Maryland - Autism Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Maryland Department of Health (MDH) covers Applied Behavior Analysis (ABA) for Medicaid participants under age 21 through the EPSDT benefit and the Home and Community-Based Services Autism Waiver, governed by COMAR 10.09.28 and 10.09.56. Providers must enroll through the state's electronic Provider Revalidation and Enrollment Portal (ePREP) as either individual practitioners or group ABA practices.

Before rendering billable services, an enrolled ABA provider must register with Maryland's Behavioral Health Administrative Services Organization (BHASO), currently Carelon Behavioral Health, which manages authorizations and network credentialing. Behavior Technicians (BTs) face a strict 90-day regulatory clock from their ePREP enrollment date to secure and submit proof of Registered Behavior Technician (RBT) certification to maintain active Medicaid billing status.

1. Service Definition and Scope

Maryland Medicaid defines ABA as the direct observation, measurement, and functional analysis of the relations between environment and behavior for individuals with Autism Spectrum Disorder (ASD). Services require a comprehensive diagnostic evaluation confirming ASD and must be preauthorized by the BHASO.

The benefit spans direct treatment, assessment, and caregiver training delivered by a tiered workforce of licensed and certified professionals. Services are delivered in homes, clinics, and community settings, excluding custodial care.

• Target Population: Medicaid-enrolled members under the age of 21 with a confirmed ASD diagnosis.
• Comprehensive Diagnostic Evaluation: Required assessment including direct observation, caregiver interviews, and developmental history to confirm ASD.
• Direct Treatment: Face-to-face interventions delivered by BTs, RBTs, BCaBAs, or BCBAs under clinical direction.
• Caregiver Training: Instruction provided to a willing and able individual to implement care plans.
• Excluded Services: Custodial care and services lacking preauthorization from the BHASO.

2. Regulatory and Oversight Agencies

ABA services in Maryland are jointly overseen by the Maryland Department of Health (MDH) and its contracted Behavioral Health Administrative Services Organization (BHASO). Professional licensure is managed by distinct state boards depending on the clinician's degree and discipline.

Providers interact with MDH for Medicaid enrollment and policy, the BHASO for authorizations and network management, and the Department of Public Safety and Correctional Services for mandatory background checks.

• Maryland Department of Health (MDH): Administers the Medicaid program and ePREP portal (https://health.maryland.gov).
• Carelon Behavioral Health of Maryland: The current BHASO managing ABA network registration, authorizations, and provider communications (https://maryland.carelonbh.com).
• Maryland Board of Professional Counselors and Therapists: Licenses Board Certified Behavior Analysts (BCBAs) as Licensed Behavior Analysts (LBAs) (https://health.maryland.gov/bopc).
• Maryland Board of Examiners of Psychologists: Licenses psychologists rendering ABA services (https://health.maryland.gov/psych).
• Department of Public Safety and Correctional Services (DPSCS): Processes the required Criminal Justice Information System (CJIS) background checks (https://dpscs.maryland.gov).

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland does not impose a Certificate of Need (CON), county sponsorship requirement, or closed RFP procurement process for standard EPSDT ABA services. Any qualified agency or individual meeting COMAR 10.09.28 standards may apply for Medicaid enrollment at any time.

However, structural prerequisites exist regarding professional licensure and BHASO registration. An ABA program must be anchored by a licensed psychologist or Licensed Behavior Analyst (LBA), and all providers must clear the state's specific background check petition process before ePREP approval.

• Certificate of Need: None required for ABA clinics or agencies in Maryland.
• Procurement Windows: Open enrollment; no closed network or RFP required for standard Medicaid ABA participation.
• BHASO Registration: Mandatory registration with Carelon Behavioral Health is required immediately following ePREP enrollment to receive authorizations.
• Program Structure: An ABA program must legally include at least one licensed psychologist or LBA alongside paraprofessional staff (BCaBA, RBT, or BT).
• CJIS Private Parity Petition: Agencies must complete this specific petition with DPSCS to legally receive state and national background check results for their staff.

