Maryland - Housing Stabilization — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In Maryland, Housing Stabilization services—encompassing housing search, application assistance, landlord mediation, and tenancy retention—are primarily funded through two Medicaid authorities: the Assistance in Community Integration Services (ACIS) § 1115 pilot program and the Community Options (CO) Waiver under the umbrella of Housing Support Services. These programs target high-risk Medicaid beneficiaries, including those with chronic health conditions, frequent emergency department utilization, or those transitioning out of institutional settings, providing them with the targeted case management and tenancy supports needed to secure and maintain independent housing.

The single biggest structural barrier to entry for prospective providers in Maryland is the Lead Entity gatekeeping model under the ACIS program. Standalone providers cannot directly enroll with Maryland Medicaid to bill for ACIS housing stabilization; they must be competitively selected by and subcontract under a designated county or municipal Lead Entity, such as a Local Health Department or county government. For the CO Waiver pathway, providers face a strict pre-approval gate requiring authorization from the Maryland Department of Health (MDH) Office of Long Term Services and Supports (OLTSS) before an enrollment application will even be accepted in the state's provider portal.

1. Service Definition and Scope

Maryland Medicaid defines housing stabilization as targeted interventions that assist individuals in finding, securing, and maintaining community-based housing. The service is bifurcated into two distinct phases: housing transition (pre-tenancy) and housing sustaining (tenancy retention).

These services are strictly administrative and supportive. Medicaid funds cannot be used to pay for direct room and board, rent, or utility costs, though separate state or local grant funds may be braided with Medicaid services to cover those hard costs.

• Target Population: Medicaid beneficiaries meeting institutional level of care (CO Waiver) or those with chronic health conditions and housing insecurity (ACIS).
• Housing Transition: Assistance with housing searches, completing rental applications, securing move-in funds, and negotiating leases.
• Housing Sustaining: Ongoing landlord mediation, lease compliance education, eviction prevention, and connecting participants to community resources.
• Excluded Services: Direct payment of rent, security deposits, or utility bills using Medicaid service dollars.
• Service Limits: Billed hours or monthly contacts are strictly capped based on the participant's approved Person-Centered Service Plan (PCSP).

2. Regulatory and Oversight Agencies

The Maryland Department of Health (MDH) is the single state agency responsible for Medicaid administration. Within MDH, specific divisions and local partners manage the day-to-day oversight of housing stabilization services.

Because housing stabilization spans both healthcare and social services, oversight is highly decentralized, relying heavily on county-level administration and local resource centers to manage participant intake and provider monitoring.

• Maryland Department of Health (MDH): The overarching state Medicaid agency responsible for federal compliance and provider enrollment.
• Office of Long Term Services and Supports (OLTSS): The MDH division that administers the Community Options Waiver and issues initial provider approvals.
• Local Health Departments (LHDs): Act as the designated Lead Entities for the ACIS pilot program in participating counties, managing provider subcontracts.
• Maryland Access Point (MAP): Local aging and disability resource centers that handle initial participant intake, eligibility screening, and referrals.
• Supports Planning Agencies: Independent entities contracted by MDH to develop the participant's Person-Centered Service Plan and authorize specific service hours.

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland employs strict structural preconditions that block open-market enrollment for housing stabilization services. Providers cannot simply open a business and apply to bill Medicaid for these services.

Depending on the specific Medicaid authority (ACIS vs. CO Waiver), a provider must either win a local procurement contract or pass a rigorous state-level programmatic review before accessing the Medicaid enrollment portal.

• ACIS Lead Entity Subcontracting: Providers cannot enroll directly for ACIS; they must respond to a Request for Proposals (RFP) and be selected as a subcontractor by an approved county Lead Entity.
• OLTSS Pre-Approval: For the CO Waiver, applicants must submit a programmatic application directly to OLTSS and receive an official approval letter before attempting Medicaid enrollment.
• National Provider Identifier (NPI): The agency must obtain a Type 2 (Organizational) NPI from the NPPES registry prior to any application.
• Certificate of Good Standing: Applicants must possess an active Certificate of Good Standing from the Maryland State Department of Assessments and Taxation (SDAT).
• Physical Location Requirement: Providers must maintain a commercial business address in Maryland; virtual-only or out-of-state headquarters without a local branch are generally rejected.

