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

Last reviewed: 2026-09-10

The Maryland Department of Health (MDH) Office of Long Term Services and Supports (OLTSS) funds one-time institutional transition costs under the Community Options Waiver and the Money Follows the Person (MFP) demonstration. Maryland does not issue a distinct facility or agency license for Transitional Assistance Services; instead, the state restricts the provision and billing of these setup expenses to designated Supports Planning Agencies (SPAs) and Developmental Disabilities Administration (DDA) Coordinators of Community Services (CCS).

Approval to coordinate and bill for these transition expenses requires an agency to first win a competitive procurement contract from MDH to operate as an SPA or be approved as a CCS agency by the DDA. Standalone businesses cannot simply enroll in Maryland Medicaid to offer moving or furniture setup services directly to waiver participants without operating under one of these comprehensive case management umbrellas.

1. Service Definition and Scope

In Maryland, Transitional Assistance Services are defined as one-time, non-recurring setup expenses necessary to facilitate a Medicaid participant's transition from a nursing facility or other institution to a community living arrangement. These services are authorized under COMAR 10.09.54 for the Community Options Waiver and parallel regulations for DDA waivers.

The service covers essential physical items and deposits required to establish a basic household, but it strictly prohibits using funds for ongoing rent, recreational items, or food.

• Service Name: Transition Services (under Community Options Waiver) or Transition Action Plan funding (under MFP)
• Covered Expenses: Security deposits, utility setup fees, essential furnishings (bed, table, chairs), and basic window coverings
• Moving Costs: Includes professional moving services and pest eradication if required prior to move-in
• Excluded Items: Monthly rental or mortgage payments, ongoing utility charges, televisions, cable setup, and groceries
• Funding Cap: Typically capped at a lifetime maximum per participant (historically $3,000 to $5,000 depending on the specific waiver and MFP authorization)
• Delivery Model: Procured and coordinated by the participant's Supports Planner or CCS, who submits receipts for reimbursement

2. Regulatory and Oversight Agencies

Oversight of transition services is split based on the target population and the specific Medicaid waiver funding the participant's community integration.

The primary agencies manage the waiver budgets, issue the competitive procurements for case management agencies, and audit the receipts submitted for transition expenses.

• Maryland Department of Health (MDH): The single state Medicaid agency overseeing all waiver programs (https://health.maryland.gov)
• MDH Office of Long Term Services and Supports (OLTSS): Administers the Community Options Waiver and MFP program (https://health.maryland.gov/mmcp/ltss/Pages/home.aspx)
• Developmental Disabilities Administration (DDA): Administers the Community Pathways Waiver and oversees CCS agencies (https://dda.health.maryland.gov)
• Maryland Medicaid ePREP: The electronic Provider Revalidation and Enrollment Portal used for all Medicaid provider enrollment (https://eprep.health.maryland.gov)
• LTSSMaryland: The state's mandatory electronic system for person-centered care planning and service authorization (https://ltssmaryland.health.maryland.gov)

3. Gatekeeping Prerequisites: Who Can Even Apply

Maryland strictly gates access to billing for transition services. There is no open enrollment for independent moving companies, furniture vendors, or standalone transition coordinators to bill Medicaid directly.

To provide this service, an entity must first become a comprehensive case management agency under a state-issued contract or designation.

• Procurement Gate: Applicants must respond to and win a competitive Request for Proposals (RFP) issued by MDH to become a Supports Planning Agency (SPA)
• DDA Designation Gate: For DDA waivers, applicants must be approved as a Coordinator of Community Services (CCS) agency during an open application cycle
• Corporate Status: Must be a legally established entity registered and in good standing with the Maryland State Department of Assessments and Taxation (SDAT)
• No Standalone Enrollment: Entities cannot enroll in ePREP solely under a "Transitional Assistance" provider type; they must enroll as an SPA or CCS
• Financial Solvency: RFP respondents must demonstrate financial capacity to purchase transition items upfront and await Medicaid reimbursement

4. Licensure and Certification Requirements

Because Maryland does not recognize Transitional Assistance Services as a distinct facility or healthcare provider type, there is no specific license issued by the Office of Health Care Quality (OHCQ) for this service.

Instead, the agency must maintain its certification and contractual standing as an SPA or CCS, which requires adherence to COMAR regulations governing case management and waiver administration.

• OHCQ Licensure: Not applicable; no OHCQ license exists for transition services or moving companies
• SPA Certification: Must maintain active contract status with MDH OLTSS, including passing annual readiness and compliance reviews
• CCS Certification: Must maintain approval from DDA and adhere to COMAR 10.22.09 (Coordinators of Community Services)
• Business License: Must hold standard local and state business licenses applicable to operating an office in Maryland
• Insurance Requirements: Must maintain general liability, professional liability, and workers' compensation insurance as dictated by the state contract

5. Medicaid Provider Enrollment

Once an agency has secured the prerequisite SPA contract or CCS designation, it must enroll in the Maryland Medicaid program through the electronic Provider Revalidation and Enrollment Portal (ePREP).

The enrollment process links the agency's National Provider Identifier (NPI) to the specific waiver programs and authorizes access to the LTSSMaryland system.

