News
NAMI Montana's Comments on the Montana Medicaid HELP Demonstration Waiver
Written by
Written by
Matt Kuntz
Matt Kuntz
Posted on
Posted on
Aug 6, 2025
Aug 6, 2025
Category
Category
Advocacy
Advocacy
Dear Montana DPHHS,
Congratulations on the draft of your HELP Demonstration Waiver. We are very grateful for your work and particularly for the focus on developing a strong indirect validation process for the community service requirements. We think those indirect processes will prevent a significant number of unfair disenrollments.We have three recommended changes to the HELP Demonstration Waiver:
A. Ensuring that Direct Validation Processes Will Not Begin Until Indirect Validation Efforts are Functional
Pages 13 and 14 describe the Indirect and Direct Validation processes for the Community Service Requirement. NAMI Montana applauds DPHHS's reliance on Indirect Validation that will take some of the communication burden off of the backs of Montana enrollees, DPHHS employees, and DPHHS contractors. This will be a critical step forward for Montana Medicaid. However, we would like to have it clarified that Montana Medicaid will not begin any Direct Validation processes until the majority of its Indirect Validation processes are functional. This will ensure that Montana DPHHS fully focuses its attention on developing functional indirect validation processes which will cut down on bureaucratic red tape and prevent unfair disenrollments.
B. Reducing the Required Disability Rating For Exempt Veterans from 100% to 50%
Page 12 lists some of the population groups exempt from the Community Engagement requirement. One population group is currently described as "A veteran with a disability rated as total under section 1155 of title 38, United States Code." We believe that a 50% disability rating is more appropriate, especially due to one quirk of the Veterans Administration's rating law that makes it clear that some veterans with a 50% rating may have service-connected disabilities that prevent them from maintaining substantially gainful employment. This is known as Total Disability based on Individual Unemployability (TDIU). While it may be possible to expand the definition to include TDIU, that would still exclude veterans with a 50% rating who are in the process of being categorized as TDIU. So, we recommend switching the language from "total" to "50% or more."
C. Adding Mental Health Programming to Criteria to Prevent Disenrollment
Page 16 describes some criteria to prevent disenrollment if there is an issue with paying premiums- "Participation in any of the following healthy behavior plans developed by a health care provider or a third-party administrator, if any, or as approved by DPHHS[.]" Please add "Mental health prevention program designed to support recovery from mental health symptoms for a person or their family." Montana DPHHS supports a variety of these programs through the Behavioral Health Block Grant such as NAMI's Peer-to-Peer, Family-to-Family, Connections Support Group and Family Support Group. Including these programs would be consistent with other programming designed to reduce obesity, cardiovascular conditions, etc.
Thank you so much for your consideration. Please let us know if you have any questions.
Matt Kuntz JD, MHA
Executive Director
www.namimt.org
Dear Montana DPHHS,
Congratulations on the draft of your HELP Demonstration Waiver. We are very grateful for your work and particularly for the focus on developing a strong indirect validation process for the community service requirements. We think those indirect processes will prevent a significant number of unfair disenrollments.We have three recommended changes to the HELP Demonstration Waiver:
A. Ensuring that Direct Validation Processes Will Not Begin Until Indirect Validation Efforts are Functional
Pages 13 and 14 describe the Indirect and Direct Validation processes for the Community Service Requirement. NAMI Montana applauds DPHHS's reliance on Indirect Validation that will take some of the communication burden off of the backs of Montana enrollees, DPHHS employees, and DPHHS contractors. This will be a critical step forward for Montana Medicaid. However, we would like to have it clarified that Montana Medicaid will not begin any Direct Validation processes until the majority of its Indirect Validation processes are functional. This will ensure that Montana DPHHS fully focuses its attention on developing functional indirect validation processes which will cut down on bureaucratic red tape and prevent unfair disenrollments.
B. Reducing the Required Disability Rating For Exempt Veterans from 100% to 50%
Page 12 lists some of the population groups exempt from the Community Engagement requirement. One population group is currently described as "A veteran with a disability rated as total under section 1155 of title 38, United States Code." We believe that a 50% disability rating is more appropriate, especially due to one quirk of the Veterans Administration's rating law that makes it clear that some veterans with a 50% rating may have service-connected disabilities that prevent them from maintaining substantially gainful employment. This is known as Total Disability based on Individual Unemployability (TDIU). While it may be possible to expand the definition to include TDIU, that would still exclude veterans with a 50% rating who are in the process of being categorized as TDIU. So, we recommend switching the language from "total" to "50% or more."
C. Adding Mental Health Programming to Criteria to Prevent Disenrollment
Page 16 describes some criteria to prevent disenrollment if there is an issue with paying premiums- "Participation in any of the following healthy behavior plans developed by a health care provider or a third-party administrator, if any, or as approved by DPHHS[.]" Please add "Mental health prevention program designed to support recovery from mental health symptoms for a person or their family." Montana DPHHS supports a variety of these programs through the Behavioral Health Block Grant such as NAMI's Peer-to-Peer, Family-to-Family, Connections Support Group and Family Support Group. Including these programs would be consistent with other programming designed to reduce obesity, cardiovascular conditions, etc.
Thank you so much for your consideration. Please let us know if you have any questions.
