May 1, 2026

The President’s Message is published in the MHA Weekly News Report, a member-only publication of the Montana Hospital Association. To subscribe, click here.

The Montana Department of Public Health and Human Services (DPHHS) this week hosted the first in a series of informational webinars focused on upcoming federal Medicaid changes.

These changes will significantly affect the Montana Medicaid Expansion population beginning in July 2026.

The webinars provide information on the implementation of new federal requirements passed under last year’s congressional budget bill, H.R. 1. A primary feature is new community engagement requirements, commonly referred to as work requirements, for certain beneficiaries enrolled in Medicaid.

Community engagement requirements have been in Montana state law since 2019, when they were adopted as part of the reauthorization of Medicaid Expansion. At the time, community engagement requirements were outside the standard Medicaid program design and therefore required federal approval. The state’s request to adopt them into the Montana Medicaid program was never approved.

Montana’s current Medicaid Expansion law and the new H.R. 1 requirements are similar in concept, but the federal law is broader, more prescriptive, and significantly more binding on the state. Recent administrative rulemaking issued by the state makes clear that Montana’s implementation language must align directly with federal statutory and regulatory language.

This is an important point. It means many operational details (including definitions, verification processes, exemptions, reporting requirements, and timelines) may ultimately be dictated by forthcoming CMS guidance rather than state-level flexibility. We are concerned that the blanket federal approach will disallow certain features tailored for Montana including provisions for tribes and certain religious organizations, and put a heavy burden on both DPHHS and eligible Montanans to maintain compliance.

For hospitals, providers and community organizations, these developments underscore the importance of ongoing outreach, patient education, and preparation for potential coverage disruptions among Medicaid Expansion enrollees. We encourage hospitals, clinics, care teams, and community partners to participate in the remaining webinar opportunities:

• General informational webinar: Wednesday, May 13, from 2:00–3:00 p.m.
• Healthcare provider webinar: Thursday, May 21, from 10:30–11:30 a.m.

Registration is required for all sessions. For webinar information and registration links click here. For more information on Medicaid changes, including FAQs, click here.