worked, volunteered, or went to school for at least 80 hours each month you are covered.
- Wait for your notice: We will check your community engagement compliance, or exemption, when it is time for your renewal.
- Renewal every 6 months: You will now need to renew your Medicaid every six months beginning Jan. 1, 2027.
When do new members need to show they are either exempt from or meet the community engagement requirements?
If you are a low-income adult aged 19-64 and are applying for Medicaid for the first time, you must either:
- Show you meet the community engagement requirements for the month before your application; or
- Show you qualify for an exemption
This will need to be included in your application if you apply for coverage on or after July 1, 2026.
Applicants who are not exempt will need to show that they completed at least 80 hours of community engagement activities (such as working, volunteering, attending school, or a combination of these) during the month before applying for coverage.
Applicants who are exempt will need to show they are a part of an exempt group when they are applying for coverage.
What are the new community engagement requirements?
The community engagement requirements require non-exempt adults on Medicaid Expansion, ages 19-64, to participate in community engagement activities to keep their health coverage.
The main community engagement requirements are:
- 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
- Workforce training or job readiness programs through the State of Montana
- Internships or registered apprenticeships
- Going to school (college or vocational school)
- Mixing activities: You can mix these together. For example, you could work 60 hours and do community service for 20 hours.
These community engagement requirements apply to you if:
- You are between the ages of 19-64.
- You are covered under the Medicaid Expansion (low-income adults).
- You do not have an exemption.
Who has to follow the new community engagement requirements?
Adults aged 19-64 who are part of Montana’s Medicaid Expansion. These individuals must either meet the 80-hour requirement through community engagement activities or qualify for an exemption.
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).
How do I know if I am exempt?
Some people do not have to follow the community engagement requirements. This is called being exempt. You might be exempt if you are in the following groups:
- American Indian/Alaska Natives (also exempt from 6-month redeterminations)
- Children ages 18 or younger
- Adults ages 65 or older
- Pregnant people and postpartum individuals (up to 12 months)
- Parents or caregivers of children under age 13
- Parents/caregivers of persons with disabilities
- Veterans with disabilities rated as total
- People who are medically frail
- People enrolled in treatment programs for substance use disorder
- Individuals currently incarcerated or recently released
- Individuals eligible for Medicare
How is “medically frail” defined?
Federal law uses the term “medically frail” for people who have serious health problems.
You might be “medically frail” if you:
- Are blind or have a disability
- Have a serious mental health struggle
- Have problems with drugs or alcohol
- Have a hard time doing daily tasks (like getting dressed or eating) because of a physical or learning problem
- Have a very serious or complex illness
If I am a parent of someone with a disability, do I have to follow the community engagement requirements?
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 requirements. This is true no matter how old your child is.
I am in the Montana Medicaid for Workers with Disabilities program. Do the community engagement requirements 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 requirements?
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 requirements. People with disabilities do not have to meet the new requirements.
How do I show I meet the community engagement requirements?
Details on verification processes are still being developed. Montana DPHHS will provide guidance soon. In most cases, verification will require documentation of hours in employment, education, volunteer service, or other qualifying activities.
How often do I need to show verification of community engagement activities or exemption from those activities?
Most people will need to show verification at each renewal.
If you are applying for the first time:
You must show that you met the community engagement requirements during the month before you apply, or that you have an exemption.
- Example: If you apply in September, you must show you completed 80 hours of work or activities in August.
If you already have Medicaid:
You must show that you meet the community engagement requirements or have an exemption at the time renewal.
How does someone with seasonal income meet the community engagement requirements?
Members with seasonal income can demonstrate that they have fulfilled the requirements by completing at least 80 hours of a combination of community engagement activities (such as working, volunteering, or attending school). For example, you could work 60 hours and volunteer for 20 hours.
Do community engagement requirements in other programs count?
When possible, work or community engagement that meets requirements for SNAP/TANF may also be used to satisfy Medicaid requirements, but precise alignment depends on final state and federal rules.
Once I’m determined eligible for Medicaid, how often am I required to renew my coverage?
Once you are on Medicaid, most people must renew coverage every six months beginning in January 2027. To keep your health coverage, you must show that you still qualify and meet the community engagement requirements.
Can individuals appeal eligibility decisions related to community engagement requirements?
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?
Montana DPHHS will send updated notices indicating whether members need to meet community engagement requirements, 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.

