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

Last reviewed: 2026-09-10

Maryland funds tenancy support, housing search, and landlord mediation primarily through the Assistance in Community Integration Services (ACIS) pilot under the HealthChoice section 1115 waiver, rather than a standalone "Housing Stabilization" state plan benefit. Providers seeking to deliver these services cannot enroll directly with the state as independent housing stabilization agencies; they must first secure a subcontract with a state-designated ACIS Lead Entity, which is typically a county or municipal health department awarded a specific allocation of participant slots by the Maryland Department of Health (MDH).

Because Maryland does not issue a distinct facility or agency license for housing stabilization, oversight relies on the general Home and Community-Based Services (HCBS) provider rules under COMAR 10.09.36 and the specific contractual terms of the ACIS Lead Entity. For individuals with intellectual and developmental disabilities, similar tenancy supports are covered as Housing Support Services under the Developmental Disabilities Administration (DDA) Community Pathways Waiver, which requires DDA programmatic pre-approval before a provider can submit an application through Maryland's ePREP (transitioning to MPRIME) Medicaid enrollment portal.

1. Service Definition and Scope

Maryland does not cover a universal service named "Housing Stabilization." Instead, tenancy support is delivered through the ACIS pilot for high-utilizer Medicaid beneficiaries experiencing homelessness, or as Housing Support Services under the DDA Community Pathways Waiver. Both authorities cover the core components of housing search, application assistance, landlord mediation, and retention planning.

These services are strictly administrative and supportive. Medicaid funds cannot be used to pay for room and board, rent, or security deposits directly, though providers are expected to connect participants with local housing vouchers or Montgomery County's local Housing Stabilization Services grants.

• ACIS Tenancy Support: Includes housing search, landlord negotiation, lease education, and eviction prevention interventions.
• DDA Housing Support Services: Assists waiver participants in identifying independent, integrated housing options and navigating the application process.
• Target Population (ACIS): Medicaid beneficiaries who are experiencing chronic homelessness or frequent institutional transitions and meet specific health criteria.
• Target Population (DDA): Individuals enrolled in the Community Pathways Waiver seeking to transition from provider-owned settings to independent living.
• Exclusions: Direct payment of rent, utilities, or security deposits is strictly prohibited under Medicaid HCBS rules.
• Service Setting: Must be delivered in the community or the participant's home, fully compliant with the HCBS Settings Rule.

2. Regulatory and Oversight Agencies

The Maryland Department of Health (MDH) is the single state Medicaid agency responsible for the HealthChoice 1115 waiver and the ACIS pilot. Within MDH, the Developmental Disabilities Administration (DDA) oversees the Community Pathways Waiver and its specific housing support providers.

While the Office of Health Care Quality (OHCQ) licenses traditional residential and healthcare facilities, it does not issue a specific license for housing stabilization agencies. Instead, oversight is managed through provider enrollment compliance and Lead Entity monitoring.

• Maryland Department of Health (MDH): Administers the Medicaid program and the ACIS pilot (https://health.maryland.gov).
• Developmental Disabilities Administration (DDA): Manages the Community Pathways Waiver and approves DDA housing support providers (https://dda.health.maryland.gov).
• Office of Health Care Quality (OHCQ): Conducts incident investigations and surveys for licensed HCBS providers, though housing support is largely unlicensed (https://health.maryland.gov/ohcq).
• ACIS Lead Entities: County or city governments (e.g., Baltimore City Health Department) that hold the state contract and oversee subcontracted providers (https://health.maryland.gov/mmcp/Pages/ACIS-Pilot.aspx).

3. Gatekeeping Prerequisites: Who Can Even Apply

The ACIS Lead Entity subcontract requirement blocks any applicant from enrolling directly as an ACIS provider in Maryland. MDH awards a capped number of ACIS slots to approved Lead Entities (usually local health departments or county governments) through a competitive Request for Applications (RFA) process. Agencies wishing to provide the actual tenancy support services must be selected by and subcontract with one of these Lead Entities.

