How to start an IOP in Maryland: accreditation, the COMAR 10.63 license and the ASO

Who wrote this, honestly

We're Texas operators: we run a licensed Texas outpatient program, PHP through outpatient, and built our own EHR to run it. When we help an owner open in another state, the first task on that client's roadmap is "apply for your state's SUD treatment program license". The work behind it is finding the state's rule and checking it against the agency's current text. This guide is that check for Maryland, and it's the same work our Program Launch + Accreditation does for a client opening outside Texas. Where we couldn't confirm a detail, we left it out or told you who to ask.

Comparing neighbors? Read our guides for Virginia and Pennsylvania, or how to start an IOP or PHP in Texas.

Maryland at a glance

Question	Maryland's answer
Who licenses an outpatient SUD program	Maryland Department of Health, Behavioral Health Administration (BHA) licensing unit
Regulation	COMAR 10.63, community-based behavioral health programs and services
Accreditation	Required: Level 2.1 needs an accreditation-based license (COMAR 10.63.02.02)
Local sign-off	An Agreement to Cooperate with the core service agency, local addictions authority or local behavioral health authority in each jurisdiction
How you apply	BHA's online licensure application, launched February 1, 2025
Pending change	Proposed action 26-079-P (July 2026) would repeal and re-adopt 10.63.01, repeal 10.63.02, and give Level 2.1 SUD treatment its own chapter
Counselor credentials	Board of Professional Counselors and Therapists: LCADC, LGADC, CAC-AD, CSC-AD and ADT
Medicaid	Public Behavioral Health System; Carelon Behavioral Health is the ASO from January 1, 2025 (base contract through 2029)

Accreditation comes first

Maryland moved most community behavioral health programs from state-surveyed licenses to accreditation-based licenses when COMAR 10.63 replaced the older COMAR 10.21 and 10.47. BHA's accreditation and regulations FAQ says most providers previously regulated under those chapters must be accredited by an approved national accrediting organization. For an IOP the rule is explicit: COMAR 10.63.02.02 lists Intensive Outpatient Treatment Level 2.1 among the programs that need an accreditation-based license.

• Which accreditors. The application requires proof of accreditation from a Maryland-approved accreditation organization. BHA's materials have referenced CARF and The Joint Commission, and an early Carelon provider alert also covered ACHC. Ask BHA for its current list before you sign with an accreditor; our Joint Commission vs. CARF guide helps you choose between the two most common ones.
• The sequence problem. An accreditor usually wants to see an operating program, and Maryland wants accreditation before it licenses you. Ask your accreditor exactly what it needs for an initial survey (policies, staff files, a minimum of records or clients served), and ask BHA how a brand-new program should sequence the two. Get both answers in writing.
• Budget it into the launch. Accreditation fees and survey preparation aren't optional extras in Maryland. Our guides to accreditation for new programs and accreditation cost and timeline cover what it takes, and a mock survey before the real one is cheap insurance.

The rules to read

Regulation or document	What it covers
COMAR 10.63.01	General requirements for community-based behavioral health programs
COMAR 10.63.02.02	The programs required to be accredited to be licensed, including Level 2.1
COMAR 10.63.03.03	Level 2.1 criteria: meet 10.63.01, .02 and .06, and ASAM's Level 2.1 criteria
COMAR 10.63.06	The application and licensure process
BHA online application guide	How to submit initial, renewal and change applications in BHA's online system

Because the license rests on accreditation, Maryland's surveyor is mostly your accreditor. Our Program Launch + Accreditation builds the policy manual once, crosswalked to the accreditor's standards, COMAR 10.63 and ASAM's Level 2.1 criteria. For how Level 2.1 differs from 2.5 and Level 1, see IOP vs. PHP vs. outpatient.

The Agreement to Cooperate

This is the Maryland step owners from other states miss. BHA's Agreement to Cooperate form (revised July 31, 2025) says applicants must enter into an agreement with the core service agency (CSA), local addictions authority (LAA) or local behavioral health authority (LBHA) in each county, or Baltimore City, where the program operates or wants to operate, before a COMAR 10.63 license is issued. It's required with an initial application, a renewal, an added service or any change to the license.

