State tracker

Montana — Medicaid Coverage Retention

Applies Last updated 2026-06-03 · confidence: high

Montana is subject to federal Medicaid community-engagement/work-requirement implementation beginning January 1, 2027, unless modified by future federal or state guidance.

Procurement / RFP activity

None identified

No public RFP for work-requirement communications/outreach identified as of 2026-06-03.

Procurement portal: eMACS (Montana Acquisition & Contracting System) at bids.mt.gov / bids.sciquest.com (CustomerOrg=StateOfMontana); federal opportunities on SAM.gov · Implementation funding: No dedicated work-requirement communications procurement budget identified. Implementation is being staffed in-house: DPHHS added 43 new client service coordinator positions (30 filled as of April 2, 2026) for community engagement and 6-month redeterminations. Federal H.R.1 implementation funding (the ~$200M national pool for system changes) applies but no MT-specific outreach contract figure is public. (Separate/unrelated: MT's $233M federal Rural Health Transformation Program, which has its own RFPs on eMACS.)

Latest detail

Montana is implementing H.R.1/OBBBA "community engagement" (work) requirements EARLY, on July 1, 2026 — about six months ahead of the federal January 1, 2027 deadline — making it a national early-warning case. DPHHS (Director Charlie Brereton) is conducting member outreach in-house: it mailed letters to all Medicaid members in March 2026, launched a single-source-of-truth website (dphhs.mt.gov/medicaidchanges), and is using mail, text, website, social media, and community partners (Cover Montana, tribal partners, providers) rather than a procured advertising/media vendor. Eligibility is handled through the existing CHIMES system; no new community-engagement-system implementation RFP was identified. CMS has indicated it will require a Medicaid State Plan Amendment (not an 1115 waiver) to authorize the requirements; the only open DPHHS solicitation on eMACS as of June 2026 is an unrelated elder legal-assistance RFP (DPHHS-RFP-2026-0682MQB).

Medicaid expansion status	Expanded
Implementation status	Early implementer — rolling out work/community engagement requirements July 1, 2026 (ahead of federal Jan 1, 2027 deadline)
Who may be affected	Yes — expansion adults
Reporting frequency	Pending state guidance
Reporting method	Pending state guidance
Renewal cadence	Every 6 months for expansion adults (H.R.1)
Notice timing	Pending state guidance
Self-attestation allowed?	Pending state guidance
State system / vendor	Pending state guidance
Major Medicaid MCOs	Pending state guidance
Languages likely needed	Pending state guidance

Key exemption categories to monitor

80 hours/month of work, job training, education, or community service — or qualifying monthly income.
Targets many ACA Medicaid expansion adults (19–64); non-expansion states largely have no such group.
Federal enforcement: January 1, 2027 (states implement; some earlier).
New: expansion adults redetermine every 6 months (not annually).
Commonly-defined exemptions: pregnancy/postpartum; medically frail; primary caregiver; disability; SUD treatment; certain students; tribe (AIAN); short-term hardship. Exact definitions set by CMS rule and each state.

Short-term hardship exemptions to track

Short-term hardship exemptions — adoption pending state guidance.

Member communication risk

Risk detail pending.

What MCOs & state partners should do now

Segment affected members
Identify likely exemptions
Send plain-language multilingual notices
Deploy SMS/email/IVR reminders
Track retention outcomes

Operating in Montana?

The member-notice window is open now and closes August 31, 2026. Complete a Coverage Retention Readiness Audit while there is still time to act — we build CMS-compliant, plain-language, multilingual outreach to keep eligible Montana members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in Montana?

Many ACA Medicaid expansion adults ages 19–64 who do not qualify for an exemption. Final scope is set by CMS rule and state implementation.

When do Montana Medicaid work requirements start?

Federal enforcement begins January 1, 2027 (some states may implement earlier). Member notices are expected in the federally-required window of June 30–August 31, 2026.

What exemptions are available?

Federal baseline categories include parent/caretaker of a child under 14, pregnant/postpartum, disabled/medically frail, American Indian/Alaska Native, and those already meeting SNAP/TANF work rules. Short-term hardship exemptions and exact definitions are set by CMS rule and state implementation.

Sources

This page tracks publicly available implementation information and is updated as Montana publishes guidance. State-specific rules are evolving. Not legal or eligibility advice.