Maryland's Waiver Consolidation: What DDA Providers Need to Know About the Billing Transition

On October 6, 2025, Maryland's Developmental Disabilities Administration collapsed three separate Medicaid waiver programs — the Community Pathways Waiver, the Community Supports Waiver, and the Family Supports Waiver — into a single consolidated program: the Community Pathways Waiver. For participants, the transition was designed to be seamless. For providers, it wasn't.

What the Consolidation Actually Changed

The intent of the consolidation was straightforward: merge three programs with overlapping populations into one, give all participants access to the full service array, and streamline the administrative structure. CMS approved the amendment, and DDA executed it on the October 6 effective date.

What that meant operationally was that every participant previously enrolled in the Family Supports or Community Supports Waiver was automatically transitioned to the Community Pathways Waiver. Their Person-Centered Plans were converted in LTSSMaryland. Provider authorizations under the old waivers were carried forward — agencies authorized to provide services under the Family Supports or Community Supports Waiver were automatically authorized under the new Community Pathways structure.

On paper, continuity. In practice, providers needed to verify every active participant's updated plan, confirm that converted service authorizations were accurate, and ensure their billing was going out under the correct waiver and service codes as of October 6 — not the legacy ones.

The LTSSMaryland Billing Layer

Maryland's DDA billing runs entirely through LTSSMaryland — the state's Provider Portal, which is also the mandated EVV system for Personal Support Services and Respite Care. Unlike most states that use Sandata or HHAeXchange as an external aggregator, Maryland built its own system and requires exclusive use of it. No alternate EVV vendors are permitted.

The consolidation required LTSSMaryland system updates to convert service plans, transmit enrollment data from MDThink, and reflect the new Community Pathways service definitions. Providers billing through LTSSMaryland in October and November 2025 were doing so while the system itself was mid-transition — and any service code, authorization reference, or plan conversion that didn't carry over cleanly created a billing mismatch.

The HealthChoice Complication

Layered on top of the DDA transition, Maryland's HealthChoice managed care program experienced its own disruption in 2025. Priority Partners — one of the state's major HealthChoice MCOs — was placed under an enrollment sanction in March 2025 following loss of NCQA accreditation. New members were unable to select Priority Partners for nearly a year until the sanction was lifted in February 2026.

For providers with a significant portion of members on Priority Partners, this created uncertainty around plan assignments, continuity of authorizations, and claim routing during the sanction period. Providers who weren't actively monitoring member MCO status could find claims routing to the wrong plan or denied for authorization issues tied to the enrollment disruption.

What Providers Should Be Auditing Now

Any agency serving DDA waiver participants should verify that every active member's LTSSMaryland plan reflects the Community Pathways Waiver — not a legacy Family Supports or Community Supports reference. Service authorizations should be confirmed as valid under the new program structure, and claim submissions since October 6 should be reviewed for any denials tied to waiver code mismatches.

For HealthChoice providers, member MCO assignments should be audited against current enrollment data, particularly for any members who may have been affected by the Priority Partners sanction and reassigned to another plan.

Maryland's consolidation was the right long-term move for the program. But it landed as a simultaneous billing system update, waiver program transition, and MCO disruption — all in the same quarter. The providers who come through it cleanly are the ones who didn't assume the automatic transitions were error-free.