Matt Kuntz JD, MHA
Executive Director
www.namimt.org
Dear Montana DPHHS,
Congratulations on the draft of your HELP Demonstration Waiver. We are very grateful for your work and particularly for the focus on developing a strong indirect validation process for the community service requirements. We think those indirect processes will prevent a significant number of unfair disenrollments.We have three recommended changes to the HELP Demonstration Waiver:
A. Ensuring that Direct Validation Processes Will Not Begin Until Indirect Validation Efforts are Functional
Pages 13 and 14 describe the Indirect and Direct Validation processes for the Community Service Requirement. NAMI Montana applauds DPHHS's reliance on Indirect Validation that will take some of the communication burden off of the backs of Montana enrollees, DPHHS employees, and DPHHS contractors. This will be a critical step forward for Montana Medicaid. However, we would like to have it clarified that Montana Medicaid will not begin any Direct Validation processes until the majority of its Indirect Validation processes are functional. This will ensure that Montana DPHHS fully focuses its attention on developing functional indirect validation processes which will cut down on bureaucratic red tape and prevent unfair disenrollments.
B. Reducing the Required Disability Rating For Exempt Veterans from 100% to 50%
Page 12 lists some of the population groups exempt from the Community Engagement requirement. One population group is currently described as "A veteran with a disability rated as total under section 1155 of title 38, United States Code." We believe that a 50% disability rating is more appropriate, especially due to one quirk of the Veterans Administration's rating law that makes it clear that some veterans with a 50% rating may have service-connected disabilities that prevent them from maintaining substantially gainful employment. This is known as Total Disability based on Individual Unemployability (TDIU). While it may be possible to expand the definition to include TDIU, that would still exclude veterans with a 50% rating who are in the process of being categorized as TDIU. So, we recommend switching the language from "total" to "50% or more."
C. Adding Mental Health Programming to Criteria to Prevent Disenrollment
Page 16 describes some criteria to prevent disenrollment if there is an issue with paying premiums- "Participation in any of the following healthy behavior plans developed by a health care provider or a third-party administrator, if any, or as approved by DPHHS[.]" Please add "Mental health prevention program designed to support recovery from mental health symptoms for a person or their family." Montana DPHHS supports a variety of these programs through the Behavioral Health Block Grant such as NAMI's Peer-to-Peer, Family-to-Family, Connections Support Group and Family Support Group. Including these programs would be consistent with other programming designed to reduce obesity, cardiovascular conditions, etc.
Thank you so much for your consideration. Please let us know if you have any questions.
Matt Kuntz JD, MHA
Executive Director
www.namimt.org
Dear Montana DPHHS,
Congratulations on the draft of your HELP Demonstration Waiver. We are very grateful for your work and particularly for the focus on developing a strong indirect validation process for the community service requirements. We think those indirect processes will prevent a significant number of unfair disenrollments.We have three recommended changes to the HELP Demonstration Waiver:
A. Ensuring that Direct Validation Processes Will Not Begin Until Indirect Validation Efforts are Functional
Pages 13 and 14 describe the Indirect and Direct Validation processes for the Community Service Requirement. NAMI Montana applauds DPHHS's reliance on Indirect Validation that will take some of the communication burden off of the backs of Montana enrollees, DPHHS employees, and DPHHS contractors. This will be a critical step forward for Montana Medicaid. However, we would like to have it clarified that Montana Medicaid will not begin any Direct Validation processes until the majority of its Indirect Validation processes are functional. This will ensure that Montana DPHHS fully focuses its attention on developing functional indirect validation processes which will cut down on bureaucratic red tape and prevent unfair disenrollments.
B. Reducing the Required Disability Rating For Exempt Veterans from 100% to 50%
Page 12 lists some of the population groups exempt from the Community Engagement requirement. One population group is currently described as "A veteran with a disability rated as total under section 1155 of title 38, United States Code." We believe that a 50% disability rating is more appropriate, especially due to one quirk of the Veterans Administration's rating law that makes it clear that some veterans with a 50% rating may have service-connected disabilities that prevent them from maintaining substantially gainful employment. This is known as Total Disability based on Individual Unemployability (TDIU). While it may be possible to expand the definition to include TDIU, that would still exclude veterans with a 50% rating who are in the process of being categorized as TDIU. So, we recommend switching the language from "total" to "50% or more."
C. Adding Mental Health Programming to Criteria to Prevent Disenrollment
Page 16 describes some criteria to prevent disenrollment if there is an issue with paying premiums- "Participation in any of the following healthy behavior plans developed by a health care provider or a third-party administrator, if any, or as approved by DPHHS[.]" Please add "Mental health prevention program designed to support recovery from mental health symptoms for a person or their family." Montana DPHHS supports a variety of these programs through the Behavioral Health Block Grant such as NAMI's Peer-to-Peer, Family-to-Family, Connections Support Group and Family Support Group. Including these programs would be consistent with other programming designed to reduce obesity, cardiovascular conditions, etc.
Thank you so much for your consideration. Please let us know if you have any questions.
Matt Kuntz JD, MHA
Executive Director
www.namimt.org
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Stay Connected to Better Health
We are mental health experienced therapists that are passionate about our goal on empowering you mentally with our wellness journey.
© 2025 NAMI Montana
Privacy Policy
Terms & Conditions
Stay Connected to Better Health
We are mental health experienced therapists that are passionate about our goal on empowering you mentally with our wellness journey.
© 2025 NAMI Montana
Privacy Policy
Terms & Conditions
