- See also: Reform proposals related to work requirements for public assistance programs
This page provides information about work requirements for public assistance in Montana as of December 2024.
Work requirements for public assistance refer to conditions that require participation in employment-related activities to qualify for the assistance. These activities may include job searching, engaging in job training, volunteering, or working a specified number of hours each week.
Public assistance programs involve the division of responsibilities between the federal government and state governments. The federal government sets eligibility criteria, provides guidelines, and allocates funding for these programs, while states are responsible for administering them and, in some cases, have the authority to tailor the programs to meet local needs.
Ballotpedia has tracked work requirements in Montana related to the Supplemental Nutrition Assistance Program (SNAP), child care subsidies, Medicaid, and public housing. Click here to see work requirements for public assistance in other states.
Supplemental Nutrition Assistance Program (SNAP)
Previously called food stamps, the federal work requirement is generally 30 hours per week, but for Able-Bodied Adults Without Dependents (ABAWDs), it is 20 hours per week. States can request temporary waivers from the Food and Nutrition Service (FNS) to exempt recipients from ABAWD work requirements in areas with an unemployment rate above 10% or insufficient job opportunities. ABAWDs who fail to meet the work requirement can only receive SNAP benefits for up to 3 months in a 36-month period unless they meet the requirement or are exempt.
Child care subsidies
Federal law requires parents receiving
Child Care and Development Fund (CCDF) subsidies to work or engage in work-related activities. States have flexibility in defining eligible activities, which may include employment, job search, self-employment, education or training, foster care, and subsidized guardianship. Employment is an approved activity for CCDF subsidies in all states, and some states also allow subsidies for education and training.
Medicaid
Medicaid work requirements are eligibility conditions that require recipients to complete certain work-related activities—such as working, pursuing education, participating in a work program, or volunteering—in order to qualify for or maintain benefits. The
budget reconciliation bill that was signed into law on July 4, 2025 requires states to adopt community engagement requirements for able-bodied adults without dependents on Medicaid by January 1, 2027.
Public housing
Public housing work requirements mandate that adult residents (who are not elderly, disabled, or already employed) complete eight hours of community service per month to remain eligible for assistance. Public housing authorities (PHAs) in the U.S. Department of Housing and Urban Development (HUD) Moving to Work (MTW) Program can establish additional work requirements. PHAs must apply to the MTW program to create such requirements.
The following table outlines Montana's public assistance work requirements by type as of December 2024, including both state and federal requirements, as well as the options available to states for establishing or temporarily suspending work requirements.
| Montana work requirements for public assistance, by type
|
| Type of public assistance
|
Montana requirements
|
Federal requirements
|
State options
|
| SNAP |
Partial waiver as of 2024 |
20 hours (general) |
States can request and implement temporary waivers for the ABAWD work requirements.
|
| Child care subsidy (CCDF) |
15 hours |
Required, but undefined |
States have the authority to set work requirements for child care subsidies.
|
| Medicaid |
None |
None |
States can apply for Section 1115 waivers to implement work requirements, but they must receive approval from the Centers for Medicare and Medicaid Services (CMS).
|
| Public housing |
None |
Eight hours of community service |
Public housing authorities must apply to the Moving to Work (MTW) Program to implement work requirements.
|
Work requirements by type of public assistance
Click the tabs below to learn details about each public assistance program:
Supplemental Nutrition Assistance Program (SNAP)
Child care subsidy (CCDF)
Medicaid
Public housing
- See also: Supplemental Nutrition Assistance Program work requirements
Federal law establishes foundational guidelines for SNAP work requirements, setting minimum standards that include defined work hours—SNAP work requirements do not vary by state. While states do not have the authority to fully implement their own specific rules, there is some flexibility in how they administer SNAP. States can determine the specifics of work requirements, define acceptable work activities, and establish processes for tracking compliance.
Montana SNAP work requirements
The general SNAP work requirement in Montana is 30 hours per week. Additionally, for Able-Bodied Adults Without Dependents (ABAWDs), the requirement is to work at least 80 hours per month or 20 hours per week. As of the fourth quarter of the 2024 fiscal year, Montana has a partial waiver for work requirements.[1]
Montana policy regarding Supplemental Nutrition Assistance Program (SNAP) work requirements
The following is the text of the Montana policy regarding Supplemental Nutrition Assistance Program (SNAP) work requirements:[2]
Montana Code Annotated § 53-2-091 (2023)
| “
|
Administration of food stamp program -- rulemaking authority
(1) The department is authorized to administer the food stamp program in compliance with all federal laws and requirements.
