Montana - Personal Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Montana’s Department of Public Health and Human Services (DPHHS) administers Personal Assistance Services (PAS) through the Community First Choice (CFC) state plan option and 1915(c) waivers like the Big Sky Waiver and SDMI HCBS. The state is currently transitioning the nomenclature of these programs to Community First Choice Services and Personal Care Services (CFCS/PCS) to align with federal naming conventions.

Prospective agencies must incorporate as a business under Montana law, secure commercial insurance, and pass the DPHHS Provider Self-Assessment (PSA) prior to receiving a Medicaid provider ID. Because Montana does not issue a standalone facility license for non-medical personal care agencies through its Licensure Bureau, the Medicaid enrollment and DPHHS program certification process serves as the primary regulatory gate for new providers.

1. Service Definition and Scope

In Montana, Personal Assistance Services (PAS) provide hands-on assistance with activities of daily living, including bathing, dressing, transferring, and toileting in the member's residence. The service is designed to keep eligible beneficiaries in their own homes and communities rather than institutional settings.

The baseline CFC/PAS program covers standard in-home needs, while waiver programs authorize additional hours or specialized tasks. The service explicitly excludes non-essential shopping, pet care, general transportation, and major household repairs.

• State Plan Authority: Authorized under Section 1915(k) Community First Choice and Section 1905(a).
• Waiver Authority: Additional hours and community supervision are authorized under the 1915(c) Big Sky Waiver and SDMI HCBS 360.
• Baseline Limits: The standard CFC/PAS benefit is generally limited to 42 weekly hours.
• Extended Services: Waiver authorizations are required for hours exceeding the 42-hour limit or for assistance outside the member's residence.

2. Regulatory and Oversight Agencies

Oversight of PAS providers in Montana is divided between the program administration bureaus and the state's program integrity units. DPHHS serves as the umbrella agency for all Medicaid HCBS operations.

Provider enrollment is managed centrally, while quality assurance and fraud prevention are handled by the Office of Inspector General.

• Operating Agency: DPHHS Community Services Bureau (https://dphhs.mt.gov/SLTC/csb/) manages waiver policy and program rules.
• Program Integrity: DPHHS Office of Inspector General Surveillance and Utilization Review Section (SURS) (https://dphhs.mt.gov) conducts focused program integrity reviews.
• Medicaid Enrollment: Montana Healthcare Programs Provider Enrollment (https://medicaidprovider.mt.gov/providerenrollment) processes all NPI and application data.
• Assessment Entity: Mountain Pacific Quality Health (https://www.mpqhf.org) handles referrals and documented need assessments for the Big Sky Waiver.

3. Gatekeeping Prerequisites: Who Can Even Apply

Montana operates an open enrollment model for Personal Assistance Services providers. There is no Certificate of Need (CON) program, Request for Proposals (RFP) procurement, or closed network moratorium blocking new agencies from applying.

However, structural prerequisites exist at the corporate level. An applicant must establish a legal business entity in the state and secure appropriate commercial insurance before the Medicaid enrollment application will be accepted.

• Corporate Status: Applicants must be businesses incorporated under the laws of the state of Montana.
• Certificate of Need: Genuinely none exists for non-medical personal care agencies in Montana.
• Network Access: Open enrollment; no managed care contracting or RFP award is required to submit an application.
• Insurance Requirement: Agencies must be properly insured to provide personal care services prior to enrollment.

4. Licensure and Certification Requirements

Montana does not license non-medical personal care agencies through the DPHHS Licensure Bureau of the Quality Assurance Division, which typically handles assisted living and health care facilities. Instead, agencies achieve authority to operate by meeting DPHHS provider requirements and enrolling directly in Medicaid.

To ensure compliance with HCBS settings and operational rules, new providers must complete a self-assessment process during their initial onboarding.

• Facility License: Not required; Montana does not issue a distinct facility license for PAS agencies.
• Program Certification: Providers must meet the requirements outlined in the SDMI HCBS 360 and Big Sky Waiver manuals.
• Provider Self-Assessment (PSA): New providers must complete a PSA during their initial enrollment to verify operational readiness.
• NPI Requirement: Agencies must obtain an active National Provider Identifier (NPI) via NPPES prior to submitting state applications.

5. Medicaid Provider Enrollment

All PAS agencies must enroll as Montana Healthcare Programs providers to bill for services. The process is entirely digital and requires strict alignment between the agency's federal tax information and state records.