For DDA Housing Support Services, providers must complete the DDA Provider Application process and receive programmatic approval from the DDA Regional Office before they can initiate a Medicaid enrollment application. There is no open-door enrollment for standalone housing stabilization outside of these two specific pathways.

• ACIS Lead Entity Subcontract: Required affiliation; providers cannot enroll in ACIS without a formal contract with a designated county/city Lead Entity.
• Slot Caps: ACIS is limited to a specific number of individuals per year (e.g., 900 slots statewide), restricting provider network expansion.
• DDA Programmatic Approval: Required before a provider can enroll to offer Housing Support Services under the Community Pathways Waiver.
• HCBS Settings Rule Compliance: Providers must pass a settings assessment prior to enrollment to prove they do not isolate participants.
• Moratoria: Maryland Medicaid periodically places holds on new provider enrollments (e.g., the July 2026 hold for moderate/high-risk providers during the MPRIME transition).

4. Licensure and Certification Requirements

Maryland does not have a specific licensure category for housing stabilization or tenancy support agencies. Providers must instead meet the general conditions for Medicaid provider participation outlined in COMAR 10.09.36.

If the agency also provides personal care or residential services, they must hold the appropriate license from OHCQ (such as a Residential Service Agency license). However, for pure tenancy support, certification is achieved through the DDA approval process or the ACIS Lead Entity vetting process.

• COMAR 10.09.36 Compliance: All providers must adhere to the general Medicaid HCBS provider participation regulations.
• Unlicensed Status: Tenancy support itself does not require an OHCQ facility or agency license.
• Lead Entity Certification: ACIS providers must meet the specific organizational and quality standards set by their contracting Lead Entity.
• DDA Certification: DDA providers must complete the DDA's mandatory provider training and policy review.
• Business Registration: Must be registered and in good standing with the Maryland State Department of Assessments and Taxation (SDAT).

5. Medicaid Provider Enrollment

Providers must enroll in the Maryland Medicaid program using the state's electronic portal. Maryland is currently transitioning its enrollment system from ePREP (electronic Provider Revalidation and Enrollment Portal) to MPRIME.

During this transition, certain provider types may face temporary enrollment holds. Applicants must submit their Lead Entity contract or DDA approval letter as an attachment within the portal to be approved for the specific housing support billing codes.

• Enrollment Portal: ePREP, transitioning to MPRIME (https://eprep.health.maryland.gov).
• Provider Type: Enrolled under the specific waiver provider type designated by DDA or the ACIS program.
• Application Fee: Subject to the federal Medicaid application fee (approximately $709 in 2024) unless waived or paid to Medicare.
• Risk Category: Typically categorized as limited or moderate risk, requiring standard screening.
• Required Attachments: W-9, SDAT certificate of good standing, and DDA approval or ACIS Lead Entity contract.

6. Staffing, Training and Background Checks

Staff providing tenancy supports must meet the qualifications established by the ACIS pilot or the DDA waiver. This generally requires a high school diploma or equivalent, plus specific experience in human services, case management, or housing navigation.

All direct support professionals and case managers must undergo criminal background checks through the Maryland Department of Public Safety and Correctional Services (CJIS) and be screened against state and federal Medicaid exclusion lists.

• Minimum Education: High school diploma or GED required for direct support staff; bachelor's degree often preferred by Lead Entities for case managers.
• Background Checks: Mandatory fingerprint-based state and FBI criminal history records check via Maryland CJIS.
• Exclusion Screening: Monthly screening against the OIG LEIE and Maryland Medicaid exclusion lists.
• Training Requirements: Must complete DDA-mandated trainings (if under Community Pathways) or ACIS-specific trauma-informed care and housing first trainings.
• CPR/First Aid: Basic life support certification is typically required for staff conducting in-home or community visits.

7. Documentation, Policies and Records

Providers must maintain comprehensive records that align with the participant's Person-Centered Plan (PCP). The PCP, developed by a Coordinator of Community Services (CCS) or ACIS case manager, must explicitly authorize the housing support services.

Agencies must also maintain policies demonstrating compliance with the HCBS Settings Rule, ensuring participants have lease protections, privacy, and control over their living arrangements.

