How to start a home care agency in Montana and reach your first client faster
Montana does not license nonmedical home care agencies, so new owners expect a quick start. Private pay can be quick. Medicaid is where the work is: Community First Choice enrollment as provider type 12, insurance at state minimums, a licensed nurse supervisor, 16 hours of training for every attendant, onsite visits and electronic visit verification all come before your first Medicaid shift. Home health and hospice add a DPHHS license and Medicare. We put all of it in the right order for you.
- Guides reviewed by Christine Ochimas, RN, LMFT, MBA
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- Christine OchimasRN, LMFT, MBA
- All three care typesNonmedical, home health, hospice
- Written to Montana rulesARM 37.40 Subchapter 10 and the DPHHS CFCS/PCS Agency Based Policy Manual
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Updated November 2026 · Reviewed by Christine Ochimas, RN, LMFT, MBA
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Nonmedical home care for Community First Choice members
- State license
- None for nonmedical care; Montana Medicaid enrollment as a CFCS/PCS provider (provider type 12) under ARM 37.40.1013 instead
- Who you deal with
- DPHHS Senior and Long-Term Care Division, Community Services Bureau, and Montana Medicaid provider enrollment
- Must haves
- Montana business entity, service area of at least one county or reservation, insurance at ARM 37.40.1013 minimums, DPHHS mandatory CFCS training, onsite visits, licensed nurse supervisor, 16 hour attendant training, EVV
- Realistic time to first client
- Several months
Orientation for Montana only. We confirm your exact path on the free call.
Three places new Montana agencies lose months
Each one keeps you paying rent, insurance and payroll while no clients arrive.
Treating no license as no rules
Montana has no nonmedical home care license, so owners open for private pay and assume Medicaid will be a quick add on. It is not. ARM 37.40.1013 sets insurance minimums, DPHHS training, onsite visits before and after enrollment, and a service area that covers at least one whole county or reservation.
What it costs: Months of payroll and rent before the first Medicaid shift if enrollment starts late.
No nurse supervisor, no Medicaid program
Agency based Community First Choice requires a licensed nurse supervisor with at least a year of aging and disability experience, plus a certified plan facilitator. The nurse oversees intake visits, service plans and every attendant's training. In rural Montana, finding that nurse is often the slowest step.
What it costs: Approved members you cannot serve because no one can sign their service plans.
Caregivers who cannot start yet
An attendant cannot deliver CFCS/PCS until they finish 16 hours of basic training overseen by a licensed nurse and pass a competency check, unless their training is waived under DPHHS policy. Every visit must then be captured in EVV, including live in caregivers, or the claim is denied.
What it costs: A client you cannot staff this week and claims that bounce back unpaid.
What does a delay cost your agency?
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Home care vs home health vs hospice in Montana
The three sound alike and are regulated differently. The one you choose decides your regulator, staffing, startup capital and timeline.
| Topic | Nonmedical home care | Home health (skilled) | Hospice |
|---|---|---|---|
| What your staff do | Personal care, help with daily activities, light housekeeping, medical escort; private pay may add companionship | Skilled nursing and at least one other therapeutic service in the patient's home | Palliative and supportive care for people who are terminally ill, with a formal bereavement program |
| State license | None | DPHHS home health agency license (ARM 37.106.1505) | DPHHS hospice program license (ARM 37.106.2301) |
| Certificate of Need | No | No Certificate of Need review | No Certificate of Need review |
| Main payers | Private pay, Community First Choice and Personal Care Services, Big Sky Waiver services | Medicare, Montana Medicaid (Medicare certification required), commercial insurance | Medicare hospice benefit, Montana Medicaid, private insurance |
| Medicare | Not covered | Accreditation or state survey, then Medicare enrollment (new enrollments paused from May 13, 2026) | Accreditation or state survey, then Medicare enrollment (new enrollments paused from May 13, 2026) |
| Key staff | Licensed nurse supervisor and plan facilitator for Medicaid; trained personal care attendants | Administrator, clinical manager, registered nurses and therapy staff, trained home health aides | Administrator, interdisciplinary team with physician, nursing, counseling and trained volunteers |
| Startup capital | Lowest | Higher: clinical payroll before Medicare revenue | Highest: interdisciplinary team before revenue |
| Time to first client | Weeks (private pay) to months (Community First Choice) | Longest: licensure, survey, enrollment | Longest: licensure, survey, enrollment |
Many Montana owners start with nonmedical care, build cash flow and a caregiver team, then add home health. Montana's home health license rule adopts the Medicare Conditions of Participation (42 CFR Part 484) as the state standard, so a licensed agency is already built to the federal rules when it seeks Medicare certification. We plan both from day one so your policies and hiring grow with you instead of being rewritten.