• One per jurisdiction. Opening sites in Baltimore City and Baltimore County means two agreements.
• Start early. Contact the local authority while you're still choosing a site; they can tell you about local needs and expectations before you're committed.
• Keep it current. Every license change brings the form back, so track it like a license document.

BHA's 2017 provider presentation lists the sequence as four steps: accreditation, the Agreement to Cooperate from each jurisdiction, the COMAR 10.63 application to BHA's licensing unit, then the license. Licenses are issued for a set date range and must be renewed. Since February 1, 2025, applications go through BHA's online system.

The 2026 rewrite

On July 13, 2026, BHA published proposed action 26-079-P, a reorganization of COMAR 10.63. Among other changes, it would repeal and re-adopt 10.63.01, repeal 10.63.02, and create separate chapters including 10.63.13, Intensive Outpatient Treatment Level 2.1 for substance-related disorders, and 10.63.37, a mental health intensive outpatient program. We couldn't confirm whether it has been adopted. If you're applying in 2026 or 2027, ask BHA which numbering and requirements will apply on your application date, and write your policy manual so it can be re-mapped to the new section numbers without rewriting the policies.

Counselors and staffing

Maryland's Board of Professional Counselors and Therapists credentials alcohol and drug counselors under regulations that took effect December 31, 2018:

Credential	What to know
Licensed clinical alcohol and drug counselor (LCADC)	The independent license. The board's application requires two years and 2,000 hours of supervised experience after a master's degree of at least 60 semester credits, the MAC exam and the Maryland law assessment
Licensed graduate alcohol and drug counselor (LGADC)	The graduate license, held while working toward the LCADC under supervision
Certified associate counselor, alcohol and drug (CAC-AD)	A certification that requires a bachelor's degree or higher in a health and human services counseling field or a related field the board approves
Certified supervised counselor, alcohol and drug (CSC-AD)	A certified level that practices under supervision
Alcohol and drug trainee (ADT)	The entry status for people accruing education and supervised hours

Scope and supervision differ by level, so check each with the board before you write job descriptions. Plan licensed clinicians for diagnosis and co-occurring care, a medical relationship for MAT (see adding MAT to an IOP), and a check of every hire against the federal OIG exclusion list. We build personnel files from our staff credential file checklist; accreditors pull them too.

Medicaid and the ASO

• The Public Behavioral Health System. Maryland Medicaid pays specialty behavioral health services through the Public Behavioral Health System (PBHS), administered by an administrative services organization (ASO) rather than the HealthChoice managed care plans.
• Carelon replaced Optum. The Maryland Department of Health's August 2025 report to the legislature says Carelon Behavioral Health began processing provider claims on January 1, 2025. MDH's February 2024 transmittal sets the base contract from January 1, 2025 through December 31, 2029, with a two-year option. Authorizations go to Carelon through its ProviderConnect portal.
• What it means for you. Enroll with Maryland Medicaid with your COMAR 10.63 license, register with the ASO, and request authorizations for Level 2.1 there. Commercial plans and Medicare Advantage are separate contracts.
• Medicare pays for IOP and PHP only through hospitals, community mental health centers and a few other provider types, so most freestanding programs plan without it (CMS 2024 outpatient rule).

Our credentialing service handles Medicaid enrollment, ASO registration and commercial facility contracts in any state; Medicaid enrollment is $500 per clinician. Getting insurance contracts for an IOP covers the commercial packet, where your accreditation letter does a lot of the work. Before every admission, verify benefits and authorization with the prior authorization guide.

Referrals and marketing

We didn't find a Maryland statute aimed specifically at substance use patient brokering. Federal prosecutors have used federal law against Maryland residents: in May 2024 a Baltimore man was sentenced in New Jersey federal court for a scheme that paid recruiters to bring people with addictions into rehab facilities (U.S. Attorney's Office, District of New Jersey). The Eliminating Kickbacks in Recovery Act (18 U.S.C. 220) covers treatment facilities whatever the payer. Pay marketers a salary, never per admission, and ask your attorney about Maryland's own laws. See patient brokering laws and marketing a treatment center.

