Overview of Montana’s CFC / PAS Programs
Montana’s Community First Choice (CFC) Program and Personal Assistance Services (PAS) Program are both Medicaid programs through which in-home assistance is provided for seniors and persons who are disabled. Intended to encourage independent living, hands-on assistance with daily living activities is provided. This may include assistance with bathing, dressing, toileting, ambulation, and meal preparation. Through CFC, additional home and community based services, such as personal emergency response systems, are also available.
Program participants can reside in their home or that a loved one. They cannot reside in an assisted living residence or an adult foster care home.
While services offered under the CFC / PAS can be provided by licensed agency providers, program participants also have the option of self-directing their personal care services. This means they can hire, manage, and even fire, the personal care attendant (caregiver) of their choosing. While this allows them to hire a friend or family member, such as an adult child, a spouse or parent of a minor child are prohibited from being hired. With self-direction, a provider agency handles the financial aspects of employment responsibilities, such as tax withholding and caregiver payments.
Montana’s Community First Choice (CFC) Program is a 1915(k) Medicaid State Plan Option, and the Personal Assistance Services (PAS) Program is part of Montana’s Regular State Plan Medicaid program. These are entitlement programs; meeting eligibility requirements means one will be able to access program benefits without a waiting list.
Benefits of Montana’s CFC / PAS Programs
Follows is a list of activities with which assistance may be provided. The exact services and supports one receives is based on an individualized service plan.
– Ambulation / Exercise
– Bathing
– Changing Bed Linens
– Dressing
– Eating
– Grooming / Personal Hygiene
– Health Maintenance Activities (limited to persons self-directing their care) – i.e., medication administration, bowel care, urinary system management, wound care
– Laundry
– Light Housecleaning
– Meal Preparation
– Medical Escort – for persons who need assistance going to medical appointments
– Medication Reminders / Assistance
– Shopping for Essentials – i.e., groceries and pharmacy
– Toileting
– Transferring
The CFC Program also provides additional services. These include skill acquisition, personal emergency response systems, yard hazard removal (i.e., shoveling snow and maintaining the walkway), community integration (to assist isolated program participants in becoming involved in community activities), and correspondence assistance (i.e., getting mail and making a phone call).
Eligibility Requirements for Montana’s CFC / PAS Programs
Applicants for the CFC and PAS Programs must be Montana residents. Additional eligibility criteria follows and is relevant for the elderly (65+ years old).
Financial Criteria: Income, Assets & Home Ownership
Income
The individual applicant income limit is $943 / month. This figure is equivalent to 100% of the Federal Benefit Rate (FBR) for 2024. The income limit for a couple, regardless of it one or both spouses are applicants, is $1,415 / month.
Assets
In 2024, the asset limit is $2,000 for a single applicant. For married couples, with one or both spouses as applicants, the asset limit is $3,000.
Some assets are not counted towards Medicaid’s asset limit. These generally include an applicant’s primary home, household furnishings and appliances, personal effects, and a vehicle.
Assets should not be given away or sold under fair market value within 60-months of long-term care Medicaid application. This is because Medicaid has a Look-Back Rule and violating it results in a Penalty Period of Medicaid ineligibility.
Home Ownership
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take it. For eligibility purposes, Medicaid in MT considers the home exempt (non-countable) in the following circumstances.
– The applicant lives in the home or has Intent to Return, and in 2024, their home equity interest is no greater than $713,000. Home equity is the current value of the home minus any outstanding mortgage. The applicant’s home equity interest is the portion of the home’s equity value that is owned by the applicant.
– The applicant has a spouse living in the home.
– The applicant has a minor child living in the home.
– The applicant has a disabled child of any age living in the home.
Learn more about the potential of Medicaid taking the home here.
Medical Criteria: Functional Need
For CFC / PAS, an applicant’s need for assistance must be “medically necessary”. For CFC, an applicant must require a higher level of care; they must require a Nursing Facility Level of Care (NFLOC). For both programs, an in-home functional needs assessment is completed by a nurse from Mountain Pacific Qualify Health (MPQH) to determine if one meets the functional need. Limitations in the ability to independently complete Activities of Daily Living (ADLs) and Instrumental Activities of Daily Living (IADLs) are considered. These activities include bathing, mobility, dressing, eating, toileting, transferring, grooming, medication management, shopping for essentials, cooking, housework, laundry, and money management. While persons with Alzheimer’s disease or a related dementia commonly need assistance with their ADLs and IADLs due to cognitive decline, a diagnosis of dementia in and of itself does not mean one will automatically meet the level of care need.
