ABA and RBT guide for Maryland

Last researched October 21, 2026

Start with the topic you need

• Payers and coverage

  Autism insurance mandate, Medicaid ABA, major payers and how to enroll.

  9 verified facts

• Telehealth vs in-person

  BCBA licensure and telehealth or telesupervision rules.

  10 verified facts

• BT vs RBT

  What a behavior technician needs to work in this state.

  6 verified facts

• Practice requirements

  Internal processes a practice must follow.

  3 verified facts

The autism coverage law in Maryland

Md. Code, Insurance Article, 15-835 (habilitative services); COMAR 31.10.39 (implementing regulation) See coverage details and sources.

Getting a new technician started in Maryland

Maryland Medicaid lets a new BT enroll in ePREP and start before holding the RBT credential, but the clock is 90 days from application and is tied to the individual (it does not reset when changing employers). The CJIS background check and ePREP approval (managed by MDH, not the ASO) are the gating items, so confirm turnaround before promising start dates. (Our research note; confirm with the agencies on the BT vs RBT page.)

What we are still checking

• COMAR 10.09.28, 10.09.36 and 10.09.49 text was not read directly; only the manual's summary.
• Whether commercial plans in Maryland must cover ABA and any age limits/caps (Insurance Commissioner regulations under 15-835(e) not reviewed).
• Whether self-funded plans are excluded (not stated in sources read).
• Board of Professional Counselors and Therapists behavior analyst license fees, application steps and current rules; FAQ is old and undated.
• Medicaid managed care (HealthChoice MCO) role, if any, for ABA; manual says ABA is fee-for-service through the BHASO.
• Whether CPR/first aid or other training is required of BTs in Maryland Medicaid.
• Commercial telehealth parity law for ABA in Maryland.
• autism_insurance_mandate: verifier astra marked conflict - Replace 'does not reimburse' with 'does not require reimbursement' for services delivered through early-intervention or school programs. The definition, covered entity categories, age wording, November 1, 2013 date, and subsection (e) description match the statute. Its omission of an ABA name or dollar cap is accurately reported, but does not establish the full coverage rules. Add COMAR 31.10.39: it expressly includes ABA. Section .03D protects prescribed services against denial solely for their hours at up to 25 hours/week for ages 18 months to under 6, and 10 hours/week for ages 6 to under 19; these are not maximum treatment caps. Section .03F also protects medically indicated services in an educational setting while preserving the distinction from IEP obligations. Set excludes_self_funded_plans to true for this state mandate, without implying those plans cannot voluntarily cover ABA. No annual dollar cap appears in the reviewed statute or implementing chapter.
• medicaid_aba: verifier astra marked conflict - The February manual supports the stated Carelon/BHASO administration, rendering categories, supervision, billing restrictions, prior authorization, and 180-day cycles. However, its enrollment instructions are outdated as of October 21. Use MPRIME instead of ePREP. PT 39-27, dated October 6, describes a 150-day waiver/enrollment period and a new RBT enrollment application, conflicting with the manual's 90-day supplemental-application instructions. Preserve that discrepancy: COMAR 10.09.28.02J(2) still specifies registration within 90 days of enrollment, while the manual calculates from application. Cite .02J for BT requirements; .02I addresses RBTs. Specify that BCBA/BCBA-D providers must also hold the required Maryland license. Add the monthly 25% in-person requirement discussed in telehealth_aba. Under-21 status and ASD diagnosis are necessary but not exhaustive eligibility conditions under .03.
• telehealth_aba: verifier astra marked conflict - The original details accurately describe the February manual, including audiovisual delivery, eligible service categories, schedule markings, GT/POS 11, readiness checklist, and remote-direction approval. They are incomplete as current rules. PT 60-26 requires at least 25% in-person delivery for 97155, 97156/97156-U2, and 97157 effective April 1, 2026; COMAR .04B(6), (7), and (10), and Carelon's May FAQ specify monthly measurement. MDH reviews exceptions individually. Strengthen the 97153 statement: COMAR .04B(11) expressly requires in-person treatment, rather than merely omitting a telehealth marker. The home/community/clinic statement remains supported. telehealth_parity_law=null is an unverified field, not evidence that no parity law exists.
• bt_vs_rbt: verifier astra marked conflict - Conditional BT delivery remains supported, but 'only within 90 days after application' is not reliable current guidance. PT 39-27 describes a 150-day waiver/enrollment period for newly enrolling BTs and permits submission of RBT certification in a new enrollment application before or after that period expires; it does not authorize continued BT service after expiration. COMAR .02J still says 90 days from enrollment, so retain an explicit regulatory-versus-agency-guidance conflict. Replace the obsolete ePREP steps with MPRIME instructions. Applications submitted by December 31, 2026 and approved may receive an August 1 backdate or a requested later effective date; subsequent applications use submission date. The diploma upload remains required. The BT license-number entry, issue-date calculation, and other legacy fields match the old manual but should not be presented as current portal instructions. Add age 18+, appropriate supervision, and a written supervisory relationship from .02J. Billing and school-aide restrictions are supported within this Medicaid benefit. Correct 'Private Parity Petition' to 'Private Party Petition'; the manual contains the typo.
• practice_requirements: verifier astra marked conflict - Replace ePREP with MPRIME. Qualify the absolute enrollment-before-Carelon sequence because transition guidance permits courtesy registration/authorization before Medicaid enrollment, while withholding claims. Correct the petition name to Private Party Petition and distinguish employer authorization from each provider's background check. Exclusion screening covers employees and contractors, including administrative staff; the manual recommends every 30 days and requires screening documentation. The attestation, prior authorization, under-21 eligibility, and qualified ASD diagnosis statements are supported. Add PT 76-26: for service dates beginning July 1, 2026, claims require the individual referring practitioner's NPI in field 17b and active Medicaid enrollment on the service date; group/facility NPIs do not qualify. Treat facility_or_agency_license=null and staff_training_requirements=null as unverified, not as findings that no requirements exist.

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