4. Licensure and Certification Requirements

Maryland requires ABA providers to hold specific state licenses and national certifications from the Behavior Analyst Certification Board (BACB). The state distinguishes between licensed independent practitioners and certified paraprofessionals working under supervision.

Psychologists and BCBAs must hold active Maryland state licenses, while BCaBAs and RBTs rely on their BACB credentials and documented supervisory relationships.

• Licensed Psychologist: Must be licensed by the Maryland Board of Examiners of Psychologists and act within their scope of practice.
• BCBA and BCBA-D: Must hold current BACB certification and be licensed by the Maryland Board of Professional Counselors and Therapists as an LBA.
• BCaBA: Requires current BACB certification and a documented written supervisory relationship with a licensed psychologist or LBA.
• RBT: Requires current BACB registration, high school diploma or equivalent, and a documented written supervisory relationship.
• Out-of-State Credentials: Professionals with credentials obtained outside the US require an equivalency review by an accredited agency before rendering Autism Waiver services.

5. Medicaid Provider Enrollment

All ABA providers, including individual technicians and group practices, must enroll through Maryland Medicaid’s electronic Provider Revalidation and Enrollment Portal (ePREP). ePREP manages initial applications, revalidations, and demographic updates.

Group practices enroll first, followed by individual practitioners who link their ePREP profiles to the group. Licensed psychologists must also submit a specific ABA Attestation Form to MDH.

• Enrollment System: ePREP (electronic Provider Revalidation and Enrollment Portal) (https://eprep.health.maryland.gov/).
• Group Enrollment: ABA agencies enroll as a group practice to obtain a group Medicaid provider number for billing.
• Individual Enrollment: Every BCBA, BCaBA, RBT, and BT must individually enroll in ePREP and affiliate with their employing group.
• Psychologist Attestation: Licensed psychologists must complete and submit the ABA Attestation Form found on the MDH ABA webpage.
• OIG Screening: Providers must screen all owners and employees against the DHHS-OIG exclusion list (https://www.oig.hhs.gov/exclusions/index.asp) prior to enrollment.

6. Staffing, Training and Background Checks

Maryland Medicaid strictly regulates the onboarding of Behavior Technicians (BTs) and mandates comprehensive background checks for all ABA staff. BTs are granted a temporary window to provide services while completing their formal certification.

Background checks must be processed through the state's Criminal Justice Information System (CJIS) before an individual can be approved in ePREP.

• BT Age and Education: Behavior Technicians must be at least 18 years old and possess a high school diploma or national equivalent.
• BT 90-Day Grace Period: BTs enroll in ePREP using specialty code 325 and have exactly 90 days from their application date to obtain and submit BACB RBT certification.
• Grace Period Portability: The 90-day clock is tied to the individual BT; it does not restart if the BT changes employers.
• CJIS Background Check: All ABA providers must complete a Criminal Justice Information System criminal background check as part of ePREP enrollment.
• Autism Waiver Experience: Direct care workers under the Autism Waiver must have a minimum of 100 hours of volunteer or employment experience working with children with developmental disabilities.

7. Documentation, Policies and Records

ABA agencies must maintain rigorous clinical and administrative records to comply with COMAR 10.09.28 and BHASO audit standards. Documentation must clearly link the comprehensive diagnostic evaluation to the individualized treatment plan and daily encounter notes.

Supervisory relationships between LBAs and paraprofessionals must be formalized in writing and available for state review.

• Supervisory Documentation: Written contracts or employment agreements detailing the supervisory relationship between the LBA/Psychologist and the BCaBA, RBT, or BT.
• Encounter Notes: Daily logs must include the date, location, type of contact, supportive documentation of the service, and the provider's printed name and signature.
• Treatment Plans: Individualized plans based on the functional assessment, updated regularly, and submitted to the BHASO for reauthorization.
• Transportation Logs: If transportation is provided under the Autism Waiver, the provider must implement a transportation policy and identify the driver in daily notes.
• Reportable Events: Agencies must maintain and submit Reportable Event forms concerning participant incidents as mandated by MDH.

