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

Last reviewed: 2026-08-16

Adult Companion Services in Montana provide non-medical supervision and socialization to help individuals with functional impairments remain safely in their communities. These services are primarily delivered through Medicaid Home and Community-Based Services (HCBS) waivers, such as the Big Sky Waiver, the 0208 Comprehensive Waiver, and the Severe Disabling Mental Illness (SDMI) Waiver, all overseen by the Montana Department of Public Health and Human Services (DPHHS).

The single biggest structural barrier to entry is that Montana does not issue a standalone "Companion Care License." Because it is an unlicensed service category, applicants cannot simply submit an application to Medicaid; they are structurally blocked from the MPATH enrollment portal until they first secure a Qualified Provider designation or a regional Case Management Team contract from the DPHHS Senior and Long Term Care (SLTC) or Behavioral Health and Developmental Disabilities (BHDD) divisions.

1. Service Definition and Scope

In Montana, Adult Companion Services are strictly non-medical. Under Mont. Admin. R. 37.34.926, companion services consist of nonmedical supervision and socialization provided to a waiver recipient with a functional impairment.

The service is designed to ensure the health and safety of the participant while fostering independence. It explicitly excludes hands-on nursing care or personal care assistance, though incidental tasks like light housekeeping may be performed during the supervision period.

• Target Population: Medicaid HCBS waiver recipients with functional impairments, typically age 18 or older (or 14 and older under specific developmental disability waivers).
• Allowed Tasks: Socialization, supervision, light housekeeping, meal preparation, and shopping when incidental to the primary supervision role.
• Prohibited Tasks: Hands-on medical care, medication administration, and personal care assistance (Activities of Daily Living such as bathing or dressing).
• Setting: Services must be delivered in the participant's home or integrated community settings, not in congregate care or nursing facilities.
• Governing Rule: Mont. Admin. R. 37.34.926 defines the scope for developmental disability waivers, with parallel definitions in the Big Sky Waiver manual.

2. Regulatory and Oversight Agencies

The Montana Department of Public Health and Human Services (DPHHS) is the umbrella agency responsible for all Medicaid and HCBS waiver programs. Oversight is divided among specific divisions based on the target population of the waiver.

While the Quality Assurance Division (QAD) handles facility and medical agency licensing, standalone companion care is unlicensed. Therefore, programmatic compliance is monitored directly by the operating divisions and their contracted case management entities.

• Primary Agency: Montana Department of Public Health and Human Services (DPHHS) oversees all Medicaid operations.
• Operating Division (Aged/Disabled): The Senior and Long Term Care (SLTC) Division manages the Big Sky Waiver.
• Operating Division (DD/Mental Health): The Behavioral Health and Developmental Disabilities (BHDD) Division manages the 0208 DD and SDMI waivers.
• Licensing Authority: DPHHS Quality Assurance Division (QAD) licenses agencies providing hands-on care, but exempts standalone companion providers.
• Fiscal Agent: Conduent operates the Montana Access to Health (MPATH) system for provider enrollment and claims processing.

3. Gatekeeping Prerequisites: Who Can Even Apply

Montana does not allow open, standalone Medicaid enrollment for HCBS companion providers. You cannot simply submit an MPATH application and start billing. Providers are structurally blocked from enrollment until they receive programmatic approval from the state.

Because there is no facility license required, the primary gatekeeping mechanism is the DPHHS division approval process. Providers must be vetted and accepted by the specific waiver's operating division or regional case management contractor before Medicaid will process an enrollment application.

• Division Approval: Applicants must obtain a Qualified Provider designation from BHDD or SLTC prior to initiating Medicaid enrollment.
• Case Management Affiliation: Big Sky Waiver providers must be authorized by regional Case Management Teams who control participant service plans and local provider networks.
• Procurement Windows: BHDD periodically uses Requests for Proposals (RFPs) or open enrollment windows for new DD waiver providers; closed networks may apply in saturated regions.
• Licensure Exemption: No Certificate of Need (CON) or specific facility license is required for standalone non-medical companion services.
• Business Registration: Applicants must be registered and in good standing with the Montana Secretary of State before applying to DPHHS.