• System: Maryland Medicaid ePREP (https://eprep.health.maryland.gov)
• Provider Type: Must enroll under the provider type designated for Supports Planning Agencies or Coordinators of Community Services
• Required Documentation: W-9, SDAT certificate of good standing, and the executed MDH contract or DDA approval letter
• Application Fee: Subject to the ACA institutional provider application fee unless waived by Medicare enrollment or state exception
• Revalidation: Providers must revalidate their Medicaid enrollment through ePREP every five years

6. Staffing, Training and Background Checks

The personnel coordinating transition services are the Supports Planners or CCS staff employed by the enrolled agency. Maryland sets strict educational and background requirements for these professionals.

Staff do not physically move furniture; they coordinate with commercial vendors, secure leases, and purchase items on behalf of the participant.

• Educational Minimum: Supports Planners typically must hold a Bachelor's degree in a human services field or possess equivalent approved experience
• Background Checks: All staff interacting with participants must pass a Maryland state and FBI criminal history background check
• OIG Exclusion: Agencies must screen all employees and vendors against the federal LEIE and Maryland Medicaid exclusion lists monthly
• Mandatory Training: Staff must complete MDH or DDA mandated training on person-centered planning, LTSSMaryland navigation, and MFP protocols
• Vendor Vetting: The SPA/CCS is responsible for ensuring that third-party vendors (e.g., moving companies) are legitimate businesses and not excluded entities

7. Documentation, Policies and Records

Because transition services involve reimbursing agencies for physical goods and deposits, the documentation requirements are heavily focused on financial receipts and care plan integration.

Auditors frequently review these files to ensure funds were spent exclusively on allowable items and that the participant successfully transitioned.

• Person-Centered Service Plan (PCSP): The need for transition services must be explicitly documented and authorized in the participant's PCSP within LTSSMaryland
• Transition Action Plan: For MFP participants, a detailed budget and transition plan must be approved by the state prior to any expenditures
• Original Receipts: The agency must retain original, itemized receipts for every purchase, deposit, and vendor payment
• Lease Agreements: Copies of the executed residential lease must be kept on file to justify security deposit payments
• Record Retention: All financial and programmatic records must be retained for a minimum of six years from the date of service

8. Billing, Rates and Claims

Transition services are billed as a reimbursement for actual costs incurred by the SPA or CCS, up to the authorized cap, rather than as a fee-for-service hourly rate.

Agencies must float the initial costs of the transition items and submit claims with attached receipts to recoup the funds from Medicaid.

• Billing System: Claims are processed through the state's MMIS and authorized via LTSSMaryland
• Reimbursement Model: Exact cost reimbursement based on submitted and approved receipts, not to exceed the waiver's lifetime cap
• Prior Authorization: All transition expenses must be prior-authorized in LTSSMaryland before the agency makes the purchase
• Administrative Fee: SPAs may receive a separate administrative or case management fee for the time spent coordinating the move, billed under distinct case management codes
• Payer of Last Resort: Medicaid will only reimburse items if no other community resource (e.g., housing vouchers, local charities) can cover the cost

9. Approval Sequence and Timeline

Becoming an agency authorized to provide transition services is a lengthy process dictated by the state's procurement cycle.

Agencies cannot apply at will; they must wait for MDH to issue an RFP for Supports Planning Agencies.

• Step 1: Monitor eMMA (eMaryland Marketplace Advantage) for SPA RFPs or DDA announcements for CCS open enrollment
• Step 2: Submit a comprehensive proposal or application demonstrating capacity to manage waiver populations and float transition costs
• Step 3: Receive contract award from MDH or approval designation from DDA (timeline varies, often 6-12 months for procurements)
• Step 4: Submit provider enrollment application through ePREP (typically processed in 30-60 days)
• Step 5: Complete mandatory state training and gain access to LTSSMaryland before accepting participant referrals

10. Common Denials and Survey Findings

When MDH audits transition service claims, findings almost exclusively relate to financial documentation errors or purchasing unallowable items.

Agencies that fail to maintain strict financial controls risk having to absorb the costs of the transition items themselves.

• Unallowable Purchases: Denials for buying excluded items such as televisions, decorative items, or groceries
• Missing Receipts: Recoupment of funds due to the agency failing to provide itemized receipts matching the claimed amount
• Lack of Prior Authorization: Purchasing items before the transition plan and budget were officially approved in LTSSMaryland
• Failed Transitions: Complications arising if items are purchased but the participant ultimately does not discharge from the nursing facility
• Exceeding Caps: Submitting claims that push the participant's total transition expenditures over the waiver's lifetime limit

11. Key Contacts and Resources

Prospective agencies must interact with the state's procurement portal and the specific Medicaid divisions managing the waivers.

These resources provide the regulatory framework, current RFPs, and enrollment portals necessary to operate in Maryland.

• MDH Office of Long Term Services and Supports: Manages the Community Options Waiver (https://health.maryland.gov/mmcp/ltss/Pages/home.aspx)
• Developmental Disabilities Administration (DDA): Manages the Community Pathways Waiver (https://dda.health.maryland.gov)
• eMaryland Marketplace Advantage (eMMA): The state procurement portal where SPA RFPs are published (https://emma.maryland.gov)
• Maryland Medicaid ePREP: Provider enrollment portal (https://eprep.health.maryland.gov)
• COMAR Online: Division of State Documents for accessing Title 10, Subtitle 09 regulations (http://www.dsd.state.md.us)

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