MedicaidAdministrativeHigh impact
Residential Service Agencies Provider Compliance Audits
Maryland Medicaid·MD·Community First Choice
Effective date
Aug 10, 2026
We identified it
Aug 18, 2026
Summary
Maryland's Department of Health has issued updated compliance audit procedures for Residential Service Agencies (RSAs) providing Personal Assistance/Care Services under Community First Choice and related waiver programs. The policy establishes a formal progressive enforcement framework including desk reviews, site visits, Plans of Correction with 15-day response requirements, and escalating sanctions (suspension, payment withholding, termination) for non-compliance. Providers who fail to respond to audit initiation will be suspended after three outreach attempts.
Action Required
REQUIREMENTS:
- Immediately: All providers operating as Residential Service Agencies (RSAs) under Community Personal Assistance Services, Community First Choice, or Personal Assistance/Care Services programs must ensure management and compliance staff are informed of this transmittal.
- Immediately: Establish internal procedures to respond promptly to all Maryland Department of Health (MDH) audit initiation requests and inspection notices. Non-response to three MDH outreach attempts will result in automatic provider suspension.
- Establish internal process to ensure full cooperation with announced or unannounced MDH inspections during business hours and provide unrestricted access to office facilities and records upon request.
- Upon receipt of a Plan of Correction (POC): Billing/compliance team must respond within 15 calendar days with documented corrective actions. Failure to respond or continued non-compliance within 6 months will trigger escalating sanctions including payment withholding and program termination.
- Audit/Compliance Officer: Review organizational leadership against the 24-month lookback prohibition criteria (suspended/revoked licenses, prior Medicaid suspension, prior sanctions, disciplinary actions, health/safety citations, or termination for contractual/billing fraud violations).
- Contact mdh.cfcprovidersrsas@maryland.gov with any questions or to clarify audit expectations.