• Person-Centered Plan (PCP): Services must be documented and authorized in the participant's PCP prior to delivery.
• Progress Notes: Must document the date, time, duration, and specific housing-related intervention provided during each encounter.
• HCBS Settings Compliance: Policies must guarantee participant rights, including lease agreements and freedom from coercion.
• Record Retention: Medicaid records must be retained for a minimum of six years from the date of service.
• Incident Reporting: Must comply with MDH and DDA reportable event policies for any adverse incidents involving participants.

8. Billing, Rates and Claims

Billing structures differ significantly depending on the authorizing program. The ACIS pilot typically utilizes a Per-Member Per-Month (PMPM) payment model, where the Lead Entity receives the PMPM from MDH and pays the subcontracted provider based on their negotiated rate.

Under the DDA Community Pathways Waiver, Housing Support Services are billed in 15-minute increments using specific HCPCS codes. Providers submit claims directly to the state's MMIS or through the designated managed care organization if applicable.

• ACIS Payment Model: Per-Member Per-Month (PMPM) rate paid to Lead Entities, who then reimburse subcontracted providers.
• DDA Billing Units: Billed in 15-minute increments for direct time spent assisting the participant with housing tasks.
• Prior Authorization: All DDA services require prior authorization in the state's LTSSMaryland system.
• Claim Submission: Claims are submitted electronically via the MMIS/ePREP portal or clearinghouse.
• Rate Setting: DDA rates are established by MDH and published in the annual DDA rate chart.

9. Approval Sequence and Timeline

The timeline to become an approved provider depends heavily on the procurement cycles of ACIS Lead Entities or the DDA regional office review times. An agency cannot simply apply at any time; they must wait for a Lead Entity to issue an RFA or open their network.

Once a contract or DDA approval is secured, the Medicaid enrollment process through ePREP/MPRIME typically takes 60 to 90 days, assuming no enrollment holds are in effect.

• Step 1: Identify an ACIS Lead Entity with available slots or apply for DDA programmatic approval.
• Step 2: Submit a proposal or application to the Lead Entity/DDA and complete required interviews or site reviews.
• Step 3: Execute a formal subcontract or receive the DDA approval letter.
• Step 4: Submit the Medicaid provider enrollment application via ePREP/MPRIME with the required attachments.
• Step 5: Pass the state's enrollment screening and receive a Medicaid provider number (60-90 days).

10. Common Denials and Survey Findings

Applications are most frequently rejected because the provider attempts to enroll directly in ePREP without first securing the mandatory ACIS Lead Entity contract or DDA pre-approval. The state will automatically deny these applications.

During audits or desk reviews, providers often face recoupments for failing to link their daily progress notes directly to the housing goals outlined in the participant's Person-Centered Plan, or for billing administrative time (like driving without the participant) as direct service time.

• Missing Prerequisites: Denials for lacking a Lead Entity contract or DDA approval letter.
• Settings Rule Violations: Findings related to steering participants into provider-owned housing rather than independent tenancy.
• Documentation Gaps: Recoupments for progress notes that lack start/stop times or fail to describe the specific intervention.
• Unapproved Staff: Findings for utilizing staff who have not completed the mandatory background checks or training.
• PCP Misalignment: Billing for housing services that were not formally authorized in the current Person-Centered Plan.

11. Key Contacts and Resources

Providers should consult the Maryland Department of Health and the Developmental Disabilities Administration for the most current waiver appendices, rate charts, and enrollment manuals.

For the ACIS pilot, prospective providers must contact their local county health department to inquire about Lead Entity status and subcontracting opportunities.

• Maryland Department of Health (MDH): https://health.maryland.gov
• Developmental Disabilities Administration (DDA): https://dda.health.maryland.gov
• ePREP / MPRIME Enrollment Portal: https://eprep.health.maryland.gov
• ACIS Pilot Information: https://health.maryland.gov/mmcp/Pages/ACIS-Pilot.aspx
• COMAR Regulations (Title 10): https://dsd.maryland.gov

See all Maryland services · Maryland Medicaid consulting · book a consultation.