Medicaid 1115 Waiver Updates – September 2025

Learn more about proposed Medicaid 1115 Waiver amendments for Montana. For more information, reach out to Wesley at publicpolicy@familyvoices.org.

Montana – Montana’s 1115 proposal, “Health and Economic Livelihood Partnership (HELP) would impose work reporting requirements on Medicaid expansion adults, aged 19-64 with incomes up to 138% of the federal poverty level (FPL). Individuals subject to the work requirement would have to participate in community engagement activities for at least 80 hours per month. These activities include work, community service, work programs, and educational programs. Exempt groups are the same as those in H.R.1:

• Pregnant individuals
• Parents or caregivers of dependent children under age 13 or with disabilities
• Requested by the state: Foster parents of children under 19

Work requirement compliance will be checked every six months. Failure to comply will lead to disenrollment from Medicaid, with the option to reinstate within 30 days with compliance or exemption.

Additionally, Montana would like to implement premiums for the Medicaid expansion population. The state would notify tax authorities of failure to pay and to collect the amount due through the Medicaid enrollee’s income tax. For enrollees >100%-138% FPL, failure to pay overdue premiums within 90 days will lead to disenrollment. Exceptions include veterans, students, and workforce program participants.

Comments can be submitted via the Medicaid comment portal for Montana’s demonstration project. The federal comment period is open from September 18 to October 18, 2025.