If an agency is purchasing an existing business with an active NPI, a completely new application is required if the tax ID information changes.

• Enrollment Portal: Applications are submitted through the Provider Services Portal (https://portal.mt.healthinteractive.net/icapPortal/).
• Database Checks: The state verifies ownership and managing employees against LEIE, SAM, SSA-DMF, and NPPES upon enrollment.
• Site Visits: Mandatory site visits may be required depending on the specific provider type classification and risk level.
• Tax ID Alignment: Claims cannot be processed until enrollment is complete and NPPES data perfectly matches the state application.

6. Staffing, Training and Background Checks

Agency-based PCS requires the enrolled provider to supply oversight, management, and supervision of all direct care workers. The agency is strictly liable for ensuring all staff meet federal and state background requirements.

CMS regulations mandate ongoing exclusion checks to ensure no federal funds are paid to excluded individuals.

• Exclusion Screening: Agencies must check staff against the HHS-OIG LEIE and SAM databases no less frequently than monthly.
• Background Checks: Required for all direct care staff prior to providing hands-on assistance to members.
• Training: Staff must meet the training requirements designated by DPHHS for personal care aides.
• Supervision: The agency must maintain documented oversight of aides delivering services in the community.

7. Documentation, Policies and Records

Providers must maintain comprehensive records to survive SURS audits and federal program integrity reviews. Documentation must prove that services were delivered exactly as authorized by the member's care plan.

Policies must clearly delineate between standard state plan tasks and specialized waiver tasks.

• Service Plans: Delivery must align with the documented need authorized by the Quality Improvement Organization.
• Timesheets: Must capture exact start and stop times to justify billing against weekly hour limits.
• Policy Manual: Must include procedures for monthly exclusion checks, incident reporting, and supervision.
• Record Retention: Records must be maintained and made available for DPHHS and CMS program integrity reviews.

8. Billing, Rates and Claims

PAS claims are processed through the Montana Healthcare Programs MMIS. Providers are responsible for verifying member eligibility and checking the current fee schedule prior to delivering services.

Because PAS spans both state plan and waiver authorities, agencies must ensure they are billing the correct procedure codes based on the member's specific authorization.

• Billing System: Claims are submitted electronically via the Provider Services Portal.
• Hour Limits: Billing under standard CFC/PAS cannot exceed 42 hours weekly without a specific waiver authorization.
• Fee Schedule: Rates are published online by Montana Healthcare Programs and updated regularly.
• Manuals: Providers must reference the online Comprehensive Waiver Provider Manual for current billing rules.

9. Approval Sequence and Timeline

The pathway to becoming a billable PAS provider in Montana follows a linear sequence, starting with corporate formation and ending with portal registration.

Because there is no separate facility licensure step, the timeline is dictated primarily by the Medicaid enrollment processing queue and the completion of the Provider Self-Assessment.

• Step 1: Incorporate the business under Montana law and obtain commercial liability insurance.
• Step 2: Secure an NPI from the federal NPPES system.
• Step 3: Submit the Medicaid provider enrollment application and complete the Provider Self-Assessment (PSA).
• Step 4: Register for the Provider Services Portal and link the approved provider ID to begin billing.

10. Common Denials and Survey Findings

The DPHHS Surveillance and Utilization Review Section (SURS) and CMS conduct focused program integrity reviews on PCS providers. Findings frequently center on administrative oversights rather than care quality.

Failure to maintain strict separation between state plan hours and waiver hours is a primary source of recoupment.

• Exclusion Checks: Failure to conduct and document monthly LEIE and SAM checks for all managing employees and aides.
• Overbilling: Submitting claims exceeding the 42-hour CFC limit without a documented Quality Improvement Organization authorization.
• Tax ID Mismatches: Claim denials caused by purchasing an existing NPI without updating the tax ID with Provider Relations.
• Documentation: Missing timesheets or lack of evidence showing agency supervision of the direct care worker.

11. Key Contacts and Resources

Providers must rely on official DPHHS and Montana Healthcare Programs portals for current manuals, fee schedules, and policy updates.

Regional Program Officers are available to assist with policy clarification and waiver referral questions.

• Montana Healthcare Programs Provider Enrollment: https://medicaidprovider.mt.gov/providerenrollment
• Provider Services Portal: https://portal.mt.healthinteractive.net/icapPortal/
• DPHHS Community Services Bureau: https://dphhs.mt.gov/SLTC/csb/
• Mountain Pacific Quality Health (Referrals): 1-800-219-7035

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