4. Licensure and Certification Requirements

Maryland does not issue a distinct "Housing Stabilization Provider" license. Because this is a community-based support service rather than a facility-based clinical service, providers are approved based on programmatic certification rather than traditional healthcare facility licensure.

Instead of a state license, providers must demonstrate compliance with federal community integration standards and hold standard local business credentials.

• Facility Licensure: No specific state health facility license is required, as services are delivered in the community or the participant's home.
• HCBS Settings Rule Compliance: Providers must sign an attestation and demonstrate compliance with the CMS Final Rule, ensuring services promote full community integration.
• General Business License: Providers must obtain a standard business license from the Clerk of the Circuit Court in the Maryland county where they operate.
• Lead Entity Certification: For ACIS, the provider must meet any specific accreditation or certification standards mandated by the county Lead Entity's RFP.
• Medicaid Program Certification: The OLTSS approval letter serves as the de facto state certification required to operate as a CO Waiver provider.

5. Medicaid Provider Enrollment

Once programmatic pre-approval is secured, providers must formally enroll with Maryland Medicaid. The state currently utilizes the electronic Provider Revalidation and Enrollment Portal (ePREP), but is transitioning to a new system.

In October 2026, Maryland Medicaid will transition from ePREP to the Maryland Provider Registration and Information Management Enterprise (MPRIME). Providers must ensure their enrollment is active and revalidated in the current system to migrate successfully.

• Enrollment Portal: Applications must be submitted through ePREP (transitioning to MPRIME in October 2026).
• Provider Type Selection: Applicants must select the specific HCBS Waiver or ACIS provider type and specialty code designated in their OLTSS/Lead Entity approval.
• Application Fee: HCBS providers are typically exempt from the federal Medicaid application fee, but must verify their specific exemption status within ePREP.
• MCO Credentialing: After fee-for-service enrollment, providers serving managed care populations must separately credential with Maryland HealthChoice MCOs (e.g., MedStar Family Choice, Priority Partners).
• EFT Enrollment: Providers must complete Electronic Funds Transfer (EFT) enrollment through the state's Comptroller office to receive payments.

6. Staffing, Training and Background Checks

Maryland requires housing stabilization staff to meet specific educational and experiential benchmarks to ensure they can effectively navigate complex housing markets and social service systems.

Strict background screening is mandatory before any employee can have direct contact with Medicaid beneficiaries.

• Direct Support Qualifications: Staff typically must possess a high school diploma or GED and at least one year of experience in human services or housing navigation.
• Supervisor Qualifications: Program supervisors generally require a Bachelor's degree in social work, psychology, or a related human services field.
• Criminal Background Checks: Mandatory fingerprint-based state and federal background checks must be processed through the Maryland Criminal Justice Information System (CJIS).
• Exclusion Screenings: Agencies must screen all staff monthly against the federal OIG LEIE and the Maryland Medicaid exclusion lists.
• Mandated Training: Staff must complete state-approved training on person-centered planning, the HCBS Settings Rule, and mandated reporting of abuse, neglect, and exploitation.

7. Documentation, Policies and Records

Robust documentation is critical for housing stabilization providers in Maryland. Because the service is administrative, the proof of service delivery relies entirely on detailed progress notes and housing records.

Providers must maintain comprehensive files that link every billed intervention directly to the goals outlined in the participant's authorized care plan.

• Person-Centered Service Plan (PCSP): Providers must maintain a current copy of the MAP/Supports Planner-approved PCSP detailing specific housing goals.
• Progress Notes: Every billed encounter requires a detailed note including the date, start/stop times, specific housing intervention provided, and participant response.
• Housing Documentation: Client files must include copies of rental applications, secured lease agreements, eviction notices, and landlord communications.
• Record Retention: Maryland Medicaid regulations require all clinical and financial records to be retained for a minimum of six years from the date of service.
• Incident Reporting: Providers must have written policies for reporting critical incidents to OLTSS and the local MAP office within 24 hours.

