Montana - Housing Stabilization — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Montana's Tenancy Supports service funds housing search, landlord mediation, and retention planning for Medicaid recipients diagnosed with a severe mental illness or substance-use disorder. The Montana Department of Public Health and Human Services (DPHHS) administers this service as part of its behavioral health continuum, requiring providers to operate under an established behavioral health or community agency framework rather than a standalone housing license.

Approval requires submitting a complete application through the state's ICAP portal after securing the underlying agency licensure or certification. Applicants must establish billing-to-rendering provider affiliations within the portal prior to delivering services, as claims submitted without these pre-established links are automatically rejected by the Montana Healthcare Programs system.

1. Service Definition and Scope

In Montana, Tenancy Supports is defined as a targeted intervention to help individuals with behavioral health needs secure and maintain stable housing. The service bridges the gap between clinical treatment and community living by addressing the social determinants of health.

The scope of the service is strictly limited to tenancy-related assistance and does not cover the cost of room and board. Providers act as liaisons between the Medicaid member, landlords, and property managers to prevent eviction and ensure housing stability.

• Target Population: Medicaid recipients with a diagnosed severe mental illness (SMI) or substance-use disorder (SUD).
• Housing Search: Assisting members with locating available units, completing rental applications, and understanding lease terms.
• Landlord Mediation: Intervening during disputes between the member and the landlord to negotiate solutions and prevent eviction.
• Retention Planning: Developing individualized plans that identify risks to housing stability and outlining strategies to mitigate them.
• Excluded Costs: Medicaid funds cannot be used to pay for rent, utility deposits, or direct room and board expenses.
• Service Setting: Delivered in the community, at the member's prospective or current residence, or in an agency office.

2. Regulatory and Oversight Agencies

The Montana Department of Public Health and Human Services (DPHHS) is the primary regulatory authority overseeing Medicaid behavioral health and HCBS programs. DPHHS manages provider enrollment, sets policy, and conducts compliance audits.

Provider enrollment and claims processing are managed through the state's fiscal agent portal, which transitioned to a single sign-on system called ICAP. Providers must interact with both DPHHS for policy compliance and the ICAP portal for financial and enrollment transactions.

• Montana Department of Public Health and Human Services (DPHHS): Oversees program rules and waiver administration (https://dphhs.mt.gov).
• Montana Healthcare Programs Provider Information: Hosts provider manuals, fee schedules, and enrollment forms (https://medicaidprovider.mt.gov).
• ICAP Provider Portal: The mandatory single sign-on system for enrollment, revalidation, and claims (https://portal.mt.healthinteractive.net/icapPortal/).
• Provider Relations: Manages enrollment support and application processing (https://medicaidprovider.mt.gov/providerenrollment).

3. Gatekeeping Prerequisites: Who Can Even Apply

Montana does not require a Certificate of Need (CON) for Tenancy Supports, nor does it restrict enrollment to a closed network or specific Request for Proposals (RFP) procurement window. However, structural prerequisites exist regarding the type of entity that can bill for these services.

Because Tenancy Supports is integrated into behavioral health programming, an applicant must typically be an established entity capable of serving the SMI/SUD population. There is no standalone "Tenancy Supports" agency type; the service must be attached to an eligible Medicaid provider type.

• Entity Type: Must be a legally formed business entity registered with the Montana Secretary of State.
• National Provider Identifier (NPI): Must obtain an active NPI through NPPES before initiating the state enrollment process.
• Underlying Licensure: Must hold the appropriate facility or agency licensure/certification required by DPHHS for the primary behavioral health or community service provided.
• Waiver Specificity: Each waiver program a provider intends to deliver services under requires its own distinct enrollment.
• Out-of-State Restriction: Out-of-state providers must enroll directly with Montana Medicaid; enrollment in another state's Medicaid program does not transfer.

