Montana is rolling out Medicaid work requirements on July 1, 2026, five months ahead of the national January 1, 2027 deadline. If you're enrolled in Montana's Medicaid expansion program (adults 19-64 earning up to 138% of the federal poverty level), you'll need to document 80 hours per month of work, education, community service, or another qualifying activity to keep your coverage. Or prove you're exempt.

Families with disabilities often qualify for exemptions, but you can't assume the state has that information on file. Montana DPHHS will conduct outreach between June 30 and August 31, but waiting for a notice isn't a strategy. If you're already enrolled in SSDI or SSI, your exemption is automatic. If you have a disability but aren't receiving those benefits, you'll need to document your status now.

Here's what Montana disability families need to do before July 1.

Who the Work Requirements Apply To

Montana's work requirements target the Medicaid expansion population: adults ages 19 to 64 who qualified under the state's expansion of eligibility to 138% FPL. If you're enrolled in traditional Medicaid (pregnant individuals, children, individuals receiving SSI, or those who qualified before the expansion), these requirements don't apply to you.

If you're in the expansion group, you'll need to report 80 hours per month of qualifying activity. That can be employment, job training, education, community service, or a state-approved program. Or you need to prove you're exempt.

Montana is using a state plan amendment (SPA) to implement early. Arkansas is also soft-launching on July 1 but won't disenroll anyone until January 2027. Montana's approach is stricter: coverage can be terminated for non-compliance as soon as the outreach window closes on August 31.

What the Disability Exemptions Are

Montana recognizes two main exemptions for disability families: the "medically frail" exemption and enrollment in SSDI or SSI.

Medically frail: CMS published the interim final rule defining "medically frail" on June 1, 2026. The guidance lists chronic conditions, complex medical needs, and diagnoses that qualify. Montana DPHHS will issue its own interpretation, but the federal framework applies. If your child (or you) has a chronic health condition, a developmental disability, or a complex care need, this exemption likely covers you.

Nebraska published a list of qualifying diagnosis codes when it implemented work requirements on May 1, 2026. That list includes conditions like cerebral palsy, autism spectrum disorder, intellectual disabilities, and chronic respiratory or cardiac conditions. Montana's implementation is expected to follow a similar model.

SSDI or SSI enrollment: If you're already receiving Social Security Disability Insurance (SSDI) or Supplemental Security Income (SSI), you're automatically exempt. Montana DPHHS should have that information from the federal system, but verify it. Call your county office and confirm your exemption is on file.

Parents and caregivers: Some states exempt primary caregivers of children under age 6 or caregivers of disabled family members. Montana hasn't published its full exemption list yet. If you're a parent or caregiver, ask your county DPHHS office whether you qualify. Document your caregiving role with medical records, school IEP paperwork, or a letter from your child's provider.

How to Document Your Exemption Status

Don't wait for Montana DPHHS to contact you. The outreach window runs June 30 to August 31, and coverage can be terminated as soon as September 1 if you haven't documented compliance or exemption status.

If you're on SSDI or SSI: Call your county DPHHS office and confirm your exemption is already recorded. You shouldn't need to submit additional documentation, but verify it. Ask for written confirmation that your exemption is in your file.

If you have a disability but aren't on SSDI or SSI: Gather documentation of your diagnosis. That can include:

• A letter from your primary care provider or specialist stating your condition and limitations
• IEP paperwork if your child receives special education services
• Medical records showing a chronic condition diagnosis
• A Social Security disability determination letter (even if you aren't currently receiving benefits)
• State Medicaid waiver enrollment paperwork

Contact your county DPHHS office and ask to submit your documentation for the medically frail exemption. Get the name of the person you speak with and keep a record of when you submitted paperwork.

If you're a primary caregiver: Ask whether Montana's rules exempt primary caregivers of young children or disabled family members. If yes, document your caregiving role with your child's medical records, school paperwork, or a letter from their provider.

What Happens If Your Coverage Is Wrongly Terminated

If Montana DPHHS terminates your Medicaid coverage and you believe you qualify for an exemption, you can appeal. Montana law gives you 90 days to file an appeal from the date of the termination notice.

Document everything. Keep copies of:

• The termination notice
• All documentation you submitted showing your exemption
• Records of phone calls to DPHHS (dates, names, what was discussed)
• Medical records proving your disability or chronic condition

You can request a fair hearing through Montana DPHHS. The hearing is conducted by an independent hearing officer, and you have the right to present evidence and testimony. If you can't afford an attorney, contact Montana Legal Services Association (MLSA) at 1-800-666-6899. They provide free legal assistance to low-income Montanans with Medicaid appeals.

While your appeal is pending, your Medicaid coverage should continue if you file within 10 days of the termination notice. This is called "aid continuing." If you miss the 10-day window, coverage stops until the hearing decision.

The Timeline: What to Expect

Now through June 30: Montana DPHHS is finalizing its implementation rules. The federal "medically frail" guidance was published on June 1. The state will issue its own interpretation, but you don't need to wait for it. Contact your county office now with your disability documentation.

June 30 – August 31: Montana DPHHS will send notices to all Medicaid expansion enrollees explaining the work requirements and how to report compliance or claim an exemption. This is the outreach window.

July 1: Work requirements officially start. If you're subject to them and don't have an exemption, you'll need to document 80 hours of qualifying activity for July.

September 1 and beyond: Montana DPHHS can begin terminating coverage for individuals who haven't documented compliance or exemption. Appeals must be filed within 90 days of the termination notice.

If you're a Montana disability family enrolled in Medicaid expansion, act now. Gather your documentation, contact your county DPHHS office, and verify your exemption before July 1. The system isn't built to track who should be exempt automatically. It's built to track who documents it first.