MedicaidCoverageHigh impact
Policy Clarification - Four Walls Requirement Termination
Maryland Medicaid·MD · Psychiatry, General Practice, Family Medicine +2 more·General Provider
Effective date
May 11, 2023
We identified it
Jun 20, 2026
Summary
Maryland Medicaid has terminated the COVID-19 PHE waiver that allowed freestanding clinics (including OMHCs and SBHCs) to bill telehealth services at standard rates when both practitioner and patient were in their homes. Effective immediately, clinics may no longer bill for services where both parties are in their homes. An §1115 waiver amendment to continue this authority is pending approval; practices should monitor for updated guidance.
Action Required
Immediately: Billing team must stop billing Maryland Medicaid claims for telehealth services where both the practitioner and patient are in their homes. All freestanding clinics (OMHCs, SBHCs, and other outpatient clinics) must ensure encounter forms and billing software do not submit such claims under the terminated §1135 waiver authority. Update provider documentation to reflect that telehealth must originate from clinic premises to qualify for reimbursement under current policy. Establish a process to verify practitioner location (clinic-based) before submitting claims. Monitor mdh.providerenrollment@maryland.gov for notification if the pending §1115 waiver amendment is approved, which may restore billing authority. Failure to comply will result in claim denials and potential overpayment recovery.