Montana requirements at a glance
| Nonmedical home care license | None at the state level. Montana Medicaid enrollment as a CFCS/PCS provider (provider type 12) is required to serve Medicaid members. |
|---|---|
| Home health and hospice licensing | DPHHS Office of Inspector General, Licensure Bureau, under MCA Title 50, Chapter 5 and ARM Title 37, Chapter 106 (home health ARM 37.106.1505, hospice ARM 37.106.2301) |
| Certificate of Need | Not required for home health or hospice; Montana's CON law (MCA 50-5-301) covers long term care facilities |
| Medicaid home care program | Community First Choice Services and Personal Care Services (formerly CFC/PAS), a state plan entitlement with no waiting list; Big Sky Waiver services have a waiting list |
| Program agency | DPHHS Senior and Long-Term Care Division, Community Services Bureau; Mountain Pacific assesses members and authorizes hours |
| Caregiver training | 16 hours of basic training overseen by a licensed nurse, with a competency evaluation, before the first shift; eight hours of in service training a year |
| Insurance for Medicaid providers | General liability of $1,000,000 per occurrence and $2,000,000 aggregate, motor vehicle liability at ARM 37.40.1013 limits, unemployment insurance and workers' compensation |
| Electronic visit verification | Required for CFCS/PCS, Big Sky Waiver personal care and home health visits, including live in caregivers. The state system, Netsmart Mobile Caregiver+, is free to providers. |
| Medicare (home health, hospice) | Accreditation by a CMS approved organization or a survey by the DPHHS Certification Bureau, then Medicare enrollment |
| Entity filing | Montana Secretary of State; Medicaid providers must be formed or registered to do business under Montana law |
Summary of Montana requirements as of November 2026. Rules change; confirm with each agency before filing.
Step by step: launching a home care agency in Montana
The order matters. Hire your nurse supervisor and start attendant training before you apply to Montana Medicaid, because enrollment includes onsite visits and members can only choose an agency that is ready to staff them.
Form the business in Montana
File your LLC or corporation with the Montana Secretary of State, or register an out of state entity to do business in Montana. Get an EIN, register for state payroll withholding and for unemployment insurance with the Department of Labor and Industry, and check your city or county license rules.
You do this; we give you the checklistDecide your payer mix
Private pay, Community First Choice and Personal Care Services, Big Sky Waiver services, or a mix. CFCS/PCS is an entitlement with no waiting list. The Big Sky Waiver has a waiting list, so referrals depend on openings. Use the path finder above.
Decided on your free consultationBuy insurance to the Medicaid minimums
ARM 37.40.1013 requires general liability of $1,000,000 per occurrence and $2,000,000 aggregate, motor vehicle liability of $500,000 per person and $1,000,000 per accident for injury plus $100,000 property damage (or $1,000,000 combined), and current unemployment insurance and workers' compensation. DPHHS checks coverage every April.
You do this; we specify what is requiredHire your nurse supervisor and plan facilitator
Agency based providers need a licensed nurse supervisor with at least one year of aging and disability experience, and a plan facilitator certified in person centered planning. One person can hold both roles. Both must meet DPHHS conflict of interest rules.
