Behavioral Health Practice Guide: Maryland EHR, Billing, and Compliance (2026)

BHA Licensing and Accreditation

Maryland behavioral health programs are licensed by the Behavioral Health Administration (BHA) within the Maryland Department of Health. The regulatory framework is codified in COMAR 10.63 (Community-Based Behavioral Health Programs and Services). A unique feature of Maryland's system is that programs must be both licensed and accredited to operate — accreditation from bodies such as CARF, The Joint Commission, or COA is a prerequisite for licensure.

Program types requiring BHA licensure include:

• Mental health facilities: Residential Treatment Centers, Partial Hospitalization Programs (PHP), and Intensive Outpatient Programs (IOP)
• SUD treatment facilities: Detoxification, Residential Treatment, PHP, and IOP
• Crisis services: Behavioral Health Crisis Stabilization Centers (BHCSC)
• Outpatient behavioral health programs: including Outpatient Mental Health Centers (OMHC) and substance use disorder outpatient programs

In February 2025, BHA implemented a new online application system replacing the previous paper-based licensing process, making it easier for providers to apply for and maintain licenses. However, BHA withdrew proposed COMAR 10.63 regulation revisions in August 2025 that had been published in the Maryland Register in May 2025, indicating that significant regulatory updates are still in development.

HealthChoice Medicaid and the ASO

Maryland's Medicaid program operates through HealthChoice, the state's managed care delivery system. However, Maryland uses a distinctive integrated behavioral health carve-out model that separates behavioral health from physical health administration.

The Carve-Out Structure

From the inception of HealthChoice in 1997, mental health services were carved out of the MCO benefit package. SUD services were initially managed by the MCOs, but in January 2015, Maryland combined mental health and SUD services into an integrated carve-out administered by an Administrative Services Organization (ASO). Under this model, the ASO administers and reimburses all specialty mental health and SUD services for Medicaid participants on a fee-for-service basis, under the oversight of the Medicaid program and BHA.

The 2025 ASO Transition

On January 1, 2025, the ASO contract transitioned from Optum to Carelon Behavioral Health. All review guidelines and time spans remained the same during the transition. Providers should access current authorization and billing documentation through the Carelon Behavioral Health provider portal.

HealthChoice MCOs

Nine MCOs participate in HealthChoice for physical health services:

• Aetna Better Health
• CareFirst BlueCross BlueShield Community Health Plan Maryland
• Jai Medical Systems
• Kaiser Permanente
• Maryland Physicians Care
• MedStar Family Choice
• Priority Partners (enrollment reinstated February 2, 2026, after regaining NCQA accreditation)
• UnitedHealthcare
• Wellpoint Maryland

For behavioral health providers, the key operational distinction is that specialty behavioral health claims go through the ASO (Carelon), not the patient's HealthChoice MCO. Your EHR must be configured to route behavioral health claims to the ASO while coordinating care information with the patient's physical health MCO.

Billing and Authorization Requirements

Behavioral health billing in Maryland flows through the Carelon ASO for Medicaid specialty services. Understanding the ASO's authorization and claims requirements is essential for maintaining revenue cycle performance.

Timely Filing

Claims must be submitted within Maryland Medicaid's 12-month timely filing window. Authorizations have limited backdating — providers should submit authorization requests promptly to avoid denials. The Carelon provider manual and billing appendix detail specific procedure code requirements and billing guidelines.

Authorization Requirements

Many specialty behavioral health services require prior authorization through the ASO. Authorization review guidelines and time spans that were in place under Optum were maintained during the Carelon transition. Residential treatment, partial hospitalization, and intensive outpatient services typically require concurrent review and ongoing authorization.

For coding and billing guidance, see our mental health billing codes guide. Practices should ensure their EHR integrates with the Carelon portal for electronic authorization submission and status tracking.

SUD Licensing and Programs

Substance use disorder programs in Maryland are licensed by BHA under the same COMAR 10.63 framework as mental health programs. SUD-specific program types include detoxification, residential treatment, PHP, IOP, and outpatient programs. All programs must meet both licensing and accreditation requirements.