4. Licensure and Certification Requirements

Montana does not have a specific "Adult Companion Agency" license category. If a provider only offers non-medical companion services, they operate as an unlicensed Medicaid-enrolled HCBS provider subject to waiver certification standards.

However, if an agency intends to provide both companion services and hands-on personal care (such as bathing or dressing), they must obtain a Personal Care Agency (PCA) or Home Health Agency (HHA) license from the DPHHS Quality Assurance Division (QAD).

• Standalone Companion License: None exists in Montana; providers operate under waiver-specific certification.
• Alternative Licensure: A Personal Care Agency (PCA) license from QAD is required if the agency also provides hands-on ADL assistance.
• Certification Standard: Providers must meet CMS HCBS Settings Rule criteria, validated by DPHHS program officers using a state-specific validation tool.
• Insurance Requirements: Providers must maintain general liability and professional liability insurance as dictated by the DPHHS provider agreement.
• NPI Requirement: Agencies must obtain a Type 2 (Organization) National Provider Identifier (NPI), or a Type 1 for sole proprietors.

5. Medicaid Provider Enrollment

Once programmatic approval is secured, providers must enroll through the Montana Access to Health (MPATH) Web Portal. Enrollment is managed by Conduent, the state's fiscal agent.

Providers must enroll as an HCBS Waiver Provider and submit a specific set of financial and legal documents. Montana has strict validation rules for these documents, and minor discrepancies will halt the enrollment process.

• Enrollment Portal: Applications must be submitted electronically through the MPATH Provider Services system.
• Required Form 1: The Provider Enrollment Application Form, submitted via MPATH with a valid digital or original signature.
• Required Form 2: The Provider Enrollment Agreement (Terms and Agreements), a fillable PDF downloaded from medicaidprovider.mt.gov/forms.
• Required Form 3: EFT Authorization Agreement, which mandates a physical street address with a ZIP+4 code (PO Boxes are rejected).
• Required Form 4: An IRS W-9 form, where the legal name and EIN must exactly match the uploaded IRS tax identification verification letter.

6. Staffing, Training and Background Checks

Direct care workers providing companion services must meet DPHHS waiver standards for background checks and basic competency. Because they operate in vulnerable individuals' homes, strict screening is enforced.

Agencies are responsible for maintaining personnel files that prove all staff met these requirements prior to their first day of unsupervised client contact.

• Age Requirement: Direct care companion staff must be at least 18 years of age.
• Background Check: Mandatory Montana Department of Justice (DOJ) criminal history background check for all patient-facing staff.
• Federal Screening: Agencies must conduct monthly checks against the OIG List of Excluded Individuals/Entities (LEIE).
• First Aid/CPR: Staff must maintain current CPR and First Aid certification.
• Training: Staff must complete DPHHS-approved training on abuse/neglect reporting, HIPAA, and HCBS Settings rules.
• Supervision: Agencies must designate a supervisor to oversee the companion's adherence to the participant's Individualized Service Plan (ISP).

7. Documentation, Policies and Records

Providers must maintain strict documentation to comply with DPHHS and CMS HCBS Settings Rule requirements. Documentation must clearly differentiate non-medical companion time from any other services the participant receives.

Incomplete service logs are a primary source of Medicaid clawbacks during state audits. Every billed unit must be backed by a contemporaneous record.

• Service Plan: Providers must maintain a current copy of the participant's Individualized Service Plan (ISP) authorized by the case manager.
• Service Logs: Daily documentation must include start/stop times, specific activities performed, and the participant's response to the service.
• EVV Compliance: Providers must utilize the state-mandated Electronic Visit Verification (EVV) system if required by the specific waiver for companion codes.
• Incident Reporting: Agencies must have written policies for reporting critical incidents to DPHHS and the case manager within 24 hours.
• Record Retention: All financial, programmatic, and personnel records must be retained for a minimum of 5 years.