(2) The department shall adopt rules that are necessary and desirable for the administration of the food stamp program.
(3) The department shall adopt rules that may include but are not limited to rules concerning:
(a) eligibility for assistance, including income and resource limitations, income and resource exclusions, and transfers of resources;
(b) amounts of assistance and methods for determining benefit amount;
(c) periodic redetermination of eligibility;
(d) reporting requirements;
(e) work registration, employment, and training requirements and exemptions from those requirements;
(f) procedures and policies of the employment and training program;
(g) disqualification because of intentional program violations, for voluntarily quitting a job without good cause, or for any other violation of program rules; and
(h) penalties applicable to recipients of cash assistance who have been sanctioned because of failure to meet any requirement of that program.
[3]
|
”
|
Federal SNAP work requirements
- See also: U.S. Department of Agriculture
SNAP has two types of work requirements: general work requirements and able-bodied adult without dependents (ABAWD) work requirements. The following sections provide information about the two types of SNAP work requirements.
General SNAP work requirements
General SNAP work requirements mandate that individuals aged 16 to 59 who can work must complete the following work-related activities:
- Register for work
- Participate in SNAP Employment and Training (E&T) programs
- Take a suitable job if it is offered
- Not voluntarily quit a job or reduce work hours below 30 hours a week without cause.[4]
Individuals do not have to register for general work requirements if they already meet the following conditions when they apply for SNAP benefits:
- Work at least 30 hours a week
- Meet work requirements for another public benefits program
- Care for a child under six years old or an incapacitated person
- Are unable to work due to a physical or mental limitation
- Are participating in an alcohol or drug treatment program
- Are studying in school
- Are attending a training program[4]
Able-bodied adult without dependents (ABAWD) work requirements
The ABAWD (Able-Bodied Adult Without Dependents) work requirement under SNAP applies to individuals aged 18 to 64 without children. To remain eligible for SNAP, ABAWDs must meet one of the following work-related activities:
- Work or Volunteer: At least 80 hours per month (about 20 hours per week).
- Participate in a Work Program: Participate in a federal, state, or local work program, such as SNAP Education and Training (E&T), for at least 80 hours per month.
Time Limit for ABAWDs
ABAWDs who do not meet the work requirement can only receive SNAP benefits for three months in a 36-month period. After reaching this time limit, they lose eligibility for benefits unless they start meeting the work requirement.[4][5]
Requalifying for SNAP Benefits
If an ABAWD loses eligibility due to failing to meet the work requirement, they can requalify for benefits by meeting the work requirement for 30 consecutive days. However, if they do not meet the work requirement within this 30-day period, they will be ineligible for SNAP for the next three years.
Time Limit Waivers
States can request temporary waivers for ABAWD work requirements in areas where jobs are scarce. These waivers apply in places with an unemployment rate above 10%, or in noncontiguous states (Alaska and Hawaii) if the unemployment rate is at or above 1.5 times the national unemployment rate.[6]
As of the third quarter of the 2025 fiscal year, three states had full ABAWD time limit waivers, and 25 states had waivers for specific counties with high unemployment.[7]
- See also: Child care subsidy work requirements
States are responsible for defining the activities that qualify a family for child care subsidies through the Child Care and Development Fund (CCDF), such as work requirements, education participation, and community service. Employment is an approved activity for CCDF funding in every state and some states also approve subsidies for parents participating in education and training activities.
Montana child care subsidy (CCDF) work requirements
The work requirement for the child care subsidy (CCDF) in Montana is 15 hours per week. The following is the text of the Montana administrative rule regarding child care work requirements:[8]
37.80.201 NONFINANCIAL REQUIREMENTS FOR ELIGIBILITY AND PRIORITY FOR ASSISTANCE
| “
|
(1) In addition to the income requirements of ARM 37.80.202, parents must work or attend school or
vocational training to receive child care payments.
(a) With the exceptions in (2), a two parent household must work a total of 120 hours per
month, but there is no minimum number of hours that each parent must work each month.