The steps, in order

1. Define the program: Level 2.1, plus any other levels, adults or adolescents, and every county you'll serve.
2. Pick your accreditor from Maryland's approved list, and get its standards and initial-survey requirements.
3. Form the business with the Maryland State Department of Assessments and Taxation, get the EIN and the organization NPI, and line up a health-care attorney and CPA.
4. Contact the local behavioral health authority in each jurisdiction about the Agreement to Cooperate.
5. Find a site local zoning allows, and lease it with a way out if accreditation or licensing falls through.
6. Write the policy manual once, crosswalked to the accreditor, COMAR 10.63 and ASAM Level 2.1, plus 42 CFR Part 2 and HIPAA.
7. Hire the director, clinical supervisor and counselors, and verify each credential with the board.
8. Set up the EHR before the survey: Cima's IOP and PHP plan keeps levels of care, group notes with each member's entry, attendance and authorizations in one place.
9. Earn accreditation, then apply to BHA online with proof of accreditation and each Agreement to Cooperate.
10. Enroll with Maryland Medicaid and the ASO, and contract with commercial plans.
11. Keep both approvals current: license renewals, accreditation cycles, drills and chart reviews with the compliance calendar.

Questions

Do you need a license to open an outpatient rehab in Maryland?

Yes. An intensive outpatient program needs a COMAR 10.63 license from the Behavioral Health Administration, and for Level 2.1 that license is accreditation-based: you must be accredited by a Maryland-approved accrediting organization first.

What is an Agreement to Cooperate in Maryland?

A signed agreement between the program and the core service agency, local addictions authority or local behavioral health authority in each county or Baltimore City where it operates. BHA requires it before issuing a COMAR 10.63 license and with renewals, added services and license changes.

Which accreditors does Maryland accept?

The application requires accreditation from a Maryland-approved organization. BHA's materials have referenced CARF and The Joint Commission, and an early provider alert covered ACHC. Ask BHA for the current list before you choose.

Who is Maryland's behavioral health ASO?

Carelon Behavioral Health, since January 1, 2025, replacing Optum. The base contract runs through December 31, 2029, with a two-year option. Authorizations go through Carelon's ProviderConnect portal.

What's the difference between an LCADC and a CAC-AD?

Both are issued by the Board of Professional Counselors and Therapists. The LCADC is the independent license, requiring a master's degree, two years and 2,000 hours of supervised experience, the MAC exam and the Maryland law assessment. The CAC-AD is a certification that requires a bachelor's degree or higher in a counseling-related field.

Can a Texas company help with a Maryland program?

Yes, if it's honest about how. We run a Texas program, so in Maryland we work from COMAR 10.63, your accreditor's standards and the ASO's requirements, check each against the current text, and tell you where BHA, the local authority, the accreditor or your attorney has the final word. We don't guarantee accreditation, a license, a contract or a date.

Already accredited? The IOP / PHP Program Launch is $39,500. Or book a free 30-minute call and we'll walk through what Maryland will ask of you.

Cima Consulting isn't a law firm or an accounting firm. Maryland agencies and accreditors make their own decisions; we don't guarantee approvals, rates or dates. Never pay or accept anything of value for patient referrals: federal law (EKRA and the Anti-Kickback Statute) applies in every state.

Sources

• COMAR 10.63: 10.63.02 and 10.63.03 (BHA); 10.63.02.02 (Division of State Documents)
• Licensing process: BHA accreditation and regulations FAQ; BHA COMAR 10.63 provider presentation (2017); online application guide; Agreement to Cooperate (July 31, 2025); accreditation reference grid (2016)
• Proposed rewrite: transmittal, proposed action 26-079-P (July 13, 2026)
• Counselors: Board of Professional Counselors and Therapists, alcohol and drug; LCADC application
• ASO: MDH ASO transition report (August 2025); MDH transmittal PT 60-24
• Brokering prosecution: U.S. Attorney's Office, D.N.J.; EKRA, 18 U.S.C. 220: Cornell LII
• OIG exclusions: oig.hhs.gov; CMS, CY 2024 outpatient rule: cms.gov

Comparing states? See Texas and our guides for Alabama, Arizona, California, Colorado, Delaware, Florida, Georgia, Illinois, Indiana, Kentucky, Louisiana, Massachusetts, Michigan, Minnesota, Missouri, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, Tennessee, Utah, Virginia, Washington, West Virginia and Wisconsin, or how to start an IOP for what every state has in common.