MedicaidReimbursementMedium impact
Payment Rate Transparency and Comparative Rate Analysis Reporting Requirements
Maryland Medicaid·MD · Occupational Therapy, Physical Therapy, Speech Therapy·Community First Choice
Effective date
Jul 1, 2026
We identified it
Aug 6, 2026
Summary
Maryland Medicaid is implementing new Payment Rate Transparency and Comparative Rate Analysis Reporting Requirements effective July 1, 2026, mandating publication of all FFS fee schedule payment rates on a publicly accessible website and requiring comparative rate analysis reporting for personal care, home health aide, homemaker, and habilitation services. This policy implements CMS-2442-F requirements and affects all HCBS providers across multiple Maryland waiver programs.
Action Required
By July 1, 2026: All Maryland HCBS providers participating in Community First Choice, Community Personal Assistance Services, Autism Waiver, Brain Injury Waiver, and other listed waiver programs must verify that their billing systems and fee schedules align with the published Maryland Medicaid FFS payment rates. Billing teams should review the comparative rate analysis table (provided in PT 97-26 transmittal) to confirm accurate rate coding for all personal care services (W5519-W5528), habilitation services (Z9300-W1987), and employment services. Organizations must monitor the provider transmittals website regularly for rate updates and ensure staff are informed of rate changes. No immediate action required for current billing, but audit billing system rates against published rates before July 1, 2026. Contact Da-Young Kang at (443) 683-0196 or da-young.kang1@maryland.gov for questions. Note: Comparative rate analysis will be updated every two years.