Hundreds of people commented on MT Medicaid plan, but DPHHS opts against any changes

Carly Graf, Lee Enterprises, 10/21/25

Words like “unnecessary,” “punitive” and “premature” are common refrains throughout the couple hundred written public comments that have been submitted to the federal government regarding Montana’s application to overhaul its Medicaid program.

The Montana Department of Public Health and Human Services submitted its proposal last month to institute work requirements and premiums for Medicaid enrollees. It would also double how often people must prove eligibility for the joint state-federal health insurance.

Some of these provisions are pulled from the mammoth budget bill that the Trump Administration steered through the U.S. Congress’ GOP-majorities this summer. Others are unique to Montana. The state’s health department has said it wants to roll out the changes by early next year.

One psychiatrist said making health care less accessible would lead to higher costs and worse patient outcomes. A local food bank director described the proposal as unfair and ineffective, and a farmer shared fear that they wouldn’t be able to afford the new premium costs because they are already walking a financial tightrope.

In just over a month, there have been more than 220 public comments submitted to the Centers for Medicare and Medicaid Services regarding the DPHHS plan. The vast majority criticized the proposal. There were another 467 comments provided to the state between July and August, many of which, according to a DPHHS summary, raised opposition and voiced concerns about people losing coverage due to cumbersome paperwork and backlogs.

If its application is approved, Montana would become one of the first states to adopt the bulk of the Medicaid changes packaged into the Trump budget bill, even though the federal law doesn’t require many of the provisions to go into effect until 2027.

Montanans could face Medicaid work requirements, higher costs earlier than rest of country

Montana Democrats call DPHHS proposal a “premature and unnecessarily hasty rush to wrap red tape around Medicaid.”

The state is required to solicit public input, but it is not obligated to incorporate any of that feedback. Montana’s health department has declined to modify its proposal based on comments it received and instead has moved forward with seeking approval from the federal government to roll out Medicaid changes sooner rather than later.

“Given that this demonstration seeks to implement both state and federal law, DPHHS is not revising the key components of this demonstration application based on public comment at this time,” according to a response published by the agency. “However, DPHHS will continue to review and consider all public comments as it develops its operational plans to support implementation.”

2025 Legislature

The 2025 Montana Legislature passed and Republican Gov. Greg Gianforte signed into law the renewal of Medicaid expansion, which makes the government-backed health coverage available to able-bodied adults who earn below 138% of the federal poverty level. (In 2025, that’s $36,777 for a household of three). Lawmakers also signed off on slashing the program’s sunset.

Baked into the legislation is a slew of guardrails designed to get Republican lawmakers on board and ensure that only people who most need the government help can get it.

DPHHS estimates 17.5%, or more than 13,000, of the roughly 78,000 adults currently covered by Medicaid expansion would be disenrolled from the program over the next two years under the proposal. Projections from the Montana Healthcare Foundation suggest the number could be closer to 27,000 adults.

“The safety net of Medicaid should be there for those who truly need it, but if everyone is allowed to climb upon the net, it will collapse,” Gianforte said in a statement last month after DPHHS submitted its application. “By requiring healthy adults to engage in work-related activities and cost sharing, we can help preserve the long-term sustainability of the Medicaid program and ensure that this critical health coverage remains available for those who need it most.”

A small handful of public comments echoed this sentiment, saying that most people should have to work to access government benefits. In its summary, DPHHS said some commenters thought community engagement requirements could promote self-sufficiency.

Readiness questions

State officials have said that fast-tracking its application will allow Montana to work through any kinks that arise before they’re on the hook with the federal government. But much of the public comment showed frustration that DPHHS was moving to implement changes on such a quick timeline before federal law requires it.

“Speeding up the work requirements for Medicaid prior to developing a customer friendly system is sure to make people go without insurance,” one person anonymously wrote in a comment to CMS. “You may think it will save money for the state but, those who work in healthcare know a sick population is more expensive than a healthy one.”

When Montana underwent Medicaid unwinding, during which all enrollees were reevaluated for eligibility after being kept on the rolls automatically throughout the pandemic, it had some of the worst performances in the nation on metrics like response time and administrative errors. Nearly 130,000 people lost Medicaid coverage, a majority due to procedural issues.

Members of the public cautioned that they haven’t seen improvement that makes them confident that the system won’t collapse under the weight of more frequent redeterminations and more complicated reporting requirements.

“Most people that need this program are already stretched very thin. I’ve submitted applications and sat on the phone for hours trying to speak with someone. If people want to meet in person you have to take a day off work to sit in a lobby full of people also needing assistance,” one commenter wrote. “Before you require more of the people needing these programs start fixing them and making them more efficient and accessible.”

At an interim legislative meeting in September, DPHHS officials projected they’ll need to hire up to 50 new staff to handle the influx, but the department has not provided any details on implementation. The agency also said it views the unwinding period as “distinctly different” than this proposal.

“Ultimately, the demonstration program implementation plan, including staffing needs, will be informed by ongoing eligibility and enrollment improvement efforts,” DPHHS wrote. “While a detailed implementation plan is not, nor required to be, included in this Demonstration, the State’s ongoing commitment to improving service delivery remains clear.”

Heather O’Loughlin, executive director of the Montana Budget and Policy Center agrees that redetermination was different, but argues that the task in front of the state is far more complicated.

“In many ways, it was an easier lift than what the state is embarking on now,” she said. “Redetermination asked one question of enrollees: income. What we’re talking about now is building up a new bureaucratic framework for people to report a multitude of allowable activities and nearly two dozen exemptions, all with different data points.”

Public comment closed on Saturday. Montana’s application now sits with CMS awaiting approval.