You do this; we specify what is requiredWrite policies to the DPHHS policy manual
Adopt policies for intake visits, service plans, attendant training, serious occurrence reports, complaints, conflict of interest, service delivery records and EVV, written to ARM 37.40 Subchapter 10 and the CFCS/PCS Agency Based Policy Manual.
We write this for youBuild the caregiver pipeline
Screen applicants, then give each attendant 16 hours of basic training overseen by a licensed nurse, with a documented competency evaluation, before the first shift. Certified nurse aides and trained home health aides can have basic training waived after a competency check. Track eight hours of in service training every year.
We set up the system and trackerEnroll with Montana Medicaid
Enroll as provider type 12 (CFCS/PCS) through the department's fiscal intermediary, describe a service area covering at least one whole county or reservation, complete DPHHS mandatory CFCS training, choose the agency based option and pass the onsite visit. Revalidate every five years.
We prepare and manage itSet up electronic visit verification
Every CFCS/PCS visit must be captured in EVV, including live in caregivers, and claims are submitted through Netsmart Mobile Caregiver+. The state system is free, or you can use a DPHHS certified alternate system that sends data to Netsmart.
We walk you through setupPrepare for quality assurance reviews
DPHHS reviews agencies every one to three years and expects 90% of sampled cases to meet every standard. Submit your Provider Prepared Standards report by April 1 each year and enter serious occurrence reports within 10 working days.
We get you ready for the survey
Personal care attendant training and screening
For agency based Community First Choice and Personal Care Services, the agency trains and certifies every personal care attendant under its nurse supervisor, following the DPHHS Agency Based Policy Manual. Attendants may not perform skilled tasks; only self directed members can direct health maintenance tasks such as wound care.
- Basic training: 16 hours: Covers orientation, body mechanics and transfers, personal assistance skills, home care, safety, nutrition and meal preparation, record keeping, member rights, communication and basic human needs. It must be overseen by a licensed nurse, be interactive, and end with a competency evaluation.
- Before the first shift: An attendant cannot deliver CFCS/PCS until basic training is complete. Each attendant gets a certificate, and the nurse supervisor signs the training record.
- Waiver of basic training: Allowed when the attendant shows competency and has documented training from another enrolled CFCS/PCS agency, certified nurse aide or home health aide training, or one year as a trained attendant in a licensed community setting. Family caregiver experience does not count.
- In service training: Eight hours every year. New attendants who took the 16 hour course start in their second year; attendants with a waiver start in their first year.
- On the job training: The nurse supervisor provides it as needed and documents each attendant's ability to work safely, including orientation to each member's service plan.
- Background screening: We found no Montana rule that sets a specific criminal background check for CFCS/PCS attendants, so your screening policy decides it. Write one, apply it to every hire, and keep the results in the personnel file.
- Home health aides: Medicare certified agencies follow 42 CFR 484.80: at least 75 hours of classroom and supervised practical training, or a competency evaluation, and 12 hours of in service training a year.
Six mistakes that slow Montana agencies down
We look for every one of these in the first week of an engagement.
Waiting to hire a nurse supervisor
- What it costs
- Without a licensed nurse supervisor, the agency based program cannot run: no intake visits, no service plans, no attendant training sign off.
- How we prevent it
- Your first call sets the hiring order, starting with the nurse supervisor and plan facilitator.
Insurance below the ARM 37.40.1013 minimums
- What it costs
- Enrollment stalls, and DPHHS checks coverage again every April.
- How we prevent it
- We give you the exact limits for general liability, motor vehicle liability, unemployment insurance and workers' compensation.
Scheduling attendants before training is done
- What it costs
- Shifts worked before the 16 hour basic training and competency check can be found in a quality assurance review and lead to repayment.
- How we prevent it
- A tracker that flags basic training, waivers, competency checks and yearly in service hours for every attendant.
Skipping EVV for live in caregivers
- What it costs
- Claims for CFCS/PCS visits without a compliant EVV record are denied, live in or not.
- How we prevent it
- We set up Mobile Caregiver+ or a certified alternate system before your first Medicaid visit, with IVR where coverage is poor.
