Maryland - Personal Emergency Response System — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In Maryland, Personal Emergency Response Systems (PERS) are covered primarily under the Community First Choice (CFC) program, the Community Options (CO) Waiver, and the Community Personal Assistance Services (CPAS) program. The service provides 24-hour monitoring and emergency dispatch for Medicaid participants who live alone, or are alone for significant parts of the day, and are at risk of falls or medical emergencies. Because PERS is an equipment and monitoring service rather than a direct-care facility, Maryland does not issue a distinct facility or agency license for this provider type.

The single biggest structural barrier to entry is not a state licensing gate, but rather the technical infrastructure and Medicaid enrollment requirements. Because there is no state license to obtain, providers must prove directly to the Maryland Department of Health (MDH) during the ePREP enrollment process that their equipment meets Underwriters Laboratories (UL) safety standards and that their monitoring center operates 24/7/365 with redundant systems. Navigating the ePREP portal (transitioning to MPRIME in October 2026) as an atypical HCBS provider without a standard state license requires precise matching of tax, business, and National Provider Identifier (NPI) records.

1. Service Definition and Scope

Maryland Medicaid defines PERS as an electronic device that enables high-risk individuals to secure help in an emergency. The system typically includes a portable "help" button (worn as a necklace or bracelet) and a base unit connected to a telephone line or cellular network.

Services are authorized through a participant's Person-Centered Plan (PCP) developed by a Supports Planner. The service scope includes the initial installation and testing of the equipment, participant education, and the ongoing monthly monitoring fee.

• Target Population: Medicaid participants in CFC, CPAS, or CO waivers who live alone or are alone for significant portions of the day.
• Covered Components: Initial equipment installation, testing, and monthly 24/7 monitoring.
• Equipment Standards: All devices must be Underwriters Laboratories (UL) approved for home healthcare signaling.
• Response Center: Must operate 24 hours a day, 7 days a week, 365 days a year without interruption.
• Prohibited Settings: PERS is not covered for individuals residing in Assisted Living Facilities or nursing homes, as those facilities must provide 24-hour supervision.
• Service Limits: Limited to one system per household, regardless of the number of eligible participants residing there.

2. Regulatory and Oversight Agencies

Because PERS does not involve hands-on personal care or residential housing, it falls outside the standard facility licensure purview of the Office of Health Care Quality (OHCQ). Instead, oversight is managed directly by the Medicaid program.

Providers interact primarily with the divisions responsible for provider enrollment and waiver operations to ensure compliance with federal HCBS settings rules and state Medicaid standards.

• Maryland Department of Health (MDH): The umbrella state Medicaid agency responsible for all provider enrollment and claims payment.
• Office of Long Term Services and Supports (OLTSS): The division within MDH that manages the CFC, CPAS, and CO waiver programs and sets PERS policy.
• Office of Health Care Quality (OHCQ): Does not license PERS providers, but may investigate critical incidents if a participant is harmed due to equipment failure.
• State Department of Assessments and Taxation (SDAT): The state agency where the provider's business entity must be registered and maintain "Good Standing" status.

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland imposes very few structural gatekeeping barriers for PERS providers compared to other healthcare services. There is no Certificate of Need (CON) required, no Facility Need Review, and no active enrollment moratorium for this service.

Furthermore, Maryland does not use a closed network or competitive Request for Proposals (RFP) procurement for standard HCBS PERS. Any willing provider that meets the technical equipment standards and business registration requirements may apply at any time.

• Certificate of Need (CON): Genuinely none exists; PERS is exempt from Maryland Health Care Commission CON requirements.
• Moratoria: No active moratoria block new PERS provider applications in Maryland.
• Network Access: Open enrollment; there is no closed network, RFP, or county sponsorship required to apply.
• Business Registration: Applicants must have an active, "Good Standing" status with Maryland SDAT before applying.
• SDAT Identification: LLCs and corporations must possess an SDAT identification number (typically starting with an "L" or "D").
• NPI Requirement: Must possess an active Type 2 (Organization) National Provider Identifier from NPPES.

4. Licensure and Certification Requirements

Maryland does not license or cover PERS under a distinct state licensing authority. If an agency only provides PERS, they are exempt from obtaining a Residential Service Agency (RSA) license from OHCQ.

Instead of a state license, providers are approved by demonstrating industry-standard certifications for their equipment and monitoring centers during the Medicaid enrollment process.

• State Licensure: None required; PERS providers operate without an OHCQ license.
• Equipment Certification: Providers must submit proof that all deployed base units and wearables are UL-listed.
• Monitoring Center Certification: The dispatch center must meet UL standards for central stations or hold equivalent industry certifications (e.g., TMA Five Diamond).
• General Liability Insurance: Must maintain active commercial general liability coverage.
• Professional Liability Insurance: Must maintain active professional liability (errors and omissions) coverage.
• Subcontracting: If the provider subcontracts the monitoring center, the subcontractor's UL certifications must be provided.

5. Medicaid Provider Enrollment

All Medicaid enrollment in Maryland is currently handled through the electronic Provider Revalidation and Enrollment Portal (ePREP). MDH will transition this system to the Maryland Provider Registration and Information Management Enterprise (MPRIME) in October 2026.

Providers must enroll specifically as an HCBS waiver provider for the programs they intend to serve, ensuring their taxonomy codes match their NPPES records exactly.

