Montana - Transitional Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Montana Department of Public Health and Human Services (DPHHS) funds Community Transition Services through the Big Sky Waiver and the Severe Disabling Mental Illness (SDMI) Waiver to cover one-time set-up expenses for members leaving institutions. Providers must enroll under Provider Type 28 (HCBS) and coordinate directly with regional Case Management Teams (CMT) to facilitate these transitions.
Approval requires submitting a complete enrollment application through the Montana Access to Health ICAP portal and securing an active service authorization from a CMT before any transition expenses are incurred. Montana does not require a Certificate of Need for this service, but providers cannot bill for transition costs without prior authorization documented in the member's person-centered service plan.
1. Service Definition and Scope
Community Transition Services in Montana cover non-recurring set-up expenses for individuals transitioning from an institutional or another provider-operated living arrangement to a living arrangement in a private residence where the person is directly responsible for their own living expenses. This service is available under the Big Sky Waiver and the SDMI Waiver.
Allowable expenses include security deposits, essential household furnishings, set-up fees or deposits for utility or service access, and services necessary for the individual's health and safety such as pest eradication and one-time cleaning prior to occupancy.
- Covered Expense: Security deposits required to obtain a lease on an apartment or home
- Covered Expense: Essential household furnishings required to occupy and use a community domicile
- Covered Expense: Set-up fees or deposits for utility or service access, including telephone, electricity, and heating
- Covered Expense: Health and safety services such as pest eradication and one-time cleaning prior to occupancy
- Exclusion: Monthly rental or mortgage expenses
- Exclusion: Food, regular utility charges, and household appliances or items intended for diversion or recreational purposes
2. Regulatory and Oversight Agencies
The Montana Department of Public Health and Human Services (DPHHS) oversees the administration of HCBS waivers. The Senior and Long Term Care (SLTC) Division manages the Big Sky Waiver, while the Behavioral Health and Developmental Disabilities (BHDD) Division manages the SDMI Waiver.
Provider enrollment and claims processing are managed by the state's fiscal agent, Conduent, through the Montana Access to Health web portal.
- Oversight Agency: Montana DPHHS Senior and Long Term Care (SLTC) Division (https://dphhs.mt.gov/sltc/)
- Oversight Agency: Montana DPHHS Behavioral Health and Developmental Disabilities (BHDD) Division (https://dphhs.mt.gov/bhdd/)
- Enrollment Portal: Montana Access to Health ICAP Portal (https://portal.mt.healthinteractive.net/icapPortal/)
- Fiscal Agent: Conduent (https://mtaccesstohealth.portal.conduent.com/mt/general/providerEnrollmentHome.do)
3. Gatekeeping Prerequisites: Who Can Even Apply
Montana does not require a Certificate of Need (CON) or a competitive procurement (RFP) process to become a Community Transition Services provider. However, an applicant must be legally authorized to conduct business in Montana and must be capable of purchasing and invoicing the allowable transition goods and services.
The structural precondition for delivering this service is authorization from a designated Case Management Team (CMT). A provider cannot independently initiate this service; they must receive a referral and prior authorization from the CMT managing the transitioning member's care plan.
- Prerequisite: Registration with the Montana Secretary of State to conduct business
- Prerequisite: Acquisition of a National Provider Identifier (NPI) and Employer Identification Number (EIN)
- Gatekeeper: Regional Case Management Teams (CMT) must authorize the service in the person-centered plan
- Restriction: No Certificate of Need (CON) is required for this specific service type
- Restriction: Providers cannot bill for services not explicitly authorized by the CMT prior to the transition
4. Licensure and Certification Requirements
Montana does not issue a specific facility or agency license for entities that solely provide Community Transition Services, as this is primarily an administrative and purchasing function rather than direct medical care. Providers must instead meet the general qualifications for HCBS waiver providers.
Providers must maintain standard business credentials, including general liability insurance, and must agree to the terms of the Montana Medicaid Provider Agreement.
- Requirement: Active business registration with the Montana Secretary of State
- Requirement: General liability insurance meeting state minimums
- Requirement: Compliance with the HCBS Settings Rule for any provider-owned or controlled settings
- Requirement: Signed Montana Medicaid Provider Agreement
5. Medicaid Provider Enrollment
Prospective providers must submit a full enrollment application through the Montana Access to Health ICAP portal. The provider must enroll using Provider Type 28 (HCBS) to be eligible to bill for waiver services.
All status changes, such as changes in ownership, address, or licensure, must be immediately reported to the fiscal agent. Providers are also subject to periodic revalidation requirements to maintain active billing status.
