Maryland - Behavioral Health Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Maryland's Behavioral Health Administration (BHA) licenses community-based behavioral health programs under COMAR 10.63, requiring national accreditation from entities like CARF or The Joint Commission prior to full approval. These services encompass psychiatric rehabilitation, intensive outpatient, and partial hospitalization programs funded through Maryland Medicaid's Public Behavioral Health System (PBHS).

A strict Medicaid enrollment moratorium currently blocks new Psychiatric Rehabilitation Programs (PRP), PRP Health Homes, Level 2.5 Partial Hospital Programs (PHP), and Level 2.1 Intensive Outpatient Treatment Programs (IOP) from enrolling in 10 major jurisdictions, including Baltimore City and Montgomery County. Providers in these areas cannot bill Medicaid for new programs, though BHA continues to process base licensure applications.

1. Service Definition and Scope

Community-based behavioral health programs in Maryland provide assessment, therapy, positive behavior support, and crisis response under the regulatory framework of COMAR 10.63. These services are designed to support individuals with mental health and substance use disorders in the least restrictive environment.

The scope of services ranges from standard outpatient mental health clinics (OMHC) to intensive outpatient programs (IOP) and psychiatric rehabilitation programs (PRP), each requiring specific programmatic structures and clinical oversight.

• Outpatient Mental Health Center (OMHC): Provides comprehensive diagnostic and treatment services for mental health conditions.
• Psychiatric Rehabilitation Program (PRP): Facilitates recovery and community integration for adults and minors with serious mental illness.
• Intensive Outpatient Program (IOP): Delivers Level 2.1 structured outpatient care for individuals requiring more intensive treatment than standard outpatient therapy.
• Partial Hospitalization Program (PHP): Provides Level 2.5 short-term, intensive, day-treatment programming as an alternative to inpatient hospitalization.
• Mobile Treatment Services: Delivers assertive community treatment (ACT) directly in the community for individuals with severe mental illness.

2. Regulatory and Oversight Agencies

The Maryland Department of Health (MDH) oversees behavioral health services through two primary divisions. The Behavioral Health Administration (BHA) handles programmatic licensure, while the Medicaid program manages provider enrollment and reimbursement.

Additionally, Maryland utilizes an Administrative Services Organization (ASO) to manage authorizations and claims for the Public Behavioral Health System.

• Maryland Department of Health (MDH): The overarching state agency governing health services (https://health.maryland.gov).
• Behavioral Health Administration (BHA): Licenses and certifies community-based behavioral health programs (https://health.maryland.gov/bha/Pages/Licensing-and-Certification.aspx).
• MDH Medicaid Provider Enrollment: Manages the ePREP portal for Medicaid participation (https://health.maryland.gov/mmcp/provider/Pages/enrollment.aspx).
• Optum Maryland: The designated ASO managing authorizations, claims, and provider relations for the Public Behavioral Health System (https://maryland.optum.com).

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland enforces strict geographic and service-specific moratoria that completely block new Medicaid enrollments for certain behavioral health provider types. If an applicant attempts to enroll a restricted service in a restricted county, the application is automatically denied and returned.

While BHA will still process the base COMAR 10.63 license for these providers, the inability to enroll in Medicaid effectively prevents new agencies from operating in the Public Behavioral Health System in those regions.

• Medicaid Enrollment Moratorium: Blocks new enrollments for PRP, PRP Health Home, Level 2.5 PHP, and Level 2.1 IOP services.
• Restricted Jurisdictions: The moratorium applies to Anne Arundel, Baltimore City, Baltimore County, Carroll, Frederick, Harford, Howard, Montgomery, Prince George's, and Washington counties.
• Accreditation Prerequisite: Providers must obtain accreditation from an approved national body (e.g., CARF, Joint Commission, COA) before BHA will issue a full license.
• Exemptions: The moratorium does not apply to individual practitioners, hospital-operated clinics, or Federally Qualified Health Centers (FQHCs).

4. Licensure and Certification Requirements

Providers must obtain a license from the BHA under COMAR 10.63 before delivering community-based behavioral health services. Maryland operates on an accreditation-based licensure model, meaning the state relies heavily on national accrediting bodies to ensure quality standards.

New applicants typically receive an initial approval to operate and must achieve full national accreditation within a specified timeframe to maintain their BHA license.

• Regulatory Authority: Licensure is governed by the Code of Maryland Regulations (COMAR) Title 10, Subtitle 63.
• Approved Accrediting Bodies: Providers must be accredited by The Joint Commission, CARF, or the Council on Accreditation (COA).
• Application Submission: Licensure applications and supporting documents must be submitted directly to the BHA Licensing and Certification division.
• Site Inspections: BHA or its designated agents conduct initial and periodic site visits to verify compliance with physical plant and life safety codes.

5. Medicaid Provider Enrollment

Once licensed by BHA, providers must enroll in Maryland Medicaid to receive reimbursement for services delivered to Medicaid beneficiaries. Enrollment is currently processed through the electronic Provider Revalidation and Enrollment Portal (ePREP).