8. Billing, Rates and Claims

ABA services are reimbursed according to the Maryland Medical Assistance Program fee schedule. Providers must accept Medicaid payment as payment in full and cannot balance-bill families.

Claims are submitted to the BHASO (Carelon) rather than directly to the state MMIS, requiring providers to navigate the ASO's specific clearinghouse and billing protocols.

• Payment in Full: Providers must accept the Program's reimbursement as payment in full and make no additional charges to the participant.
• Preauthorization Requirement: No claims will be paid without prior approval from the BHASO for the specific procedure codes and units billed.
• Claims Submission: Claims must include the date of service, participant Medicaid number, provider NPI, procedure codes, and units, submitted via the BHASO portal.
• Withholding of Payment: MDH or the BHASO may withhold payments if a provider fails to submit requested evidence of services, staff qualifications, or corrective action plans.
• Inactivity Termination: A provider's Medicaid status and number will be terminated if no services are billed for 24 consecutive months.

9. Approval Sequence and Timeline

Launching an ABA agency in Maryland follows a linear sequence: corporate formation, professional licensure, ePREP enrollment, and finally BHASO registration. Skipping steps or submitting incomplete ePREP applications will cause significant delays.

The state recommends that newly enrolled groups proactively engage with the BHASO to understand network expectations immediately after ePREP approval.

• Step 1: Professional Licensure: The clinical director or owner obtains LBA licensure from the Maryland Board of Professional Counselors and Therapists.
• Step 2: CJIS Background Checks: The agency establishes its CJIS Private Parity Petition and runs background checks on initial staff.
• Step 3: ePREP Group Enrollment: The agency submits its group application via ePREP, which is reviewed and managed directly by MDH.
• Step 4: Individual ePREP Linking: Staff (BCBAs, RBTs, BTs) submit individual ePREP applications linking to the approved group NPI.
• Step 5: BHASO Registration: The approved group registers with Carelon Behavioral Health to enter the network and begin requesting authorizations.
• Step 6: BHASO Meet and Greet: MDH highly recommends attending a virtual Meet and Greet with the ASO within the first three months of network entry.

10. Common Denials and Survey Findings

MDH and the BHASO actively monitor ABA providers for compliance with COMAR regulations and BACB standards. Audits frequently target the qualifications of paraprofessional staff and the validity of supervisory documentation.

Failure to manage the strict timelines for BT certification is a primary source of provider enrollment termination and claim recoupment.

• BT Grace Period Expiration: BTs failing to upload proof of RBT certification to ePREP within the 90-day window face immediate Medicaid disenrollment.
• Missing Supervisory Agreements: Audits frequently cite agencies for lacking written, signed supervisory agreements between LBAs and RBTs/BTs.
• Uncredentialed Staff Billing: Claims denied or recouped because services were rendered by staff who had not yet completed their individual ePREP enrollment.
• Lapsed Background Checks: Failure to maintain current CJIS background checks for all direct care staff.
• OIG Exclusion Violations: Employing individuals listed on the DHHS-OIG exclusion list due to inadequate pre-employment screening.

11. Key Contacts and Resources

Providers must utilize official state portals and manuals to maintain compliance. The MDH ABA Provider Manual and COMAR regulations are the definitive sources for policy.

Technical assistance for enrollment is handled by MDH, while authorization and claims support is routed through the BHASO.

• MDH ePREP Portal: The mandatory system for all Medicaid provider enrollment and updates (https://eprep.health.maryland.gov/).
• Carelon Behavioral Health of Maryland: The BHASO for provider registration, authorizations, and claims (https://maryland.carelonbh.com).
• Maryland Board of Professional Counselors and Therapists: For LBA licensure verification and applications (https://health.maryland.gov/bopc).
• DPSCS Background Checks: For CJIS Private Parity Petition forms and fingerprinting instructions (https://dpscs.maryland.gov).
• DHHS-OIG Exclusion List: Mandatory screening database for all employees and contractors (https://www.oig.hhs.gov/exclusions/index.asp).

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