Maryland's 1115 Demonstration Waiver and related federal waivers have expanded SUD treatment coverage in recent years, and the state has invested in expanding the SUD treatment continuum. SUD providers must comply with federal 42 CFR Part 2 requirements for substance use disorder record confidentiality, including the 2024 final rule changes effective February 16, 2026.

Individual SUD counselors in Maryland are licensed through the Board of Professional Counselors and Therapists, with credential types including Certified Supervised Counselor-Alcohol and Drug (CSC-AD), Certified Associate Counselor-Alcohol and Drug (CAC-AD), and Licensed Clinical Alcohol and Drug Counselor (LCADC).

Telehealth Rules

Maryland significantly strengthened its telehealth framework through the Preserve Telehealth Access Act of 2025 (HB 869/SB 372), which made several previously temporary provisions permanent:

• Audio-only coverage: Audio-only telephone conversations between a provider and patient that result in the delivery of a billable, covered health care service are permanently covered as telehealth.
• Payment parity: Both Maryland Medicaid and private insurers must reimburse telehealth visits at the same rate as in-person care — this payment parity requirement is now permanent.
• Behavioral health protection: Insurers may not exclude from coverage or deny a behavioral health service that is a covered benefit solely because it can be provided through telehealth.
• Four modalities: Maryland Medicaid reimburses for live video, store-and-forward, remote patient monitoring, and audio-only telehealth.

These permanent telehealth provisions make Maryland one of the most telehealth-friendly states for behavioral health providers. EHR systems must support telehealth-specific documentation, place-of-service coding, and modality tracking to ensure clean claims for telehealth services.

Reimbursement Landscape

Maryland's behavioral health reimbursement operates primarily through the ASO fee-for-service model for Medicaid specialty services, with fee schedules published by BHA and the Medicaid program. The state also participates in the AHEAD (All-Payer Health Equity Approaches and Development) model, Maryland's successor to the Total Cost of Care (TCOC) model, which includes behavioral health integration priorities.

The Medicaid Advanced Primary Care Program (Medicaid Path), launching as part of AHEAD, emphasizes behavioral health integration into primary care through evidence-based models like Screening, Brief Intervention, and Referral to Treatment (SBIRT). This creates opportunities for behavioral health providers partnering with primary care practices.

Major commercial payers in Maryland include CareFirst BlueCross BlueShield (the dominant regional plan), Aetna, Cigna, UnitedHealthcare, and Kaiser Permanente. For revenue cycle strategies, see our behavioral health revenue cycle guide.

EHR, CRISP, and PDMP Requirements

Maryland's health information technology infrastructure is anchored by CRISP (Chesapeake Regional Information System for our Patients), the state-designated health information exchange.

PDMP Integration

All controlled dangerous substance (CDS) prescribers in Maryland must be registered with the PDMP, which is accessible through CRISP. Providers must document in their EHR that the PDMP was checked per mandate requirements. EMR vendors with successfully integrated PDMP access include Epic, Cerner, Meditech, NextGen, and Allscripts. Effective September 1, 2025, dispensers must also begin reporting non-CDS prescription data to CRISP under COMAR 10.25.18.13.

Health Data Utility

Maryland law enacted in 2021 and 2022 requires CRISP to develop a consumer consent management application, operate a health data utility, and collect non-controlled prescription drug information. This expanding data infrastructure means behavioral health providers should plan for increasing HIE connectivity requirements in their EHR selection.

42 CFR Part 2 Compliance

Maryland SUD providers must comply with federal 42 CFR Part 2 requirements. The state's expanding HIE infrastructure through CRISP creates particular tension with Part 2's consent and re-disclosure requirements — EHR systems must support granular consent management to control what SUD data flows to CRISP and downstream recipients.

Workforce and Interstate Compacts

Maryland participates in multiple interstate licensure compacts that support behavioral health workforce expansion:

• PSYPACT: Maryland is among the 43 states participating in the Psychology Interjurisdictional Compact. Licensed psychologists can provide telepsychology across compact member states and temporary in-person services for up to 30 days per year per state.
• Counseling Compact: Maryland has enacted the Counseling Compact, which launched operationally on September 30, 2025. Licensed professional counselors in compact states can obtain a privilege to practice in Maryland and other member states through an expedited process.

