Montana - Day Habilitation Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Montana Department of Public Health and Human Services (DPHHS) Behavioral Health and Developmental Disabilities Division (BHDD) funds Day Habilitation through the 0208 Comprehensive Waiver. Providers seeking to deliver this service must either secure designation as an Organized Health Care Delivery System (OHCDS) through a full DDP Qualified Provider Application or establish a formal subcontracting agreement with an existing OHCDS-designated entity.
Facility-based day habilitation programs operating outside the participant's home must also obtain an Adult Day Care Center license from the DPHHS Office of Inspector General (OIG) Licensure Bureau before Medicaid enrollment can proceed. Once state program approval and facility licensure are secured, agencies enroll as Medicaid providers through the Montana Access to Health Web Portal managed by Conduent.
1. Service Definition and Scope
In Montana, Day Habilitation is defined under the 0208 Comprehensive Waiver as structured programming provided outside the participant's residence that assists individuals with developmental disabilities in acquiring, retaining, or improving self-help, socialization, and adaptive skills. The service focuses on enabling the individual to attain or maintain their maximum functional level in a community-integrated setting.
The service must comply with the federal HCBS Settings Final Rule, ensuring participants have opportunities to engage in community life, control personal resources, and receive services in the community to the same degree of access as individuals not receiving Medicaid HCBS.
- Target Population: Adults with developmental disabilities enrolled in the 0208 Comprehensive Waiver.
- Service Setting: Non-residential, community-based settings or licensed Adult Day Care Centers.
- Core Activities: Skill-building in socialization, adaptive functioning, and self-help.
- Integration Mandate: Must support access to the greater community and competitive integrated employment opportunities.
- Exclusions: Cannot duplicate services provided under the Rehabilitation Act of 1973 or the Individuals with Disabilities Education Act (IDEA).
2. Regulatory and Oversight Agencies
The Montana Department of Public Health and Human Services (DPHHS) is the single state Medicaid agency. Within DPHHS, the Behavioral Health and Developmental Disabilities Division (BHDD) and its Developmental Disabilities Program (DDP) manage the 0208 Comprehensive Waiver and approve qualified providers.
Facility licensure is handled by the DPHHS Office of Inspector General (OIG) Licensure Bureau. Medicaid provider enrollment and claims processing are managed by Conduent, the state's fiscal agent operating the Montana Access to Health Web Portal.
- Montana DPHHS: The overarching state Medicaid authority (https://dphhs.mt.gov).
- Behavioral Health and Developmental Disabilities Division (BHDD): Manages waiver policy and funding (https://dphhs.mt.gov/bhdd).
- Developmental Disabilities Program (DDP): Approves the DDP Qualified Provider Application (https://dphhs.mt.gov/bhdd/DisabilityServices/developmentaldisabilities/).
- DPHHS OIG Licensure Bureau: Issues Adult Day Care Center licenses (https://dphhs.mt.gov/qad/Licensure/HealthCareFacilityLicensure).
- Conduent / Montana Access to Health: Processes Medicaid enrollment and MMIS claims (https://medicaidprovider.mt.gov).
3. Gatekeeping Prerequisites: Who Can Even Apply
Montana DDP enforces a strict structural prerequisite for agency-based waiver services. An applicant must be approved as an Organized Health Care Delivery System (OHCDS) by submitting a full DDP Qualified Provider Application to the Developmental Disabilities Program.
If an applicant cannot or chooses not to become an OHCDS, they are structurally barred from contracting directly with DDP for this service. Instead, they must operate as a subcontractor under an existing OHCDS-designated DDP qualified provider.
- OHCDS Designation: Required structural status for agencies to contract directly with DDP for Day Habilitation.
- DDP Qualified Provider Application: The mandatory initial application packet submitted to the regional DDP office.
- Subcontracting Alternative: Licensed/certified individuals or agencies may bypass direct OHCDS designation by subcontracting with an existing OHCDS.
- Funding Availability: Approval is contingent on the provider identifying services they can offer under the 0208 Comprehensive Waiver funding source.
- Administrative Rule Compliance: Applicants must demonstrate capacity to meet ARM 37, Chapter 34 requirements before application acceptance.
4. Licensure and Certification Requirements
If the Day Habilitation service is delivered in a facility-based setting owned or leased by the provider, the site must be licensed as an Adult Day Care Center by the DPHHS OIG Licensure Bureau under Administrative Rules of Montana (ARM) 37.106.2600.
The licensure process requires submitting an application packet, passing a life safety code inspection, and undergoing an initial on-site health inspection by the department within 45 days of application receipt.
- Facility License: Adult Day Care Center license required for facility-based delivery.
- Regulatory Citation: Governed by ARM Title 37, Chapter 106, Subchapter 2600.
- Initial Inspection: DPHHS conducts an initial licensure inspection within 45 days of application receipt.
- Routine Surveys: Unannounced licensure surveys are conducted every 1 to 3 years.
- Provisional Licensure: A provisional or 1-year license may be issued if correctable deficiencies are found during inspection.
5. Medicaid Provider Enrollment
After securing DDP OHCDS approval and any necessary facility licenses, providers must enroll in Montana Medicaid through the Montana Access to Health Web Portal operated by Conduent. The enrollment form must be completed in its entirety before the fiscal agent can process it.
Conduent forwards the completed enrollment forms to DPHHS for final approval, assignment of procedure codes, and rate loading into the Provider Charge File in the MMIS.
- Enrollment Portal: Montana Access to Health Web Portal (https://medicaidprovider.mt.gov).