8. Billing, Rates and Claims

Billing methodologies for housing stabilization in Maryland vary significantly depending on whether the provider is operating under the ACIS pilot or the CO Waiver.

Providers must utilize the state's designated electronic systems to verify authorizations before rendering services, as retroactive authorizations are rarely granted.

• ACIS Payment Structure: Often structured as a Per Member Per Month (PMPM) capitated rate or milestone-based payment negotiated directly with the county Lead Entity.
• CO Waiver Rates: Billed in 15-minute increments or daily rates according to the published MDH OLTSS fee schedule.
• Prior Authorization: All CO Waiver services must be prior-authorized in the LTSSMaryland system by a Supports Planner before service delivery.
• Claims Submission: Fee-for-service claims are submitted via the MMIS/ePREP portal, while MCO or ACIS claims are submitted to the respective health plan or Lead Entity.
• EVV Requirements: While personal care requires Electronic Visit Verification (EVV), providers must verify current state guidance on whether EVV applies to their specific housing support billing codes.

9. Approval Sequence and Timeline

Becoming a fully enrolled provider is a multi-step, sequential process that can take several months to over a year, heavily dependent on local procurement cycles.

Providers cannot skip steps; Medicaid enrollment will be immediately rejected if the programmatic pre-approvals are not already secured and attached.

• Step 1: Respond to a Lead Entity RFP (ACIS) or submit a programmatic application to OLTSS (CO Waiver). Timeline: 1 to 3 months.
• Step 2: Receive official selection/approval letter from the Lead Entity or OLTSS. Timeline: 30 to 60 days post-submission.
• Step 3: Submit the formal Medicaid enrollment application via ePREP (or MPRIME). Timeline: 30 to 90 days for state processing.
• Step 4: Complete MCO credentialing and contracting (if applicable). Timeline: 90 to 120 days after fee-for-service Medicaid ID issuance.
• Step 5: Receive participant referrals from MAP or the Lead Entity and begin service delivery.

10. Common Denials and Survey Findings

Applications and claims are frequently denied due to administrative oversights, failure to understand the gatekeeping structure, or poor documentation practices.

State auditors and Lead Entities regularly review provider records, and failure to maintain strict compliance often results in the recoupment of paid funds.

• Missing Pre-Approval: ePREP applications are automatically denied if the required OLTSS or Lead Entity approval letter is missing.
• Procurement Failure: For ACIS, providers are denied entry simply because they failed to win a subcontract during a county's competitive RFP cycle.
• Documentation Deficiencies: Auditors frequently recoup funds when progress notes lack specific housing-related interventions or do not match the billed time.
• Background Check Lapses: Providers are cited for allowing staff to deliver services before CJIS fingerprint clearances are fully returned and reviewed.
• Unauthorized Services: Claims are denied when services are provided before the Supports Planner has officially entered the authorization into LTSSMaryland.

11. Key Contacts and Resources

Navigating the Maryland Medicaid system requires coordination with multiple state and local entities. Providers should establish direct lines of communication with their oversight bodies.

Utilizing the correct help desks and resource centers is essential for resolving enrollment delays and billing issues.

• MDH OLTSS: The primary state office managing the Community Options Waiver and initial provider programmatic approvals.
• Maryland Medicaid Provider Enrollment: Handles ePREP (and future MPRIME) system issues and enrollment status inquiries (1-844-463-7768).
• LTSSMaryland Help Desk: Provides technical support for the state's case management and authorization system.
• Maryland Access Point (MAP): Local agencies responsible for participant eligibility, intake, and referrals (1-844-627-5465).
• Local Health Departments: The primary point of contact for providers seeking to participate in the ACIS pilot program in their respective counties.

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