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DPHHS outlines July 1 HR 1 rollout and six‑month redeterminations; advocates urge delay to 2027

March 09, 2026 | 2026 Legislature MT, Montana


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DPHHS outlines July 1 HR 1 rollout and six‑month redeterminations; advocates urge delay to 2027
The Department of Public Health and Human Services told the Children, Family, Health and Human Services Interim Committee on March 11 that it expects to be operationally ready to launch HR 1 community‑engagement (CE) requirements and a six‑month redetermination schedule on July 1, 2026. "Montana, and DPHHS will be operationally ready to launch CE and the 6 month redetermination requirements on 07/01/2026," Human Services Executive Director Jesse Counts said.

Why it matters: HR 1 adds new CE obligations for many Medicaid enrollees and moves renewal cycles to six months; the department’s schedule will shift large numbers of cases into an accelerated review process. DPHHS said it will test systems, train staff, and provide a three‑month education period during which noncompliant cases will receive referrals to HelpLink rather than immediate disenrollment.

Counts detailed the phased approach: renewals due in August will be started in July so the department can align cases to the new six‑month cadence; for the first three months DPHHS "will not be disenrolling" clients for CE noncompliance and will make referrals to the HelpLink program while staff provide coaching and education. The department expects the first coverage lapses for CE noncompliance to take effect Dec. 31, 2026, meaning clients could be without coverage starting Jan. 1, 2027. DPHHS projects the full caseload will be evaluated for CE requirements by April 2027 and initial disenrollments completed by May 31, 2027.

What officials say: Counts described interfaces the department will use for ex parte determinations, including SNAP and TANF data from the integrated eligibility system, wage and tax data, and other verification feeds being developed with CMS. On the path to add CE authority, Counts said DPHHS is preparing a state plan amendment because CMS indicated it will not accept state‑specific CE changes through a section 1115 waiver.

Public and provider reaction: More than two dozen members of the public, clinicians and advocacy groups used the committee’s public‑comment period to press DPHHS to delay early adoption. Heather O’Loughlin of the Montana Budget & Policy Center said states that had planned early adoption later aligned with HR 1’s federal deadline and that Montana’s application processing already lags national averages. "We do remain concerned about the department’s decision to essentially fast track the implementation of the community engagement or work reporting requirements," she said.

Clinicians and patients described recent problems during the Medicaid unwinding and redeterminations, including long waits for phone help and difficulty receiving notices. Pediatrician Addie Moriarty and multiple Medicaid clients urged the committee to recommend a Jan. 1, 2027 start date to reduce the risk of coverage loss.

Next steps: Committee members pressed DPHHS on the timing of client notices (the department intends to post website guidance and mail notices by March 13), rulemaking timelines and clarifications about training and staffing. DPHHS said it is fast‑tracking hiring—tens of positions remain vacant—and will coordinate outreach and training with community assisters and the Department of Labor and Industry. The department will present additional rule and budget details to legislative budget subcommittees as they develop.

Ending: The department framed the three‑month hold‑harmless window and referrals to HelpLink as steps to reduce improper disenrollments while testing systems; public commenters asked the committee to recommend using the full additional federal implementation time and to strengthen outreach, plain‑language notices and community assister resources if the July 1 date is kept.

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