• Enrollment Portal: ePREP (transitioning to MPRIME in October 2026).
• Provider Agreement: Must sign the Maryland Medical Assistance Provider Agreement electronically within the portal.
• Tax Documentation: Must upload a signed IRS Form W-9 and an official IRS 147C letter confirming the EIN.
• Banking Details: Must provide a voided check or bank letter where the account name perfectly matches the SDAT and IRS records.
• Taxonomy Match: The provider type classification and specialty taxonomy in ePREP must match the NPPES record exactly.
• Application Fee: Subject to the federal Medicaid institutional provider application fee (approx. $732 in 2024) unless waived by Medicare enrollment.

6. Staffing, Training and Background Checks

While PERS does not involve hands-on personal care, provider staff still interact with vulnerable adults during in-home installations and emergency dispatch.

Providers must maintain internal policies ensuring that all field staff and monitoring center personnel are properly vetted and trained.

• Background Checks: Criminal history records checks are required for any installation staff entering a Medicaid participant's home.
• Dispatcher Training: Monitoring center staff must be trained in emergency response protocols, medical triage, and communicating with local EMS.
• Installer Qualifications: Field staff must be trained on device setup, signal testing, and educating the participant on how to use the system.
• Language Line Access: The monitoring center must have access to translation services to support non-English speaking participants.
• Exclusion Checks: Providers must check all staff against the OIG LEIE and Maryland Medicaid exclusion lists monthly.

7. Documentation, Policies and Records

MDH requires PERS providers to maintain strict documentation of service delivery to justify Medicaid billing. This includes proof of installation and logs of all emergency signals.

Records must be made available to OLTSS or MDH auditors upon request and retained according to state Medicaid regulations.

• Installation Records: Must keep signed documentation showing the date the device was installed and successfully tested.
• Participant Education: Must retain a signed acknowledgment that the participant or their representative understands how to operate the system.
• Testing Logs: Must maintain logs of monthly automated or manual test signals to prove the equipment is functioning.
• Incident Reports: Must document every emergency signal received, the triage steps taken, and the outcome (e.g., EMS dispatched, family notified).
• Record Retention: All service and billing records must be retained for a minimum of 6 years.
• HIPAA Compliance: Must maintain policies ensuring the secure transmission and storage of participant health information.

8. Billing, Rates and Claims

PERS providers bill Maryland Medicaid through the MMIS (via eMedicaid or a clearinghouse). Services cannot be billed until they are explicitly authorized in the participant's LTSSMaryland Person-Centered Plan.

Rates are fixed by the MDH OLTSS fee schedule and are typically divided into a one-time installation fee and a recurring monthly monitoring fee.

• Billing System: Claims are submitted via Maryland's MMIS / eMedicaid portal.
• Installation Code: Billed using HCPCS code S5160 (Emergency response system; installation and testing).
• Monitoring Code: Billed using HCPCS code S5161 (Emergency response system; service fee, per month).
• Prior Authorization: Services will deny if the provider is not linked to the participant's approved PCP in LTSSMaryland.
• Date of Service: Monthly monitoring (S5161) is typically billed after the month of service has been completed.
• Payment Cycle: Maryland Medicaid processes clean fee-for-service claims on a weekly cycle.

9. Approval Sequence and Timeline

Because there is no OHCQ licensure step, the timeline to become a PERS provider is dictated entirely by business setup and the ePREP enrollment queue.

Providers should expect the entire process to take 2 to 4 months from initial business registration to receiving the first Medicaid authorization.

• Step 1: Register the business entity with Maryland SDAT and obtain an IRS EIN (1-2 weeks).
• Step 2: Obtain a Type 2 NPI and request an IRS 147C letter (1-2 weeks).
• Step 3: Submit the provider enrollment application via ePREP with all required UL and insurance attachments.
• Step 4: MDH Provider Enrollment reviews the ePREP application (typically 30-60 days).
• Step 5: Receive Medicaid Provider Number and active status in the MMIS.
• Step 6: Receive service authorizations from Supports Planners via LTSSMaryland and begin installations.

10. Common Denials and Survey Findings

Most barriers for PERS providers occur during the ePREP application phase due to mismatched administrative data. Because the system is highly automated, slight discrepancies cause automatic returns.

Post-enrollment, the most common issue is claim denial due to billing before the Supports Planner has finalized the authorization in LTSSMaryland.

• Taxonomy Mismatch: ePREP applications are frequently returned because the NPI taxonomy does not match the requested Medicaid provider type.
• SDAT Issues: Application denied because the business is not in "Good Standing" with SDAT or the legal name doesn't match the IRS 147C letter.
• Missing UL Proof: Failure to upload clear documentation proving the specific equipment models are UL-listed.
• Authorization Denials: Billing S5161 before the Supports Planner has officially added the provider to the authorized PCP.
• Revalidation Failure: Missing the 5-year revalidation window in ePREP, resulting in automatic disenrollment and stopped payments.

11. Key Contacts and Resources

Providers must utilize several state portals and help desks to maintain their enrollment and receive authorizations.

Keeping contact information updated in ePREP is critical to receiving revalidation notices and policy transmittals from MDH.

• MDH Provider Enrollment: Manages ePREP (and future MPRIME) applications; reachable via the ePREP support desk.
• OLTSS Provider Relations: Handles waiver-specific policy questions for CFC, CPAS, and CO waivers.
• Maryland SDAT: The portal for business entity registration, annual reports, and Good Standing certificates.
• LTSSMaryland: The state's case management system used by Supports Planners to generate participant care plans and authorizations.
• NPPES: The federal registry for managing and updating the provider's National Provider Identifier (NPI) data.

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