Billing companionship as CFCS/PCS
- What it costs
- Supervision, companionship, pet care and child care are not covered, so those hours are not payable.
- How we prevent it
- Service definitions and care plans that keep Medicaid hours to covered daily living tasks.
Drifting into skilled care without a license
- What it costs
- Agency attendants may not perform skilled tasks, and skilled home health requires a DPHHS license.
- How we prevent it
- Clear service definitions so nonmedical attendants never perform skilled tasks.
In a free 30 minute call we confirm your Montana path, flag the mistakes that apply to your plan, and give you a fixed price to handle the rest.
Montana launch packages
Three fixed price packages, matched to the path you choose. Your exact price is quoted in writing after your free call, before any work starts.
Private pay launch
For nonmedical agencies serving families who pay privately.
- Montana path and a dated launch plan
- Policy and procedure manual written to ARM 37.40 Subchapter 10 and the DPHHS CFCS/PCS Agency Based Policy Manual
- Service agreement, client rights and care plan forms
- Caregiver hiring and screening workflow
- Google Business Profile setup
Community First Choice ready agency
Everything in Private pay launch, plus the Medicaid route.
- Policies aligned to Community First Choice requirements
- Caregiver training and background check tracker
- Medicaid provider enrollment
- Credentialing packets for Montana Medicaid and the DPHHS Senior and Long-Term Care Division
- Survey and audit readiness
- Montana city pages for local search
Home health and Medicare
For skilled home health. Hospice is scoped separately.
- Staffing and capital timeline
- Policies written to DPHHS rules and the Medicare Conditions of Participation
- License application and inspection readiness
- Accreditation survey preparation
- Medicare and Medicaid enrollment support
Every package: one fixed price agreed in writing · you own 100% of your agency · no franchise fees or royalties.
On your own vs a franchise vs Lunaria
| Topic | On your own | Home care franchise | With Lunaria |
|---|---|---|---|
| Who owns the business | You | You, under the franchisor's brand and rules | You, 100% |
| Ongoing fees | None | Royalties and brand fees, usually a share of revenue | None. One fixed project fee |
| Knowing what Montana requires | Pieced together from manuals and forums | A national playbook, adapted | Confirmed on your first call, then in writing |
| Policy manual | A template, often from another state | The franchisor's standard manual | Written to ARM 37.40 Subchapter 10 and the DPHHS CFCS/PCS Agency Based Policy Manual |
| Medicaid credentialing | One application at a time | Varies by franchisor | Packets for Montana Medicaid and the DPHHS Senior and Long-Term Care Division prepared together |
| Your brand and marketing | Up to you | The franchisor's brand, with territory limits | Your brand, plus local search set up for you |
The Montana home care startup checklist
Every Montana step in order: business setup, your payer path, policies, caregiver screening and training, Medicaid enrollment and getting found. The items to start first are starred.
- Choose your care type and payer mix (private pay, Community First Choice, Big Sky Waiver)
- Form your LLC or corporation with the Montana Secretary of State
- Get an EIN and register for state payroll withholding and unemployment insurance
- Check your city or county business license rules
- Buy workers' compensation, general liability and motor vehicle coverage at ARM 37.40.1013 limits
- and 14 more steps
Christine Ochimas, RN, LMFT, MBA
Christine founded Lunaria Care Consulting to give nurses and caregivers a direct route from "I want my own agency" to a compliant business with clients. She reads state requirements the way a reviewer does and writes policies the way a nurse would actually use them.
- We serve owners in all 50 states and DC, with a plan written for Montana
- We help through enrollment and survey readiness, not just the application
- We tell you what we cannot promise: no one can guarantee a state or health plan decision
Have these ready for your consultation
- The care you want to provide and the clients you want to serve
- The Montana cities or counties you plan to cover
- Where you are now: idea, business formed or already operating
- Who you expect to pay: families, Community First Choice, Medicare
- Your target opening month and rough budget
No client or patient records. We never need them for a first call.