Qualifying When Over the Limits
Having income and / or assets over Medicaid’s limit(s) does not mean an applicant cannot still qualify for MT Medicaid. There are a variety of planning strategies that can be used to help persons who would otherwise be ineligible to become eligible. Some of these strategies are fairly easy to implement, and others, exceedingly complex. Below are the most common.
Montana has a Medically Needy Program for Medicaid applicants who have high medical expenses relative to their income. Also known as a spend-down program, applicants are permitted to spend “excess” income on medical expenses and health care premiums, such as Medicare Part B, in order to meet Medicaid’s Medically Needy income limit (called a Protected Income Level). The amount that must be “spent down” can be thought of as a deductible. Once one’s “deductible” has been met, CFC / PAS will pay for care services and supports.
When persons have assets over the limit, trusts are an option. Irrevocable Funeral Trusts (IFTs) are pre-paid funeral and burial expense trusts that Medicaid does not count as assets. Medicaid Asset Protection Trusts (MAPTs), which must be implemented well in advance of the need for care, are trusts that protect assets from Medicaid and the Medicaid Estate Recovery Program. Persons who do not have a large amount of excess assets might choose to “spend down” countable assets on ones that are exempt. Examples include purchasing home furnishings and appliances, making home repairs, and buying personal items, such as clothing. There are additional planning strategies available when the applicant has assets exceeding the limit.
Inadequate planning or improperly implementing a Medicaid planning strategy can result in a denial or delay of Medicaid benefits. Professional Medicaid Planners are educated in the planning strategies available in Montana to meet Medicaid’s financial eligibility criteria without jeopardizing Medicaid eligibility. Some of the strategies violate Medicaid’s 60-month Look-Back Rule, and therefore, should only be implemented with careful planning. However, there are some workarounds, and Medicaid Planners are aware of them. For these reasons, it is highly suggested one consult a Medicaid Planner for assistance in qualifying for Medicaid when over the income and / or asset limit(s). Find a Medicaid Planner.
How to Apply for Montana’s CFC / PAS Programs
Before You Apply
Prior to submitting an application for CFC / PAS Programs, applicants need to ensure they meet the eligibility criteria. Applying when over the income and / or asset limit(s) will be cause for denial of benefits. The American Council on Aging offers a free Medicaid Eligibility Test to determine if one might meet Medicaid’s eligibility criteria. Take the Medicaid Eligibility Test.
As part of the application process, applicants will need to gather documentation for submission. Examples include copies of Social Security and Medicare cards, bank statements up to 60-months prior to application, proof of income, and copies of life insurance policies, property deeds, and pre-need burial contracts. Unfortunately, a common reason applications are delayed is required documentation is missing or not submitted in a timely manner.
Application Process
To be eligible for Montana’s Community First Choice Program or Personal Assistance Services Program, one must be eligible for Montana Medicaid. Persons can apply online or via their local Office of Public Assistance. For application assistance or questions, persons can contact the Montana Public Assistance Helpline at 888-706-1535.
Once enrolled in Medicaid, Mountain Pacific Quality Health should be contacted at 800-219-7035 to initiate the Level of Care determination (functional needs assessment).
Limited information about the CFC / PAS Programs can be found here.
Montana’s Department of Public Health & Human Services’ (DPHHS) Division of Senior & Long Term Care (SLTC) administers the CFC / PAS Programs The Office of Public Assistance (OPA) determines financial eligibility and Mountain Pacific Qualify Health (MPQH) determines functional eligibility.
Approval Process & Timing
The Montana Medicaid application process can take up to 3 months, or even longer, from the beginning of the application process through the receipt of the determination letter indicating approval or denial. Generally, it takes one several weeks to complete the application and gather all of the supportive documentation. If the application is not properly completed, or required documentation is missing, the application process will be delayed. Based on federal law, Medicaid offices have up to 45 days to review and approve or deny one’s application (up to 90 days for disability applications). Despite the law, applications are sometimes delayed even further.