(b) A single parent must work a minimum of 60 hours each month or attend school or
vocational training full-time. A single parent must be working a minimum of 40 hours each
month if attending school or vocational training part-time.[3]
|
”
|
Federal child care subsidy work requirements
Federal law requires that parents receiving CCDF child care subsidies work or complete work-related activities. States are responsible for defining the activities that qualify a family for assistance through CCDF, including work requirements, education participation, and community service. Employment is an approved activity for CCDF funding in every state and some states also approve subsidies for parents participating in education and training activities. Working, periods of job search, self-employment, attending job training or education-related activities, foster care, and subsidized guardianship are activities that meet eligibility standards for CCDF subsidies in different states. State agencies have flexibility in determining eligibility for CCDF subsidies, according to HHS regulations.[9][10][11]
- See also: Medicaid work requirements
Medicaid work requirements are mandated work-related activities that Medicaid recipients must complete to qualify for benefits, such as applying for a job, interviewing for a job, or participating in job training or volunteer activities. Section 1115 of the Social Security Act of 1935 allows states to apply to the Centers for Medicare and Medicaid Services (CMS) for approval to develop state-level Medicaid work requirement programs.[12]
Montana Medicaid work requirements
Montana applied for a waiver in 2019 but did not receive CMS approval before the Biden administration began withdrawing waivers in 2021.
Federal Medicaid work requirements
Federal law does not universally impose work requirements for Medicaid until 2027. Instead, work requirements have been introduced through state-level waivers under Section 1115 of the Social Security Act. These waivers allow states to experiment with different approaches to Medicaid, including work-related criteria. As of 2024, only Georgia has a Medicaid work requirement.
- See also: Public housing work requirements
Public housing work requirements are mandated work-related activities that public housing recipients must complete to maintain eligibility for housing assistance, such as applying for a job, interviewing for a job, or participating in job training or volunteer activities.
Montana public housing work requirements
There are 16 public housing authorities (PHAs) in Montana. Zero PHAs are part of the Move to Work (MTW) program and zero list work requirements in their annual applications as of August 2023.
Federal public housing work requirements
The federally required work-related activity is eight hours of community service per month for adult residents of public housing who are not elderly, disabled, or already working. Public housing authorities (PHAs) in the Department of Housing and Urban Development's (HUD) Move to Work (MTW) program have the flexibility to implement additional work requirements.
Of the 123 public housing authorities (PHAs) authorized to establish work requirements under the U.S. Department of Housing and Urban Development's (HUD) Move to Work (MTW) Demonstration Program, 17 had work requirements as of January 9, 2024.
Public housing authorities with work requirements
Noteworthy events
The Montana Department of Public Health and Human Services (DPHHS) opens comment period for section 1115 waiver (2025): On July 7, Montana's DPHHS announced the opening of a 60-day public comment period on the state's proposed section 1115 waiver application. The draft of the waiver was scheduled to be made publicly available on July 18. The press release stated that the section 1115 waiver would be used to implement community engagement and cost-sharing requirements that are required under state and federal law. The community engagement requirement would condition Medicaid benefits on full or part-time work.[13]
See also
External links
- ↑ USDA Food and Nutrition Service, "ABAWD Waivers," accessed January 31, 2024
- ↑ Montana Legislature, "Montana Code Annotated § 53-2-091 (2023)," accessed May 1, 2025
- ↑ 3.0 3.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 4.0 4.1 4.2 USDA, "SNAP Work Requirements," accessed May 16, 2023
- ↑ HHS, "SNAP ABAWD work requirements," accessed June 2, 2023
- ↑ Congress.gov, "H.R.1 - 119th Congress (2025 - 2026)," July 4, 2025
- ↑ USDA Food and Nutrition Service, "ABAWD Waivers," accessed July 1, 2025
- ↑ Montana Secretary of State, "Administrative Rules of Montana 37.80.201", accessed May 1, 2025
- ↑ Urban Institute, Child care subsidies, accessed May 31, 2023
- ↑ HHS Child care, parental activities and reason for care, accessed May 31, 2023
- ↑ Child care aware, child care and development block grant, accessed May 31, 2023
- ↑ Social Security, Demonstration Projects, accessed May 15, 2023
- ↑ Montana DPHHS, "DPHHS Seeks Public Comment on Proposed Community Engagement, Cost Sharing," accessed July 9, 2025
| Work requirements |
|---|
| | Index | | | | Overviews | | | | Arguments | | | | Reform proposals | | | | Legislation, court cases, and scholarly work | | | | Relevant agencies | |
|