4. Licensure and Certification Requirements

Montana does not issue a distinct, standalone license specifically for "Tenancy Supports." Instead, providers must meet the licensure or certification standards applicable to their broader agency type, such as a licensed mental health center or a certified community behavioral health clinic.

Providers must maintain their underlying professional licenses and board certifications in active status. Any lapse in the primary agency license will result in the suspension of Medicaid billing privileges for all associated services, including Tenancy Supports.

• Agency Licensure: Must maintain current DPHHS licensure appropriate to the facility or agency type delivering the behavioral health services.
• Professional Licensing: All rendering staff must hold current, valid Montana licenses or certifications for their specific disciplines, if applicable.
• License Maintenance: Copies of current licenses must be uploaded and maintained in the ICAP portal.
• Date Span Matching: License effective dates in the portal must span the dates of service for claims to process successfully.

5. Medicaid Provider Enrollment

Provider enrollment is conducted entirely online through the ICAP portal. As of April 2026, every provider who orders, refers, or prescribes for Montana Healthcare Programs members must enroll under 42 CFR 455.410.

A complete application requires specific documentation, and missing any single document triggers a deficiency notice that restarts the 30-working-day processing clock. Providers must select the correct enrollment type (e.g., Group or Facility) based on their taxonomy and organizational structure.

• Application Portal: Submitted via the ICAP system at portal.mt.healthinteractive.net/icapPortal/.
• Provider Enrollment Agreement: A required fillable PDF submitted alongside the core application.
• W-9 Form: The legal name and EIN must exactly match the provider's IRS tax identification verification letter.
• EFT Authorization Agreement: Required for all pay-to providers; must include a street address with ZIP+4 (PO Boxes are rejected).
• Disclosures Form: Must complete the ownership and controlling-interest disclosures and screening consent PDF.
• Medicare Attestation: Must complete the "Not Enrolled with Medicare Provider Attestation" if applicable to dual-eligible claims.

6. Staffing, Training and Background Checks

Staff delivering Tenancy Supports must meet DPHHS qualifications for working with individuals diagnosed with severe mental illness or substance-use disorders. Agencies are responsible for verifying staff credentials prior to service delivery.

Comprehensive background checks are mandatory for all personnel with direct member contact. Training must cover behavioral health competencies, crisis intervention, and the specific components of housing retention planning.

• Background Checks: Mandatory state and federal criminal history background checks for all direct-care staff.
• OIG Exclusion List: Agencies must verify staff are not on the federal OIG List of Excluded Individuals/Entities (LEIE) prior to hire and monthly thereafter.
• Behavioral Health Competency: Staff must possess documented training or experience in working with SMI and SUD populations.
• Housing Training: Staff must be trained in local housing markets, tenant rights, and lease negotiation strategies.
• Training Records: Agencies must maintain auditable personnel files containing certificates of completed mandatory training.

7. Documentation, Policies and Records

Providers must maintain comprehensive records that justify the billing of Tenancy Supports. Documentation must clearly link the housing intervention to the member's behavioral health treatment goals.

DPHHS requires customized policy manuals that dictate how the agency handles incident reporting, member rights, and service planning. Progress notes must be contemporaneous and detail the specific housing-related activities performed.

• Tenancy Support Plan: A documented, individualized plan identifying housing barriers and specific retention strategies.
• Progress Notes: Must include the date, start and end times, specific activities performed, and the signature of the rendering staff.
• Lease Documentation: Copies of lease agreements or rental applications assisted with must be kept in the member's file.
• Incident Reporting Policy: Written procedures for reporting critical incidents to DPHHS within required timeframes.
• Record Retention: All clinical and financial records must be retained for the period specified by Montana Medicaid rules (typically 5-7 years).

8. Billing, Rates and Claims

Claims for Tenancy Supports are submitted electronically through the ICAP portal or via an approved clearinghouse. Providers must establish billing-to-rendering affiliations within the portal before the claims system will accept submissions.