What it costs to start a home care agency in Montana
| Item | Notes |
|---|---|
| State license | None for nonmedical care. Home health agencies and hospices pay a DPHHS license fee with the application; check the current amount with the Licensure Bureau. |
| Entity formation and local licenses | Montana Secretary of State filing fee plus any city or county license |
| Insurance | General liability at $1,000,000 per occurrence and $2,000,000 aggregate, motor vehicle liability at ARM 37.40.1013 limits, workers' compensation |
| Nurse supervisor | Salary or contract time for a licensed nurse to supervise attendants and service plans |
| Attendant training and screening | Trainer and nurse time for the 16 hour basic course and yearly in service hours, plus screening vendor fees |
| EVV and scheduling software | The state EVV system, Netsmart Mobile Caregiver+, is free to providers; a separate scheduling or alternate EVV system is your cost |
| Accreditation (home health, hospice) | Accrediting organization application and survey fees |
| Operating reserve | Covers payroll, rent and insurance while Medicaid enrollment, licensure or Medicare enrollment is pending |
Fees change. Confirm current amounts with each agency before budgeting.
How long it takes in Montana
Weeks, once the business, insurance and hiring process are in place.
Several months: nurse supervisor hiring, DPHHS training, Medicaid enrollment with onsite visits, then member referrals after Mountain Pacific assessments.
Longest: an application up to six months before opening, policies at least 45 days ahead, a six month provisional license with a survey, then certification and Medicare enrollment, which CMS paused from May 13, 2026.
Montana is a large, mostly rural state, so distance shapes home care more than paperwork does. Families in Billings, Missoula, Bozeman, Great Falls, Helena and Kalispell have the most agency choices, while smaller towns and reservation communities are harder to staff. Community First Choice providers choose their service area by county or reservation, so a realistic map of where your attendants can reliably travel is a business decision, not a formality. Many families search for care for a parent from out of state, which makes a strong Google Business Profile and clear city pages matter.
Frequently asked questions
Do you need a license to start a nonmedical home care agency in Montana?
No. Montana's health care facility law licenses home health agencies and hospices, not nonmedical personal care agencies. You still need business registration, workers' compensation and insurance, and to serve Medicaid members you must enroll with Montana Medicaid as a Community First Choice Services and Personal Care Services provider.
Who licenses home health and hospice agencies in Montana?
The DPHHS Office of Inspector General, Licensure Bureau, under MCA Title 50, Chapter 5. Home health agencies must meet ARM 37.106.1505, which adopts the Medicare Conditions of Participation, and hospices must meet ARM 37.106.2301. Both receive a six month provisional license and an onsite survey before full licensure.
Does Montana require a Certificate of Need for home health or hospice?
No. The Licensure Bureau's application letters state that home health agencies and hospices are not reviewed by the Health Planning Program and do not need a Certificate of Need. Montana's CON law applies to long term care facilities.
What is Community First Choice in Montana?
Community First Choice Services (CFCS) and Personal Care Services (PCS), formerly CFC/PAS, are Montana Medicaid state plan programs that pay for help with daily living activities at home. They are entitlements with no waiting list. Members are assessed by Mountain Pacific and choose an agency based or self directed option.
What does Montana require to enroll as a CFCS/PCS agency?
Under ARM 37.40.1013: a business formed or registered under Montana law, a service area of at least one whole county or reservation, onsite visits before and after enrollment, set insurance minimums, unemployment insurance and workers' compensation, completion of DPHHS mandatory training and use of EVV.
How much training do Montana personal care attendants need?
Agency based attendants complete 16 hours of basic training overseen by a licensed nurse, with a competency evaluation, before their first shift, then eight hours of in service training a year. Certified nurse aides and others with documented training can have basic training waived after a competency check.
Can I still enroll a new home health agency or hospice in Medicare?
CMS placed a six month nationwide pause on new Medicare enrollment of home health agencies and hospices, effective May 13, 2026. It may have ended or been extended, so check its status. Montana Medicaid also requires home health agencies to be Medicare certified, so the pause affects Medicaid home health too.
Is a franchise a better way to start a home care agency in Montana?