Maryland's proximity to Washington, D.C. and Virginia makes interstate compact participation particularly valuable for practices serving patients across state lines. EHR systems must track compact membership status, privilege-to-practice credentials, and state-specific scope-of-practice rules for each clinician.

Parity Enforcement and Regulatory Environment

Maryland is actively working to strengthen mental health parity enforcement. Senate Bill 205, introduced January 14, 2026, seeks to codify provisions of the federal Code of Federal Regulations related to mental health parity into state law and clarify the authority of the Maryland Insurance Administration (MIA) to enforce parity requirements. This legislation is designed to align Maryland's parity law with the 2024 federal Mental Health Parity and Addiction Equity Act (MHPAEA) final rule.

The Maryland Parity Coalition, convened by the Legal Action Center, works to ensure non-discriminatory access to mental health and SUD services through enforcement of MHPAEA, robust network adequacy standards, and consumer protections against high out-of-pocket costs when insurance networks are inadequate.

However, advocacy groups have noted that Maryland regulators have not thoroughly reviewed plans' written policies and actual practices to ensure parity compliance. Behavioral health practices can strengthen their position by tracking denial rates, authorization requirements, and reimbursement disparities by payer and service type in their EHR, generating data that supports parity complaints.

Top EHR Picks for Maryland Behavioral Health Practices

Maryland's unique ASO carve-out model, CRISP HIE requirements, dual licensing/accreditation framework, and the 2025 Carelon transition require an EHR purpose-built for behavioral health complexity. Based on these requirements:

• Ease: strongest fit for Maryland practices needing AI-native productivity, ASO billing automation, CRISP/PDMP integration readiness, and end-to-end operational automation for growth-stage and larger organizations navigating the Carelon transition.
• AZZLY Rize: practical choice for organizations prioritizing all-in-one BH/SUD workflow depth with integrated treatment planning, concurrent review management through the ASO, and faster onboarding — well suited for programs meeting COMAR 10.63 requirements.
• PIMSY: solid option for mid-size practices wanting balanced behavioral health workflow support with configurable ASO authorization tracking and moderate implementation complexity.

Compare these and other options in our behavioral health EHR comparison and best EHR for mental health evaluations.

Frequently Asked Questions

How does Maryland license behavioral health programs?

The Behavioral Health Administration (BHA) licenses community-based behavioral health programs under COMAR 10.63. Programs must be both licensed and accredited by a recognized body (CARF, Joint Commission, or COA). BHA launched a new online application system in February 2025, replacing the paper-based process. Program types include residential treatment, PHP, IOP, detox, crisis stabilization, and outpatient behavioral health services.

How does Maryland Medicaid handle behavioral health billing?

Maryland uses an integrated behavioral health carve-out. Since January 2015, specialty mental health and SUD services have been administered through an ASO on a fee-for-service basis. The ASO transitioned from Optum to Carelon Behavioral Health on January 1, 2025. The nine HealthChoice MCOs handle physical health while the ASO manages all specialty behavioral health claims. Timely filing requires claims within 12 months.

What are Maryland's telehealth rules for behavioral health?

The Preserve Telehealth Access Act of 2025 (HB 869) permanently established audio-only coverage, payment parity for telehealth at the same rate as in-person care, and protections against denying behavioral health services solely because they can be delivered via telehealth. Maryland Medicaid reimburses for all four modalities: live video, store-and-forward, remote patient monitoring, and audio-only.

What is CRISP and how does it affect behavioral health EHR requirements?

CRISP is Maryland's designated statewide HIE. All CDS prescribers must be PDMP-registered, with access available through CRISP. Dispensers must report non-CDS prescriptions to CRISP by September 2025. Maryland law requires CRISP to operate a health data utility and develop a consumer consent management application, increasing HIE connectivity expectations for all providers.

Is Maryland a member of PSYPACT and the Counseling Compact?

Yes. Maryland participates in both PSYPACT (43 member states) and the Counseling Compact (launched September 30, 2025). These compacts allow licensed psychologists and counselors to practice across state lines, which is particularly valuable given Maryland's proximity to D.C. and Virginia.