Reimbursement rates are established by DPHHS and published on the Montana Healthcare Programs fee schedule. Claims will suspend—halting all revenue—if a provider fails to complete mandatory revalidation or if EFT data becomes invalid.

• Claims System: Processed through the Montana Healthcare Programs (MTHCS) system via the ICAP portal.
• Affiliations: Billing-to-rendering provider relationships must be actively linked in ICAP; missing affiliations cause automatic claim rejection.
• Fee Schedule: Rates are published on the medicaidprovider.mt.gov website under the specific behavioral health or waiver program.
• Revalidation: Providers must revalidate enrollment every 3 to 5 years; failure results in total claims suspension.
• EFT Maintenance: Invalid Electronic Funds Transfer data will cause the state to hold payments until corrected.

9. Approval Sequence and Timeline

The pathway to becoming a billable provider follows a strict sequence: entity formation, obtaining underlying agency licensure, securing an NPI, and finally submitting the Medicaid enrollment application. Attempting to enroll in Medicaid before securing the necessary DPHHS agency license will result in immediate rejection.

Once a complete application is submitted through the ICAP portal, DPHHS Provider Relations typically processes it within 30 working days. Any missing documentation resets this clock to day one upon correction.

• Step 1: Entity Formation: Register the business with the Montana Secretary of State and obtain an IRS EIN.
• Step 2: Agency Licensure: Secure the required behavioral health or community agency license from DPHHS.
• Step 3: NPI Registration: Obtain a National Provider Identifier via the NPPES system.
• Step 4: ICAP Submission: Submit the complete enrollment application and all required PDFs through the ICAP portal.
• Step 5: Processing Window: Allow 30 working days for Provider Relations to issue a written approval or denial.
• Step 6: Affiliation Setup: Establish billing-to-rendering links in the Provider Services Workbench before submitting the first claim.

10. Common Denials and Survey Findings

Enrollment applications are frequently delayed or denied due to administrative errors rather than programmatic deficiencies. The most common barrier is submitting an application with missing supplemental forms or mismatched tax information.

During compliance surveys, auditors frequently cite providers for failing to maintain active affiliations in the portal or allowing staff licenses to expire. A suspension of claims is the standard state response to lapsed credentials or missed revalidation deadlines.

• Mismatched W-9: Application denied because the legal name or EIN does not perfectly match the IRS verification letter.
• Missing Affiliations: Claims rejected because the rendering provider was not linked to the billing entity in the ICAP portal.
• Deficient EFT Form: Payment holds triggered by using a PO Box instead of a physical street address with ZIP+4 on the EFT agreement.
• Expired Licenses: Claims suspended because the professional license dates in the portal do not cover the date of service.
• Missed Revalidation: Total revenue interruption caused by failing to complete the 3-to-5-year revalidation process on time.
• Signature Errors: Applications rejected for using stamped or copied signatures instead of original or valid digital signatures.

11. Key Contacts and Resources

Providers must rely on official DPHHS and Montana Healthcare Programs resources for current forms, fee schedules, and portal access. The Provider Relations unit is the primary point of contact for enrollment status inquiries.

Maintaining access to the ICAP portal is critical, as it is the sole mechanism for updating licenses, managing affiliations, and responding to revalidation notices.

• Montana DPHHS: Official state agency homepage (https://dphhs.mt.gov).
• Montana Healthcare Programs Provider Information: Source for manuals and forms (https://medicaidprovider.mt.gov).
• ICAP Portal: The mandatory system for enrollment and claims (https://portal.mt.healthinteractive.net/icapPortal/).
• Provider Enrollment Page: Guidelines and document checklists (https://medicaidprovider.mt.gov/providerenrollment).
• Provider Relations Phone: 800-624-3958 (Option 7, then Option 4 for Enrollment Support).
• Provider Enrollment Email: [email protected] for status inquiries if the 30-day window passes without an update.

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