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

Last reviewed: 2026-08-16

Personal Assistance Services (PAS) in Maryland provide critical hands-on support with activities of daily living (ADLs) such as bathing, dressing, toileting, and transferring in a participant's own home. These services are primarily funded through Maryland Medicaid's Community First Choice (CFC) program and the Community Options (CO) Waiver, requiring providers to navigate both state facility licensure and Medicaid provider enrollment.

The single biggest structural barrier to entry for a new PAS provider in Maryland is the requirement to obtain a Residential Service Agency (RSA) license from the Office of Health Care Quality (OHCQ) before a Medicaid enrollment application can even be submitted. While RSAs are exempt from the Certificate of Need (CON) process that restricts Home Health Agencies, applicants cannot pass the OHCQ gate without submitting a mandatory RSA Certification regarding the employment and classification of personal care aides pursuant to Health General §19-4A-11.

1. Service Definition and Scope

In Maryland, Personal Assistance Services (PAS) encompass hands-on assistance with activities of daily living (ADLs) and instrumental activities of daily living (IADLs) delivered in the participant's private residence. These services are designed to prevent institutionalization and are authorized under specific Medicaid waiver and state plan programs.

Services must be strictly aligned with an individual's Person-Centered Plan (PCP), which is developed by a state-designated Supports Planner. Providers are not permitted to deliver or bill for services outside the scope and frequency authorized in this plan.

2. Regulatory and Oversight Agencies

The Maryland Department of Health (MDH) serves as the primary umbrella agency overseeing both licensure and Medicaid participation. Within MDH, responsibilities are bifurcated: the Office of Health Care Quality (OHCQ) handles facility and agency licensure, while the Medical Care Programs division manages Medicaid provider enrollment and reimbursement.

Providers must also interact with local entities, such as Area Agencies on Aging (AAAs) and Local Health Departments, which act as Supports Planning Agencies to coordinate participant care and generate referrals.

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland does not require a Certificate of Need (CON) for Residential Service Agencies (RSAs), nor are there active moratoria or closed network procurements for standard PAS providers. The state's behavioral health moratorium does not apply to community personal assistance.

However, strict structural prerequisites exist before Medicaid will accept an enrollment application. A provider cannot simply apply to Medicaid; they must first secure an RSA license, which itself requires specific corporate structuring and statutory certifications regarding labor practices.

4. Licensure and Certification Requirements

To provide Medicaid PAS, agencies must be licensed as a Residential Service Agency (RSA) by OHCQ to provide Level Two or Level Three home care, pursuant to COMAR 10.09.84.06. The application process requires submission of comprehensive operational policies, administrator credentials, and training curricula.

OHCQ mandates that all applications be typed and submitted electronically via their Smartsheet portal. Handwritten applications are immediately rejected and returned to the applicant.

5. Medicaid Provider Enrollment

Once the RSA license is secured, providers must enroll in the Maryland Medical Assistance Program. Enrollment establishes the billing relationship and assigns the Medicaid provider number necessary for reimbursement.

Enrollment is currently processed through the electronic Provider Registration and Enrollment Portal (ePREP). Providers should be aware that MDH is replacing ePREP with a new system called MPRIME in October 2026.

6. Staffing, Training and Background Checks

Direct care staff must meet specific qualifications to deliver PAS safely and legally. Agencies are responsible for ensuring all Personal Care Aides (PCAs) and Certified Nursing Assistants (CNAs) are properly vetted, trained, and supervised.

Maryland places a strong emphasis on nursing oversight. Even for non-medical PAS, an RN case monitor must supervise the care delivery and ensure the participant's Person-Centered Plan is being executed correctly.

7. Documentation, Policies and Records

OHCQ and Maryland Medicaid require RSAs to maintain comprehensive policy and procedure manuals. These documents are heavily scrutinized during the initial OHCQ licensure survey and subsequent Medicaid audits.

Providers must establish robust electronic and physical record-keeping systems that comply with HIPAA and state data retention laws, particularly concerning participant care logs and staff credentialing.

8. Billing, Rates and Claims

PAS providers bill the Maryland Medical Assistance Program directly for fee-for-service waiver participants. Claims and service logging are heavily integrated with the state's Electronic Visit Verification (EVV) system.

Providers cannot bill for services that exceed the frequency or scope authorized in the participant's Person-Centered Plan. Accurate banking information must be established during enrollment to facilitate Electronic Funds Transfer (EFT).

9. Approval Sequence and Timeline

Becoming a PAS provider in Maryland is a strictly sequential process. Applications cannot be submitted concurrently; the RSA license must be fully approved and in hand before Medicaid enrollment can begin.

The entire process from corporate formation to billing readiness typically takes several months, heavily dependent on the completeness of the OHCQ application and the speed of background checks.

10. Common Denials and Survey Findings

Applications and claims are frequently delayed or denied due to administrative mismatches or incomplete documentation. Maryland has increased RSA enforcement in recent years, leading to closer application vetting.

During OHCQ surveys, inspectors heavily target staffing files and worker classification. Missing credentials or lapsed background checks are among the most common citations.

11. Key Contacts and Resources

Prospective providers should bookmark the primary state portals and regulatory pages. These resources provide the necessary forms, transmittals, and system access points required for compliance.

Monitoring these sites is critical, as MDH frequently updates transmittals regarding system transitions (such as the move from ePREP to MPRIME) and EVV requirements.

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