8. Billing, Rates and Claims

Claims are submitted to Conduent via the MPATH portal or through an approved clearinghouse using EDI 837P transactions. Services are billed on a fee-for-service basis.

Companion services cannot be billed without an active prior authorization on file. Furthermore, group practices must ensure all rendering providers are properly affiliated with the billing provider in the MPATH system.

• Billing System: Claims are processed through the MPATH Provider Services portal.
• HCPCS Code: Services are typically billed under S5135 (Companion care, per 15 minutes) or equivalent waiver-specific codes.
• Prior Authorization: 100% of companion services require prior authorization from the waiver case manager before services are rendered.
• Rate Structure: Reimbursement rates are set by the DPHHS Medicaid fee schedule, which is typically updated annually on July 1.
• Affiliations: Group practices must establish billing-to-rendering provider affiliations in MPATH; claims without confirmed affiliations will be denied.

9. Approval Sequence and Timeline

The process from initial business setup to active Medicaid billing takes several months. The timeline is heavily dependent on how quickly the applicant can secure programmatic approval from the DPHHS operating division.

Once the MPATH application is submitted, Conduent and DPHHS review the file. Any missing documents trigger a deficiency notice, which restarts the review clock.

• Step 1: Register the business with the Montana Secretary of State and obtain an EIN and NPI (1-2 weeks).
• Step 2: Apply for Qualified Provider status or regional Case Management approval with SLTC or BHDD (30-90 days).
• Step 3: Submit the Medicaid enrollment application via the MPATH portal with all required attachments (1 day).
• Step 4: Conduent and DPHHS review the MPATH application and verify credentials (30-60 days).
• Step 5: Resolve any deficiency notices (the 30-working-day review clock restarts upon resubmission).
• Step 6: Receive the Welcome Letter and begin accepting authorized participants.

10. Common Denials and Survey Findings

Applications and claims are frequently denied due to administrative errors in the MPATH portal or failure to maintain current credentials. Montana Medicaid has strict validation rules for financial documents.

During audits, DPHHS frequently cites providers for failing to maintain continuous documentation or allowing staff credentials to lapse.

• Enrollment Denial: Mismatch between the legal name or EIN on the W-9 and the IRS tax identification verification letter.
• Enrollment Denial: Using a PO Box on the EFT Authorization Agreement instead of a physical street address with a ZIP+4 code.
• Claim Denial: Missing or lapsed billing-to-rendering provider affiliations in the MPATH system.
• Claim Denial: Providing and billing for services before the prior authorization is officially approved by the case manager.
• Audit Finding: Missing start/stop times or lack of required signatures on daily service logs.
• Audit Finding: Allowing staff to provide services after their CPR/First Aid certification or background check has expired.

11. Key Contacts and Resources

Providers should rely on official DPHHS portals and Conduent support for accurate, up-to-date information regarding enrollment and billing.

Because companion care is waiver-specific, maintaining open communication with the respective DPHHS operating division is critical for compliance.

• Medicaid Enrollment Portal: Montana Access to Health (MPATH) Provider Services.
• Fiscal Agent: Conduent Provider Relations (for MPATH enrollment and claims support).
• Oversight Agency (Aged/Disabled): DPHHS Senior and Long Term Care (SLTC) Division.
• Oversight Agency (DD/Mental Health): DPHHS Behavioral Health and Developmental Disabilities (BHDD) Division.
• Forms Repository: medicaidprovider.mt.gov/forms (for the Provider Agreement and EFT Authorization forms).
• Licensing Agency: DPHHS Quality Assurance Division (QAD) (for agencies also seeking PCA or HHA licensure).

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