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Maryland - Home Health Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Maryland Department of Health's Office of Health Care Quality (OHCQ) licenses Home Health Agencies (HHAs) to deliver intermittent skilled nursing and therapy under COMAR 10.07.10, but only after an applicant secures a Certificate of Need (CON) from the Maryland Health Care Commission (MHCC). This CON requirement strictly limits market entry, requiring applicants to prove geographic need under the State Health Plan (COMAR 10.24.16) before OHCQ will even accept a licensure application.

Once the CON is obtained, agencies must submit the OHCQ Application for a Home Health Agency License, pass an initial on-site survey, and secure Medicare certification or accreditation. Approved agencies then enroll in Maryland Medicaid through the ePREP portal to bill for skilled home health services provided to eligible beneficiaries.

1. Service Definition and Scope

Home Health Agencies in Maryland provide intermittent skilled medical services, including nursing, physical therapy, and occupational therapy, to clients in their residences. These services require a physician's signed order and are designed for individuals who need skilled care but do not require hospitalization or facility placement.

The scope of practice is strictly defined by state licensure rules, ensuring that all therapeutic and nursing interventions are delivered under proper clinical supervision.

2. Regulatory and Oversight Agencies

Multiple state entities govern the approval and oversight of HHAs in Maryland. The MHCC controls market entry, OHCQ handles licensure and surveys, and the Medicaid program manages provider enrollment and reimbursement.

Providers must interact with each of these agencies sequentially to achieve full operational and billing status.

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland is a strict Certificate of Need (CON) state for Home Health Agencies. An entity cannot apply for an OHCQ license without first obtaining a CON or a formal exemption from the MHCC.

This structural precondition blocks any new agency from entering the market unless they can prove a quantitative need for additional home health services in a specific jurisdiction based on the State Health Plan.

4. Licensure and Certification Requirements

After clearing the CON hurdle, applicants submit the Application for a Home Health Agency License to OHCQ. The application requires extensive documentation, including operational procedures and proof of insurance, followed by an on-site survey.

OHCQ mandates that the application be typed; handwritten submissions are automatically rejected.

5. Medicaid Provider Enrollment

Licensed HHAs must enroll in Maryland Medicaid to bill for services. This is done through the electronic Provider Revalidation and Enrollment Portal (ePREP), which requires the OHCQ license and Medicare certification or accreditation details.

Enrollment allows the agency to participate in fee-for-service Medicaid and serves as a prerequisite for credentialing with HealthChoice Managed Care Organizations.

6. Staffing, Training and Background Checks

Maryland HHAs must maintain qualified clinical staff to deliver skilled services. Agencies are required to have a Professional Advisory Group and ensure all personnel meet state licensing and background check standards.

Contracted staff are held to the same clinical and administrative standards as direct employees.

7. Documentation, Policies and Records

OHCQ requires HHAs to submit specific written procedures during the application process and maintain comprehensive patient records. These policies must align with COMAR 10.07.10.04.

Clinical records must demonstrate that care is delivered strictly according to the physician's orders.

8. Billing, Rates and Claims

HHA services are billed to Maryland Medicaid or the respective HealthChoice MCO using standard CMS claim formats. Rates are established by MDH and vary based on the specific skilled service provided.

Providers must verify eligibility and secure any necessary prior authorizations before initiating billable care.

9. Approval Sequence and Timeline

The pathway to becoming a billing HHA in Maryland is sequential and lengthy due to the CON process. Providers cannot skip steps or apply concurrently for MHCC and OHCQ approvals.

Any deficiencies found during the OHCQ survey must be corrected via a formal Plan of Correction before a license is issued.

10. Common Denials and Survey Findings

OHCQ surveys rigorously evaluate clinical procedures and administrative compliance. Failures often stem from missing documentation or operating outside the scope of the CON.

Administrative errors on the initial application will cause immediate delays before a survey is even scheduled.

11. Key Contacts and Resources

Providers should rely on official state resources for the most current regulations, forms, and portal access. The following links direct to the primary regulatory bodies for Maryland HHAs.

Always verify current CON methodologies and application versions directly with MHCC and OHCQ.

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