A franchise gives you a brand and playbook in exchange for fees and ongoing royalties. Starting independently with Lunaria costs one fixed price, and you own 100% of your agency with no franchise fees or royalties.
How much does Montana home care consulting cost?
Lunaria charges one fixed price per engagement, based on your path: private pay, Community First Choice or home health and Medicare. You receive the price in writing after a free 30 minute consultation. There are no hourly charges.
Do you only work in Montana?
No. Lunaria works with owners in all 50 states and DC, so you can expand into a second state with the same team.
Sources checked for this guide (37)
- MCA 50-5-101, health care facility definitions (Montana Code Annotated 2025)
- MCA 50-5-203, application for license (45 days before opening)
- MCA 50-5-301, when a Certificate of Need is required
- DPHHS Licensure Bureau, Home Health Agency page
- DPHHS Licensure Bureau, prospective home health agency letter (2025)
- DPHHS Licensure Bureau, prospective hospice letter (2025)
- DPHHS printable minimum standards for all health care facilities, ARM 37.106 Subchapter 3 (2025)
- DPHHS printable hospice rules, ARM 37.106 Subchapter 23
- ARM 37.106.1505, minimum standards for a home health agency (Cornell LII)
- ARM 37.40.1013, CFCS provider enrollment (Cornell LII, pre 2025 text)
- MAR Notice 2025-280.1, proposed amendment of ARM 37.40.1013
- MAR Notice 2025-280.2, adoption effective July 26, 2025 (Montana entity, EVV, IVR option)
- MAR Notice 2025-523.1 and 2025-523.2, HCBS EVV rule ARM 37.85.405 (effective November 22, 2025)
- ARM 37.40.1022, CFCS compliance reviews (Cornell LII)
- ARM 37.40.1006, self directed CFCS and health maintenance tasks (Cornell LII)
- ARM 37.40.702, Medicaid home health requirements (Cornell LII)
- ARM 37.40.802, Medicaid hospice adoption of Medicare rules (Cornell LII)
- DPHHS CFCS/PCS program page (name change from CFC/PAS)
- DPHHS Big Sky Waiver Program page
- DPHHS Big Sky Waiver wait list placement notice (BSW 103)
- Montana Healthcare Programs, Community First Choice overview and provider requirements (January 2025)
- Montana Healthcare Programs, CFCS/PCS presentation (2025)
- DPHHS Agency Based Policy Manual AB-CFC/PAS 701, agency requirements (nurse supervisor, plan facilitator)
- DPHHS Agency Based Policy Manual AB-CFC/PAS 706, training attendants
- DPHHS Agency Based CFCS/PCS Policy 612, Electronic Visit Verification (July 2026)
- DPHHS Agency Based CFCS/PCS Policy 606, reimbursement
- DPHHS Electronic Visit Verification page (Netsmart Mobile Caregiver+)
- Montana Healthcare Programs provider notice: EVV full compliance deadline (June 14, 2024)
- DPHHS Home Health Policy 601, provider eligibility
- Montana Department of Labor and Industry, UI employer resources
- CMS Provider Enrollment Moratoria (HHA and hospice moratorium from May 13, 2026)
- Federal Register 2026-09717, nationwide moratorium on Medicare enrollment of HHAs (effective 05/13/2026)
- Federal Register 2026-09718, nationwide moratorium on Medicare enrollment of hospices (effective 05/13/2026)
- 42 CFR 484.80, home health aide training (Cornell LII)
- 42 CFR Part 484, home health Conditions of Participation (Cornell LII)
- 42 CFR Part 418, hospice care (Cornell LII)
- CMS-855A Medicare enrollment application, institutional providers
This guide is general information and reflects Montana requirements as we understood them in November 2026. Requirements change. Confirm current rules, fees and procedures with the Montana Department of Public Health and Human Services, Montana Medicaid and CMS before filing. Lunaria Care Consulting provides professional consulting services and does not provide legal advice.
Other states: see all state guides. What we do: licensing, compliance, Medicaid enrollment and local search marketing.