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Maryland - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Maryland Department of Health (MDH) Office of Health Care Quality (OHCQ) requires agencies providing non-medical supervision and socialization to hold a Residential Service Agency (RSA) license before they can bill the state. Maryland does not operate a standalone "Adult Companion Services" provider type; instead, these socialization and supervision functions are bundled into Personal Assistance Services funded through the Community Personal Assistance Services (CPAS) program, Community First Choice (CFC), and the Community Options Waiver.

Agencies must secure an RSA Level Two or Level Three license under COMAR 10.07.05 to deliver these services in a participant's home. Currently, the Maryland Medicaid electronic Provider Revalidation and Enrollment Portal (ePREP) has placed a temporary hold on new enrollment applications for moderate and high-risk provider types as the state transitions to a new MPRIME system, blocking immediate new agency enrollments.

1. Service Definition and Scope

Because Maryland does not license or cover a distinct "Adult Companion Services" category, providers must enroll to provide Personal Assistance Services. This service category encompasses the non-medical supervision, socialization, and assistance with Activities of Daily Living (ADLs) and Instrumental Activities of Daily Living (IADLs) that allow an adult to remain safely in the community.

Under the CPAS and CFC programs, personal assistance includes cueing, supervision, and hands-on support. Services must be delivered in the participant's own home or community setting, explicitly excluding assisted living facilities.

2. Regulatory and Oversight Agencies

The Maryland Department of Health (MDH) divides oversight between facility licensing and waiver administration. The Office of Health Care Quality (OHCQ) handles the initial and ongoing licensure of the agency itself.

The MDH Office of Long Term Services and Supports (OLTSS) administers the CPAS, CFC, and Community Options Waiver programs, managing participant eligibility, plans of service, and provider compliance.

3. Gatekeeping Prerequisites: Who Can Even Apply

An applicant cannot submit a Medicaid provider enrollment application for Personal Assistance Services without first obtaining a Residential Service Agency (RSA) license from OHCQ. The Medicaid enrollment portal will automatically reject applications lacking this active, unrestricted license.

Additionally, Maryland Medicaid has instituted a temporary enrollment hold for moderate and high-risk provider types (which includes personal care agencies) as of July 1, pending the transition from ePREP to the new MPRIME system in 2026. This moratorium prevents new agencies from receiving a Medicaid ID until the hold is lifted or the new system is active.

4. Licensure and Certification Requirements

To provide personal assistance and companion-level care, an agency must apply for a Residential Service Agency (RSA) license. Specifically, the agency must be licensed to provide Level Two (personal care) or Level Three (complex care) home care services under COMAR 10.07.05.

The RSA application requires submission of organizational policies, a designated agency manager, and a registered nurse (RN) to serve as the nurse monitor for direct care staff.

5. Medicaid Provider Enrollment

Once the RSA license is secured and the enrollment hold is lifted, providers must apply through the electronic Provider Revalidation and Enrollment Portal (ePREP). The agency must sign a Maryland Medical Assistance Provider Agreement.

Providers must enroll under the specific taxonomy codes for personal care agencies and link their Type 2 NPI to their ePREP profile. All principals and owners must be disclosed and screened for federal exclusions.

6. Staffing, Training and Background Checks

Direct service workers providing personal assistance must undergo rigorous vetting before interacting with participants. COMAR 10.09.20.05 mandates that providers conduct a criminal history records check on all direct service workers.

Workers must be supervised by an RN Nurse Monitor who conducts initial and ongoing assessments of the participant's needs and the worker's competency.

7. Documentation, Policies and Records

Agencies must maintain comprehensive records for at least six years. Services must be delivered strictly in accordance with the participant's OLTSS-approved plan of service.

Maryland mandates the use of Electronic Visit Verification (EVV) for all personal assistance services. Providers must use the state-sponsored ISAS/LTSSMaryland system or an approved alternate EVV vendor to capture the date, time, location, and type of service provided.

8. Billing, Rates and Claims

Billing for Personal Assistance Services is processed through the LTSSMaryland system, which interfaces with the state's MMIS. Claims are generated automatically based on validated EVV data.

Rates are established by the MDH and published in the OLTSS fee schedule. Providers cannot bill for services provided outside the authorized hours in the plan of service.

9. Approval Sequence and Timeline

The approval sequence begins with corporate formation and obtaining the RSA license from OHCQ, which can take 3 to 6 months depending on application completeness and survey scheduling.

Following licensure, the ePREP Medicaid enrollment phase typically takes 60 to 90 days, though this is currently impacted by the system transition hold. Finally, the provider must be configured in LTSSMaryland to receive service authorizations.

10. Common Denials and Survey Findings

OHCQ frequently cites RSA applicants for incomplete policy manuals, particularly lacking detailed procedures for RN nurse monitoring and emergency preparedness. Missing or delayed CJIS background checks for direct care staff are a primary cause for survey deficiencies.

On the Medicaid side, ePREP applications are routinely rejected if the NPI is not properly linked to the exact legal name on the RSA license, or if ownership disclosures are incomplete.

11. Key Contacts and Resources

Prospective providers should monitor the MDH OHCQ and OLTSS websites for updates on licensure rules and the ePREP/MPRIME transition. The state provides specific provider manuals for the CPAS and CFC programs.

For EVV and billing support, providers must coordinate with the LTSSMaryland help desk.

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