- Fiscal Agent: Conduent manages the application verification and MMIS integration.
- Provider Type: Typically enrolled under Provider Type 74 (Developmental Disabilities) for 0208 Waiver services.
- Provider Charge File: DPHHS authorizes specific procedure codes and rates in the MMIS based on DDP approval.
- Revalidation: Providers must revalidate their Medicaid enrollment every 5 years per ACA requirements.
6. Staffing, Training and Background Checks
All Day Habilitation staff must meet the qualifications outlined in ARM 37.34 and the DDP service standards. Providers must employ staff experienced in providing services to persons with developmental disabilities.
Before hire, all staff must clear background checks as mandated by the DDP Criminal History Background Check Policy. Ongoing training requirements include CPR, first aid, and behavior management.
- Background Checks: Mandatory compliance with the DDP Criminal History Background Check Policy (effective 8/06).
- Staffing Ratios: At least one employee must be present in the center at all times when a client is present.
- Initial Orientation: Must cover the policy manual, job description, fire/disaster drills, and basic safety hazards.
- Required Certifications: Staff must maintain current certification in First Aid and CPR.
- Specialized Training: In-service training must include behavior management and other identified client needs.
7. Documentation, Policies and Records
Providers must maintain comprehensive records that align with the participant's Person-Centered Plan of Care. Documentation must prove that the service is integrated into the community and optimizes individual autonomy.
Any modification to the HCBS Settings Rule requirements (e.g., rights restrictions for health and safety) must be supported by a specific assessed need and explicitly justified and documented in the person-centered plan.
- Person-Centered Plan: All Day Habilitation activities must trace back to goals in the individual's approved plan of care.
- Settings Rule Compliance: Policies must ensure privacy, dignity, respect, and freedom from coercion.
- Rights Restrictions: Must be individualized, justified by assessed need, and documented in the care plan.
- Daily Logs: Providers must maintain daily attendance and activity logs detailing the specific skills addressed.
- Incident Reporting: Mandatory reporting of critical incidents to DDP and OIG within state-defined timeframes.
8. Billing, Rates and Claims
Day Habilitation services are billed to Montana Medicaid through the Conduent MMIS portal. Reimbursement rates are established by DPHHS and published in the DDP Rates Information schedule.
Providers can only bill for procedure codes that have been explicitly authorized and loaded into their Provider Charge File by the department following CMT (Case Management Team) authorization.
- Billing System: Claims are submitted via the Montana Access to Health Web Portal.
- Rate Setting: Fixed fee schedule determined by DPHHS and published on the DDP Rates Information page.
- Prior Authorization: Services must be prior-authorized by the CMT and loaded into the MMIS before billing.
- Provider Charge File: The MMIS file that dictates exactly which codes and rates a specific provider may bill.
- Unit of Service: Typically billed in 15-minute increments or per diem, as specified in the waiver appendix.
9. Approval Sequence and Timeline
The approval sequence begins with the DDP Qualified Provider Application to secure OHCDS status. Once approved by DDP, facility-based providers must apply for an Adult Day Care Center license from the OIG Licensure Bureau.
After licensure is granted, the provider submits the Medicaid enrollment application to Conduent. The entire process from DDP application to active MMIS billing status typically takes 3 to 6 months, depending on facility inspection readiness.
- Step 1: Submit DDP Qualified Provider Application for OHCDS designation.
- Step 2: Apply for Adult Day Care Center license (if facility-based) via OIG.
- Step 3: OIG conducts initial facility inspection within 45 days of application.
- Step 4: Submit Medicaid enrollment application to Conduent via the web portal.
- Step 5: DPHHS approves procedure codes and activates the Provider Charge File in MMIS.
10. Common Denials and Survey Findings
Applications are frequently delayed or denied if the agency fails to secure OHCDS designation or attempts to enroll without the required DDP contract. Facility licensure delays often stem from life safety code violations or incomplete policy manuals.
During unannounced surveys, common citations include failure to document community integration activities in accordance with the HCBS Settings Rule and lapsed staff CPR/First Aid certifications.
- OHCDS Failure: Application rejected because the provider is not an OHCDS and lacks a subcontract.
- Settings Rule Violations: Facilities cited for institutional characteristics or lack of community access.
- Background Check Gaps: Staff providing services before criminal history checks are fully cleared.
- Documentation Deficiencies: Daily logs failing to align with the goals in the Person-Centered Plan of Care.
- Life Safety Code: Facility licensure delayed due to inadequate fire prevention or evacuation drill documentation.
11. Key Contacts and Resources
Prospective providers should begin by contacting their regional DDP office to discuss the OHCDS application process and current waiver funding availability. The DPHHS website hosts all necessary administrative rules and policy manuals.
For Medicaid enrollment technical assistance, providers must contact Conduent provider relations.
- DPHHS BHDD: Main division overseeing developmental disabilities (https://dphhs.mt.gov/bhdd).
- DDP Provider Process: Application instructions and OHCDS details (https://dphhs.mt.gov/BHDD/DisabilityServices/developmentaldisabilities/ddpproviderprocess/becomingqualifiedprovider).
- OIG Licensure Bureau: For Adult Day Care Center licensing packets (https://dphhs.mt.gov/qad/Licensure/HealthCareFacilityLicensure).
- Montana Access to Health (Conduent): Medicaid enrollment portal (https://medicaidprovider.mt.gov).
- Administrative Rules of Montana (ARM): Chapter 37.34 for DDP rules (http://www.mtrules.org).
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