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

Last reviewed: 2026-08-16

In Maryland, Autism Services primarily consist of Applied Behavior Analysis (ABA) delivered to Medicaid beneficiaries under 21 via the EPSDT benefit, as well as specialized services under the 1915(c) Autism Waiver managed jointly by the Maryland Department of Health (MDH) and the Maryland State Department of Education (MSDE). Services are delivered by Licensed Behavior Analysts (LBAs) and Registered Behavior Technicians (RBTs).

The single biggest structural barrier to entry for ABA providers in Maryland is the mandatory dual-enrollment and credentialing gateway. Providers cannot simply enroll in Medicaid fee-for-service; they must first secure an active Medicaid provider number through the ePREP portal and subsequently register and credential with Carelon Behavioral Health Maryland, the state's Behavioral Health Administrative Services Organization (BHASO), which strictly manages the ABA network and authorizations.

1. Service Definition and Scope

Maryland Medicaid covers medically necessary Applied Behavior Analysis (ABA) therapy for Medical Assistance Program enrolled participants under age 21. The state also operates the Autism Waiver, providing community-based therapeutic services to prevent institutionalization.

ABA services include comprehensive assessment, treatment plan development, and direct behavioral interventions. Services must be evidence-based and delivered in home, clinic, or community settings.

2. Regulatory and Oversight Agencies

Oversight is bifurcated between the Maryland Department of Health (MDH) and its designated contractors. MDH's Medical Care Programs division handles baseline Medicaid policy and enrollment.

Carelon Behavioral Health Maryland acts as the BHASO, managing the ABA program's clinical, operational, and provider network functions. The Maryland State Department of Education (MSDE) co-manages the Autism Waiver.

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland does not require a Certificate of Need (CON) or a competitive RFP procurement to become an ABA provider. However, there is a strict structural precondition: mandatory affiliation with the state's Behavioral Health ASO.

An applicant cannot bill Medicaid directly for ABA without first completing the ePREP enrollment and then securing an approved registration and credentialing status with Carelon Behavioral Health Maryland. For the Autism Waiver, providers must also be selected by the participant's multidisciplinary team.

4. Licensure and Certification Requirements

Maryland licenses behavior analysts at the state level. Agencies must ensure all supervising practitioners hold active state licenses, while frontline technicians must hold national certification.

The Maryland Board of Professional Counselors and Therapists issues the Licensed Behavior Analyst (LBA) credential. Maryland does not issue a distinct facility license for ABA agencies; instead, agencies operate under the professional licenses of their clinical directors.

5. Medicaid Provider Enrollment

All ABA providers must enroll in the Maryland Medicaid Program through the electronic Provider Revalidation and Enrollment Portal (ePREP). Note that Maryland is transitioning to the MPRIME portal in October 2026.

Providers can enroll as individual ABA providers or as group ABA providers. The ePREP system handles initial enrollment, revalidation, and demographic updates.

6. Staffing, Training and Background Checks

Maryland mandates strict background screening and ongoing training for all personnel interacting with vulnerable minors.

Agencies must maintain documentation of criminal history records checks and verify that no staff appear on state or federal exclusion lists.

7. Documentation, Policies and Records

Clinical and administrative documentation must comply with COMAR regulations and Carelon's ABA Provider Manual.

Providers must maintain comprehensive treatment plans, session notes, and, for waiver participants, integration with the MSDE Person-Centered Plan.

8. Billing, Rates and Claims

ABA claims are not submitted directly to the state MMIS; they must be routed through Carelon Behavioral Health Maryland.

Providers utilize specific portals for claims submission and eligibility verification, primarily Availity Essentials and ProviderConnect.

9. Approval Sequence and Timeline

The end-to-end process requires sequential approvals from the licensing board, the state Medicaid agency, and the BHASO.

Providers should expect the entire process to take 3 to 6 months from initial LBA licensure to final Carelon network activation.

10. Common Denials and Survey Findings

Applications and claims are frequently delayed or denied due to administrative mismatches between state and federal databases.

Audits by MDH or Carelon often target inadequate supervision documentation or billing for services without an active prior authorization.

11. Key Contacts and Resources

Providers must utilize specific state and ASO contact channels for enrollment, billing, and policy inquiries.

Maintaining access to the ePREP portal and Carelon's provider resources is essential for ongoing compliance.

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