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Montana - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Montana's Department of Public Health and Human Services (DPHHS) funds Companion Services through the Developmental Disabilities Program (DDP) 0208 Comprehensive Waiver, governed by Administrative Rules of Montana (ARM) 37.34.926. The service provides nonmedical supervision and socialization for waiver recipients aged 14 or older, assisting with tasks like meal preparation and light housekeeping without delivering hands-on nursing care.

Prospective agencies must secure a DDP Provider Addendum before their Montana Healthcare Programs Medicaid enrollment application can be approved. Providers must also establish access to the DDP's mandatory training module in Elsevier’s College of Direct Supports to qualify their direct care staff.

1. Service Definition and Scope

Under ARM 37.34.926, Companion Services in Montana consist of nonmedical supervision and socialization for individuals with developmental disabilities. The service is designed to help individuals aged 14 and older who live with family, friends, or independently to remain safely in the community.

While companions may assist with incidental daily living tasks, these activities cannot be billed as discrete services. The scope strictly prohibits the delivery of hands-on nursing care.

2. Regulatory and Oversight Agencies

The Montana Department of Public Health and Human Services (DPHHS) oversees the delivery of HCBS through its specialized divisions. The Behavioral Health and Developmental Disabilities Division (BHDD) directly manages the waiver program and provider qualifications.

Medicaid enrollment and claims processing are handled by the state's fiscal agent, Conduent, through the Montana Healthcare Programs portal.

3. Gatekeeping Prerequisites: Who Can Even Apply

Montana does not require a Certificate of Need (CON) or a competitive Request for Proposals (RFP) procurement to become a Companion Services provider. However, the state utilizes a closed-loop approval process where DDP authorization is a strict prerequisite.

An applicant cannot simply enroll in Medicaid; they must submit and receive approval for a DDP Provider Addendum. Additionally, the 0208 Comprehensive Waiver operates with a strict participant capacity limit, meaning providers rely on the DDP regional offices to assign individuals from the waiver waiting list.

4. Licensure and Certification Requirements

Montana does not issue a distinct facility or agency license specifically for Companion Services. Instead, providers are certified through the DDP qualification process and must adhere to the HCBS Settings Rule.

Agencies must meet state and federal business requirements and maintain specific commercial insurance policies mandated by the DDP Provider Manual.

5. Medicaid Provider Enrollment

Entities must enroll as a Montana Medicaid Provider through the Montana Healthcare Programs portal managed by Conduent. The enrollment type and taxonomy code must align with the services approved in the DDP Provider Addendum.

Applicants must provide complete ownership and control disclosures as required by CMS. Failure to submit accurate W-9 tax reporting information or ownership details will result in application denial.

6. Staffing, Training and Background Checks

Direct care staff providing Companion Services must meet the competency standards outlined in ARM 37.34.2102. The DDP mandates the use of a specific online training platform for all waiver service providers.

Agencies must designate an Administrator to manage learner enrollment and assign lessons through the state-sponsored system.

7. Documentation, Policies and Records

Providers must maintain comprehensive records to support claims and demonstrate compliance with DDP standards. This includes maintaining up-to-date personnel files with verified training logs.

The DDP requires providers to submit an updated Provider Addendum whenever significant organizational changes occur, ensuring the state has current operational data.

8. Billing, Rates and Claims

Companion Services are billed to Montana Medicaid through the Conduent fiscal agent system. Providers are strictly responsible for verifying a participant's Medicaid eligibility at the time of service.

Claims are subject to retrospective review by DPHHS or its Utilization Review Contractor to ensure services were appropriate and actually delivered.

9. Approval Sequence and Timeline

The approval process begins with establishing the business entity and obtaining an NPI, followed by engagement with the DDP Regional Office. The critical step is the submission and approval of the DDP Provider Addendum.

Once the Addendum is approved, the provider submits the formal Medicaid enrollment application through the Conduent portal. Processing times vary based on application completeness and background screening requirements.

10. Common Denials and Survey Findings

Enrollment applications are frequently delayed or denied due to incomplete ownership disclosures or mismatched tax information. CMS regulations strictly require full disclosure of managing control.

During retrospective reviews, providers often face recoupments if staff training records do not meet the specific documentation requirements of ARM 37.34.2102.

11. Key Contacts and Resources

Providers should utilize the official DPHHS and Montana Healthcare Programs websites for the most current manuals, fee schedules, and enrollment forms.

The DDP Regional Offices serve as the primary point of contact for waiver operations, training access, and participant assignments.


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