Six Ways DPHHS Can Reduce Harm to Medicaid Enrollees when Implementing H.R. 1

This year, states will be implementing new red tape reporting requirements for some Medicaid enrollees, and unfortunately, Montana is fast-tracking these changes, which could have a negative impact on Montanans’ accessing Medicaid. In our first blog, we provided an overview of these changes. While the state is required to comply with changes, there are administrative choices it will make that will affect Montanans’ ability to access services they qualify for. Here are six ways the state can make better choices to lessen the harm to enrollees and applicants during the implementation of H.R. 1’s changes to Medicaid Expansion.

1. The state can slow down. Early adoption of H.R.1 does not benefit the state of Montana or Medicaid Enrollees. Department of Public Health and Human Services (DPHHS) Director Charlie Brereton has stated his intent to implement new requirements by July 1, 2026, six months before H.R. 1 requires. Montana is not administratively ready to handle the additional work. Montana ranks in the bottom 25 percent of states across Medicaid administrative performance indicators. October 2025 data indicated that over two-thirds of those disenrolled from Medicaid and CHIP were for procedural reasons, and not due to eligibility. DPHHS intends to hire 59 additional staff to assist with this increased workload. But even with this increase in staff, the department estimates that autorenewals will decrease and processing times will increase. The department estimates that 15,000 people will be disenrolled in 2026 and 2027 due to the implementation of H.R.1 and cost-sharing measures. Implementing too quickly increases the opportunity for errors, confusion, and eligible individuals losing health care coverage.

   
   

2. Build Systems to use all data available. Data systems across agencies, from the Department of Labor, Office of Commissioner of Higher Education, Medicaid claims data, and other provider documentation, will take time to integrate in the application and redetermination processes. Data integration reduces the administrative burden on enrollees, DPHHS staff, and increases accuracy and efficiency. The state is still developing rules and plans for exemptions, including definitions, qualifications, and what level of verification and documentation is needed. These decisions impact ‘back-end’ workflows, data sources, and document submission portals. DPHHS communicated to the legislature that the technology preparation it is undertaking focuses on text message notifications to enrollees and a community assister portal.

   
   

3. Communicate in plain, accessible language. Notices and communications in clear, accessible language to enrollees will help them understand what is required of them and provide the department with accurate information to document exemptions and compliance with work reporting requirements. The state indicated it will start the communications process before it receives federal approval of its Medicaid State Plan Amendment. DPHHS will likely not have all the relevant implementation information for the communications until that process is complete. Vague notices with unclear terms and timelines will not properly inform enrollees and could result in preventable disenrollment of eligible recipients. Being patient and waiting until DPHHS has all the necessary information, engaging stakeholders and focus groups, and working with the Beneficiary Advisory Council can ensure communications are clear and understandable.

   
   

4. Partner with Health Care Providers. Engaging with health care providers may improve implementation outcomes and continuity of care. Communicating with providers about which patients are on Medicaid Expansion and allowing them to inform patients whether they are exempt and what documentation they need could be a crucial step in reducing harm and interruptions in critical health care treatment. Interruption in treatment, or delays in care, can cause medical expenses to balloon. Early intervention and preventive care reduce overall medical costs associated with emergency care and emergency room visits. In 2025 Medicaid paid for 155,000 preventative care claims. 

   
   

5. Strengthen the appeals process.  Adequate resources to provide support and address errors and administrative challenges can reduce harm. Each year, across all public assistance programs, an average of 2,300 individuals have the right to appeal.  But this number is less than a third of the projected disenrollment of 7,600 in 2026 under the new red tape requirements. The Appeals process should be accessible and easy to navigate. As of September 2025, DPHHS had a procedural or administrative disenrollment rate of 11 percent all renewals in that month. Disenrollment for Procedural or administrative reasons includes paperwork not being submitted correctly or on time, address issues, or processing errors. This means people who are likely eligible and have a right to re-enroll, appeal, and seek benefits they qualify for.

   
   

6. Transparency and accountability through data and reporting. The state needs to actively report performance data to the public and the legislature on the implementation process of H.R. 1. Without transparency, DPHHS cannot be properly monitored or held accountable for issues and unnecessary losses of coverage. Reporting data should include the percentage of enrollees who are determined to be in compliance or exempt using existing data; how many enrollees are applying for an exemption versus how many are granted; the rate of procedural disenrollment; and what procedure or point in the process was not completed, resulting in loss of coverage. These data can provide insight into where the system is not functioning correctly. Lastly, how many pages of documentation and requests for information are required to complete an application and redetermination can help measure the administrative burden placed on applicants and enrollees.

New burdensome requirements under H.R. 1 risk the health care coverage of thousands of Montanans. It is incumbent on the state to mitigate this harm by slowing down, making sure its systems are prepared, and being transparent about where the gaps remain.