- System: Montana Access to Health ICAP Portal
- Provider Type: HCBS code 28
- Requirement: Submission of W-9 and IRS Tax Identification Letter
- Requirement: Completion of the Electronic Funds Transfer (EFT) Authorization Agreement
- Maintenance: Revalidation required every 3 to 5 years depending on risk category
6. Staffing, Training and Background Checks
Because Community Transition Services often involve purchasing and coordinating logistics rather than providing direct hands-on personal care, the staffing requirements focus on administrative competence and financial integrity. However, any staff member who has direct contact with waiver participants must pass background checks.
Providers must ensure that no staff or subcontractors are on the OIG List of Excluded Individuals/Entities (LEIE).
- Requirement: Criminal background checks for staff with direct participant contact
- Requirement: Monthly screening against the OIG LEIE and state exclusion lists
- Requirement: Staff must be trained on the specific billing and documentation requirements of the waiver
- Requirement: Maintenance of a roster of authorized personnel handling transition funds
7. Documentation, Policies and Records
Providers must maintain exhaustive financial records for all transition expenses. This includes original receipts, invoices, and proof of payment for every item or deposit funded through the service.
Documentation must clearly link the purchased items to the authorized service plan provided by the CMT. Records must be retained for a minimum of five years and be available for audit by DPHHS or its designees.
- Record: Original receipts and invoices for all purchased goods and services
- Record: Copy of the CMT prior authorization and person-centered service plan
- Record: Proof of delivery or installation of items at the participant's new residence
- Policy: Financial tracking policy to ensure expenses do not exceed the authorized cap
- Retention: All records must be kept for at least five years from the date of service
8. Billing, Rates and Claims
Community Transition Services are billed using specific HCPCS procedure codes designated by DPHHS in the HCBS fee schedule. Reimbursement is strictly limited to the actual cost of the authorized items and deposits, up to the lifetime or per-transition cap established by the waiver.
Claims must be submitted electronically through the Montana Access to Health portal. Providers cannot bill for administrative markup or time spent shopping for items unless explicitly allowed by the current fee schedule.
- Code: HCPCS code specified in the current DPHHS HCBS fee schedule
- Limit: Reimbursement is capped at the maximum amount authorized in the service plan
- Requirement: Prior authorization number must be included on the claim
- Method: Electronic claim submission via the ICAP portal
- Restriction: No markup on goods or deposits is permitted
9. Approval Sequence and Timeline
The approval process begins with the submission of the provider enrollment application via the ICAP portal. The fiscal agent reviews the application for completeness and verifies all business credentials.
Once the fiscal agent completes the initial screening, the application is forwarded to DPHHS for final approval and assignment of procedure codes. The entire process typically takes 30 to 60 days, provided all documentation is accurate.
- Step 1: Register business entity and obtain NPI/EIN
- Step 2: Submit Provider Type 28 application via ICAP portal
- Step 3: Fiscal agent screening and credential verification
- Step 4: DPHHS final approval and rate assignment
- Timeline: Approximately 30 to 60 days for standard processing
10. Common Denials and Survey Findings
Enrollment applications are frequently delayed or denied if the provider selects the wrong enrollment type or fails to provide matching IRS documentation for their Tax ID. Sharing a tax ID improperly between individual and organizational NPIs will trigger automatic denials.
During audits, the most common finding for transition services is the lack of original receipts or purchasing items that were not explicitly authorized in the member's service plan, resulting in recoupment of funds.
- Denial Reason: Selecting an incorrect provider type instead of HCBS Type 28
- Denial Reason: Mismatch between IRS Tax ID letter and application details
- Audit Finding: Missing original receipts for reimbursed expenses
- Audit Finding: Billing for items not authorized by the CMT
- Audit Finding: Failure to complete revalidation within the required timeframe
11. Key Contacts and Resources
Providers should utilize the Montana Access to Health portal for all enrollment and billing inquiries. The DPHHS website hosts the official waiver manuals, fee schedules, and provider notices.
For specific questions regarding service authorizations, providers must contact the regional Case Management Team assigned to the member.
- Resource: Montana Medicaid Provider Enrollment (https://medicaidprovider.mt.gov/providerenrollment)
- Resource: Montana Access to Health Portal (https://mtaccesstohealth.portal.conduent.com/mt/general/providerEnrollmentHome.do)
- Resource: DPHHS HCBS Settings Information (https://dphhs.mt.gov/hcbs/)
- Contact: Conduent Provider Relations Help Desk for enrollment status
- Resource: SDMI HCBS Waiver Manual (https://dphhs.mt.gov/bhdd/)
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