Maryland Medicaid is scheduled to transition from ePREP to a new system, the Maryland Provider Registration and Information Management Enterprise (MPRIME), in October 2026.

• Enrollment Portal: Applications must be submitted via ePREP (https://eprep.health.maryland.gov).
• Future System: MPRIME will replace ePREP for all provider enrollments and updates starting in October 2026.
• Required Documentation: Applicants must upload their BHA license, national accreditation certificate, and NPI verification.
• Revalidation: Enrolled providers must revalidate their Medicaid enrollment every five years, or more frequently if directed by CMS mandates.

6. Staffing, Training and Background Checks

Behavioral health programs must employ qualified, licensed professionals in accordance with Maryland's Health Occupations Article. Staffing ratios and specific credential requirements vary based on the service type (e.g., OMHC vs. PRP).

All staff with direct participant contact must undergo comprehensive criminal background checks and complete state-mandated training on abuse reporting and crisis intervention.

• Medical Director: OMHCs must have a licensed psychiatrist serving as the Medical Director.
• Clinical Director: Programs must employ a licensed mental health professional (e.g., LCSW-C, LCPC) to oversee clinical operations.
• Rehabilitation Specialists: PRPs require designated rehabilitation specialists with specific experience in psychiatric rehabilitation.
• Background Checks: State and federal criminal history records checks (CHRC) are required for all direct care staff.

7. Documentation, Policies and Records

Providers must maintain comprehensive clinical records for each participant, documenting assessments, individualized treatment plans, and progress notes for every billed encounter. Records must comply with HIPAA and Maryland's strict confidentiality laws for mental health records.

Agencies are also required to maintain robust internal policies covering incident reporting, grievance procedures, and quality assurance.

• Individualized Treatment Plan (ITP): Must be developed within specific timeframes following admission and updated regularly based on participant progress.
• Encounter Notes: Every billed service must be supported by a progress note detailing the intervention, duration, and participant response.
• Incident Reporting: Critical incidents must be reported to BHA and Optum Maryland within 24 hours of occurrence.
• Record Retention: Clinical and financial records must be retained for a minimum of six years following the participant's discharge.

8. Billing, Rates and Claims

Reimbursement for Maryland's Public Behavioral Health System is managed by Optum Maryland, the state's ASO. Providers must submit claims electronically through the Optum provider portal or via an approved clearinghouse.

Rates are established by the Maryland Department of Health and are published in the PBHS fee schedule, which is updated annually or when legislative rate increases occur.

• Claims Portal: Claims are submitted and managed through the Optum Maryland Incedo Provider Portal.
• Prior Authorization: Many services, including PRP and IOP, require prior authorization from Optum Maryland before service delivery.
• Fee Schedule: Current reimbursement rates are published on the MDH BHA and Optum Maryland websites.
• Timely Filing: Claims must generally be submitted within 12 months of the date of service to be eligible for reimbursement.

9. Approval Sequence and Timeline

The pathway to becoming a fully enrolled behavioral health provider in Maryland is sequential and can take 12 to 18 months, largely due to the accreditation requirement. Providers must secure their physical location and establish policies before applying.

The moratorium on certain services in specific counties halts this sequence at the Medicaid enrollment phase, meaning providers should verify geographic eligibility before investing in the licensure process.

• Step 1: Establish legal entity, secure location, and develop COMAR-compliant policies.
• Step 2: Apply for initial BHA licensure and undergo preliminary site inspection (3-6 months).
• Step 3: Achieve national accreditation from CARF, Joint Commission, or COA (6-12 months).
• Step 4: Submit Medicaid enrollment application via ePREP (90-120 days for processing, subject to moratoria).

10. Common Denials and Survey Findings

Applications are most frequently denied due to attempting to enroll restricted services in moratorium counties. In these cases, ePREP applications are returned without processing.

During licensure surveys, BHA commonly cites providers for incomplete personnel files, inadequate treatment plan documentation, and failure to maintain continuous national accreditation.

• Moratorium Rejections: Automatic denial of ePREP applications for PRP, PHP, and IOP services in the 10 restricted counties.
• Accreditation Lapses: Suspension or revocation of BHA license if national accreditation expires or is revoked.
• Incomplete Background Checks: Citations for allowing staff to provide direct care before background check results are received.
• Treatment Plan Deficiencies: Recoupment of funds if billed services are not supported by an active, signed individualized treatment plan.

11. Key Contacts and Resources

Prospective providers should regularly consult the MDH and Optum Maryland websites for transmittals, policy updates, and fee schedule changes. The BHA Licensing and Certification division is the primary point of contact for regulatory compliance.

For Medicaid enrollment inquiries, providers must utilize the ePREP system and its associated support channels.

• BHA Licensing Email: [email protected]
• BHA Licensing Website: https://health.maryland.gov/bha/Pages/Licensing-and-Certification.aspx
• Medicaid ePREP Portal: https://eprep.health.maryland.gov
• Optum Maryland Provider Relations: https://maryland.optum.com

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