Americas Healthcare Services Montana and Arkansas Rollout Medicaid Work Requirements Adhering to Federal Standards

Research evidence excerpt

Americas Healthcare Services Montana and Arkansas Rollout Medicaid Work Requirements Adhering to Federal Standards

Goldman Sachs Americas Healthcare Services

From a coverage perspective, the direct operational burden falls primarily on state

agencies rather than managed care organizations. Montana’s Medicaid program remains

predominantly fee-for-service, while Arkansas administers much of its Medicaid

population through FFS arrangements, with the expansion population covered under the

ARHOME program through Arkansas Blue Cross Blue Shield and Ambetter (CNC).

From a provider perspective, hospital exposure appears relatively limited, with no

meaningful presence from HCA and ARDT in either state, UHS operating behavioral

health facilities in Arkansas and none in Montana, and Tenet maintaining facilities in

both states through its USPI network.

Key Details

Montana Launches Medicaid Community Engagement Verification Matrix

n On July 1, 2026, Montana launched the initial phase of its Medicaid community

engagement requirement for the Medicaid expansion population, making it one of

the first states to move ahead of the federal January 1, 2027 implementation

deadline.

n The rollout centers on a new “verification matrix” that outlines qualifying activities,

exemption categories, and the documentation beneficiaries must provide to

demonstrate compliance with community engagement requirements.

n Qualifying activities include employment, education, workforce training, and

community service, with beneficiaries required to submit supporting documentation

such as pay stubs, school schedules, transcripts, or participation forms.

n Montana’s framework relies heavily on administrative data and third-party

verification rather than self-attestation, with the state limiting auditable