Penguin Health
Maryland · Medical Assistance · Applied behavior analysis
Maryland reissued its ABA manual in October 2026
Maryland runs ABA as an EPSDT fee-for-service carve-out administered by Carelon Behavioral Health, under a provider manual reissued effective October 1, 2026. Its documentation section enumerates what every service note carries, down to behaviors described in measurable terms and a caregiver-participation block with a consented-absence alternative, and services not documented in accordance with COMAR 10.09.28.04 are non-reimbursable. The matching rule set lives in the rules library in the Penguin Health app.
Under COMAR 10.09.28, administered by Carelon.
From location and times to a signature with printed name and title.
Counts, durations, percentages, not impressions.
With daily unit maximums per CPT code.
The manual
What the October 2026 manual requires
The Documentation of Services section requires, for each service delivered, consent on file plus an enumerated note, and pairs it with a non-billable list and telehealth limits: telehealth is direction and parent training only (97155, 97156, 97157) with the GT modifier, and direction of technicians must equal at least 10% of their direct-service hours.
- The location, date, start time, and end time; a brief description of the service referencing the treatment plan; the participant's behaviors or symptoms in measurable terms; caregiver participation (name, relationship, date and time) or notification of the consent to be absent; and a legible signature with printed name and title.
- Completion of forms and reports, broken or missed appointments, travel, custodial care, and services by mail or telephone.
- Limited to 97155, 97156, and 97157 with the GT modifier and POS 11; direct treatment is in person.
- Direction of BCaBA, RBT, and BT staff equals at least 10% of their direct-service hours.
- A 12-section treatment plan template and reauthorization every 180 days, with daily unit maximums per code.
- Consent to treatment from the participant or guardian is on file.
The checklist
What a Maryland ABA note has to show
Each item below names its manual section and the Penguin rule that checks it. Maryland sets no note-completion deadline, so none is claimed.
| The note shows | What that means in practice | Source | Rule |
|---|---|---|---|
| Location, date, and start/end times matching the billing | When and where, agreeing with the claim. | Documentation of Services | MD-1 |
| A service description referencing the treatment plan | What was delivered, tied to the plan. | Documentation of Services | MD-2 |
| Behaviors in measurable terms | Counts, durations, or percentages, not impressions. | Documentation of Services | MD-3 |
| Caregiver participation, or a consented absence | Name, relationship, and when, or the documented consent to be absent. | Documentation of Services | MD-4 |
| A legible signature with printed name and title | The renderer, identifiable. | Documentation of Services | MD-5 |
| No non-billable time | Forms, travel, custodial care, and phone services stay outside the billed window. | non-covered list | MD-6 |
| No direct treatment via telehealth | Telehealth is direction and parent training only. | telehealth section | MD-7 |
In the rules library
Seven Maryland rules, ready to turn on
Open the rules library in the Penguin Health app, choose Maryland Medicaid ABA, and click Add to organization. Rules your organization already has are left alone, so adding the set twice only fills gaps. After adding, edit any rule or add your own alongside them.
Each rule runs only on notes billed to Maryland Medicaid payers. Penguin checks the CentralReach payer name, so a Maryland rule never fires on a commercial note in the same organization, and an organization whose payer names differ edits that match after adding the set.
Penguin reads signed session notes from CentralReach, read-only, after signature and before the claim, and runs the set on every note. Deterministic rules compare record fields. AI rules are read by the AI, which returns a pass or fail with a one-sentence reason.
Seven rules for the October 2026 Maryland ABA manual: the per-service elements, measurable-terms behaviors, caregiver participation, non-billable time, and the telehealth limit.
- reviewed
- Nov 5, 2026
- runs on
- Notes billed to Maryland Medicaid payers
- sources
- Maryland ABA Provider Manual, effective Oct 1, 2026; COMAR 10.09.28
- watching
- The manual PDF and the Maryland ABA program page
Every failure ships with QA guidance for that program code: an educational email, numbered action steps, and a QA email pre-filled with the date of service and a link to the note. Each reviewer action is written to a write-once audit log with seven-year retention. Billing Medicaid in more than one state? The rules library covers twenty-nine, including Virginia and Pennsylvania.
Maintained by Penguin
We watch the manual so the rules never go stale
Maryland reissued this manual in February 2026 and again in October 2026. The Maryland set is tied to the manual and its program page, not to a template written once.
The manual PDF and the program page where new editions appear. Penguin fetches the sources on a schedule and archives every revision.
We rewrite the affected rule, cite the document that changed it, and date the review. The set shows its sources and review date in the library.
An updated rule runs in the next scheduled validation and on demand against notes you have already reviewed, so a changed requirement shows you exactly which past notes it touches.
- A new manual edition takes effect
The enumerated note elements, non-billable list, telehealth limits, and 180-day reauthorization.
- The current manual takes effect
The October edition carries the note standard forward unchanged.
LibraryMD-1 through MD-7 are built against this edition.
- Maryland set reviewed
Checked against the October 2026 manual. Current.
- WatchingThe next edition
When the manual is reissued, the set is updated and every organization using it gets the change.
State alerts
Get an email when Maryland changes its documentation rules
We fingerprint 56 official payer documents every week, Maryland's among them. When one changes, a person verifies what changed and writes a short plain-language summary before anything is sent. A few emails a year, not a newsletter. Unsubscribe anytime.
Check your inbox: confirm your email and you are on the list.
You will get a confirmation email first. Watching more than one state? Pick your states here.
Next step
Run a month of Maryland notes through Penguin
Bring one month of session notes. We add the Maryland set from the rules library, run it, show every finding beside the source it maps to, and hand your QA lead the fix for each one. Or get a demo account and click through Penguin on your own time first.