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Maryland - Personal Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Maryland funds hands-on assistance with activities of daily living through the Community Personal Assistance Services (CPAS) program and various Medicaid waivers, requiring providers to first hold a Residential Service Agency (RSA) license issued by the Office of Health Care Quality (OHCQ). The state mandates that agencies specifically qualify to provide Level Two or Level Three home care services under COMAR 10.09.20.05 to bill for these personal care supports.

Approval requires a sequential process beginning with a business plan and policy review by OHCQ, followed by mandatory RSA Certification regarding worker classification, and concluding with Medicaid enrollment through the ePREP or MPRIME portal. Applicants must secure an official Letter of Good Standing from the Maryland Department of Assessments and Taxation before OHCQ will accept the initial licensure application.

1. Service Definition and Scope

In Maryland, Personal Assistance Services encompass hands-on assistance with activities of daily living (ADLs) such as bathing, dressing, transferring, and toileting, delivered in the participant's home. Under COMAR 10.09.20, these services are delivered through the Community Personal Assistance Services (CPAS) program and related Medicaid waivers.

Providers operate as Residential Service Agencies (RSAs) authorized for Level Two (personal care) or Level Three (complex care) services. The scope excludes skilled nursing unless the RSA is specifically licensed and staffed to provide those higher-level medical services.

2. Regulatory and Oversight Agencies

The Maryland Department of Health (MDH) divides oversight between licensure and Medicaid enrollment. The Office of Health Care Quality (OHCQ) handles the initial RSA licensure, policy review, and ongoing compliance surveys.

The MDH Medical Care Programs division manages Medicaid provider enrollment and claims processing. Providers interact with the ePREP or MPRIME portals to maintain their active billing status.

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland does not impose a Certificate of Need (CON), county sponsorship requirement, or closed-network moratorium on new Residential Service Agencies providing personal assistance. The market is open to any qualified entity that completes the sequential licensure and enrollment steps.

However, structural prerequisites exist before OHCQ will accept an RSA application. The applicant must obtain a Letter of Good Standing from SDAT, and an individual with authority over pay practices must complete the mandatory RSA Certification regarding worker classification (Health General §19–4A–11).

4. Licensure and Certification Requirements

To operate, an agency must submit the RSA License Application to OHCQ along with comprehensive operational documents. There is currently no fee to apply for an initial RSA license in Maryland.

The application packet must include a one-year operating budget, a marketing plan identifying the target population, an organizational chart, and detailed policies and procedures mapped to COMAR 10.07.05.08B.

5. Medicaid Provider Enrollment

After obtaining the RSA license, agencies must enroll as participating providers through the Maryland Medicaid provider enrollment portal. The state is transitioning from the ePREP system to the Maryland Provider Registration and Information Management Enterprise (MPRIME) portal in October 2026.

Under COMAR 10.09.20.04, providers must be free from conflicts of interest and cannot have outstanding overpayments due to the Department. Enrollment requires uploading the active RSA license and completing the standard Medicaid agreement.

6. Staffing, Training and Background Checks

Direct service workers providing personal assistance must undergo strict background and training verifications. COMAR 10.09.20.05 mandates a State criminal history records check for all direct service workers, including nurses, pursuant to Health-General Article, Title 19, Subtitle 19.

RSAs may train their own staff or use outside trainers. If utilizing an outside trainer, the trainer must submit their materials to OHCQ for approval prior to conducting sessions, as required by COMAR 10.07.05.11C.

7. Documentation, Policies and Records

OHCQ requires RSAs to maintain extensive documentation of both agency operations and client care. The initial application requires a detailed description of agency services and admission criteria.

Agencies must document the assessment of potential clients before acceptance and maintain records of informed consent. Providers must also maintain documentation showing they verify participant Medicaid eligibility monthly.

8. Billing, Rates and Claims

Personal Assistance Services are billed to Maryland Medicaid on a fee-for-service basis or through managed care organizations, depending on the participant's specific waiver enrollment. Claims are processed through the state's MMIS.

Providers must utilize the Eligibility Verification System (EVS) to confirm active coverage before billing. Rates are established by the MDH Medical Care Programs and published in the provider fee schedules.

9. Approval Sequence and Timeline

The pathway to becoming a billing provider follows a strict sequence: corporate formation, RSA licensure, and finally Medicaid enrollment. Applicants must first secure their SDAT Letter of Good Standing and complete the RSA Certification.

Next, the agency submits the RSA License Application with the business plan and policies to OHCQ. Only after OHCQ issues the RSA license can the agency submit its enrollment application through ePREP/MPRIME.

10. Common Denials and Survey Findings

Initial RSA applications are frequently delayed or returned if submitted with handwritten forms, which OHCQ strictly prohibits, or if the required 1-year operating budget and marketing plan are missing.

During operations, survey deficiencies often stem from failing to complete required criminal history checks before a worker provides direct care, or misclassifying employees as independent contractors in violation of the RSA Certification acknowledgments.

11. Key Contacts and Resources

Providers must utilize official Maryland Department of Health portals for licensure and enrollment. OHCQ manages the RSA licensure process and policy reviews.

The MDH Medical Care Programs division handles the ePREP/MPRIME enrollment systems and billing guidance.

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