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Maryland License Reinstatement

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A. Ant, CADC-II

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Author: A. Ant, CADC-II, Licensing & Accreditation Expert

Disclaimer: This content is provided for general informational purposes only and should not be construed as legal, regulatory, or licensing advice. Requirements change frequently. Consult qualified professionals for guidance specific to your situation.

A Maryland behavioral health license can be lost in several ways, and the Maryland Department of Health, Behavioral Health Administration (BHA) has a defined sequence for each one under COMAR 10.63.06. Knowing where you sit in that sequence decides what you should do this week. In the files we see, a revocation usually traces back to a notice of deficiencies that got a late answer, a thin answer, or an answer from someone who had no authority to fix the problem. That pattern is our observation, not something BHA publishes.

The Deficiency Notice Starts a Ten-Working-Day Clock

The clock on this notice starts the moment it lands, regardless of when someone actually reads it. When BHA finds a violation but does not suspend the license, it sends a notice of deficiencies listing each failure, the requirement, and the basis for the finding. Under COMAR 10.63.06.12, the organization must submit a plan of correction within 10 working days of receipt. The regulation only requires the plan to say how and when each failure will be corrected. We also recommend naming the person responsible for each item and explaining how you will keep it from happening again, because a reviewer reading a bare list of dates has little reason to believe the fix will hold. The director of the licensing unit can extend the deadline by up to 30 days, and BHA can demand an answer sooner when the risk warrants it. A program that receives a notice must also tell the individuals it serves, or their guardians, that the notice was issued. Count working days from the day the notice arrives, not the day you read it.

Sanctions Short of Revocation

BHA can layer several actions on a program without ending its license. It can prohibit new admissions, require a lower census, prohibit specific services or restrict the program to a named few, order mandatory staff training, require the program to use a consultant the Department approves in advance, require the program to set up an escrow account, and impose a civil money penalty (COMAR 10.63.06.14). Separately, under COMAR 10.63.06.15, BHA can add a directed plan of correction that mandates staffing patterns, places a temporary site monitor in the program, and requires periodic progress reports. Each sanction triggers a duty to notify the people you serve. BHA may also enter a settlement agreement setting conditions and time limits for continued operation, and a settlement agreement is a public document that must be given to individuals served or posted in a public location at the site.

Summary Suspension and Revocation

When public health, safety, or welfare imperatively requires it, BHA can suspend a license immediately. The program must stop serving individuals and carry out a Department-approved plan to notify participants, transition them to another program, protect and transfer records, and notify staff and contractors. Revocation under COMAR 10.63.06.13 is available to BHA when a program has violated the licensing requirements or the terms of an intermediate sanction already imposed on it. COMAR 10.63.06.19 lists what a program can take to a hearing: denial of a license or renewal, a summary suspension, a refused license modification, a refused request to discontinue a program, a revocation, and a sanction imposed under the intermediate sanction, settlement agreement, or civil money penalty rules. The written hearing request is due within 10 working days after the notice is received. Miss that window and the right to a hearing is waived, and BHA may go ahead with the action. When possible, BHA can offer an informal case resolution conference to try to settle some or all of the deficiencies. Hearings follow the Department’s procedures in COMAR 10.01.03, and a hearing on a summary suspension, which takes place after the suspension is already in effect, runs under the Administrative Procedure Act in State Government Article, Title 10, Subtitle 2.

Accreditation Loss Is a License Problem

These two processes run on separate tracks, but a problem in one quickly becomes a problem in the other. An accreditation-based license lasts for the accreditation period plus three months (COMAR 10.63.06.05), the application has to include the accreditor’s final letter or certificate along with the latest survey report (COMAR 10.63.06.03), and BHA can enforce the accreditor’s own standards against the program (COMAR 10.63.02.03). Put those together and a denied or withdrawn accreditation leaves the license with nothing to stand on at renewal, so the accreditor’s appeal process becomes part of your reinstatement plan. The current regulation does not spell out what BHA does with a license in the middle of its term when accreditation is lost, and it does not describe an extension for discharge planning. Our advice is to tell BHA licensing staff as soon as an adverse accreditation decision arrives and ask, in writing, how they will treat the license while the appeal is pending. In our experience, programs that work the accreditor and the state at the same time keep more of their options open than programs that wait on one before starting the other. A CARF or Joint Commission corrective action plan and a BHA plan of correction should say the same thing.

Reinstating After Revocation

There’s no shortcut built into the regulation here. Nothing in COMAR 10.63.06 describes a separate reinstatement track. A program that loses its license generally has to apply again, with a final accreditation letter in hand, a corrected record, and an Agreement to Cooperate signed with the CSA, LAA, or LBHA for its county or Baltimore City before the application is filed (COMAR 10.63.01.05). That new application starts behind. COMAR 10.63.06.06 already lets BHA deny a license to an applicant that had a license revoked, or surrendered one for disciplinary reasons, within the previous 10 years, and the same look-back reaches an applicant whose officer served with a provider that lost a license that way. A program that closed without following the discontinuation rules in COMAR 10.63.06.10 can be denied too. Applications have gone through BHA’s online system since February 10, 2025, and questions can go to bha.licensingcompliance@maryland.gov. Operating without a required license is separately exposed to civil money penalties, and a standalone civil money penalty chapter, COMAR 10.63.08, took effect April 14, 2025.

Be Careful Who You Hire When the License Is at Risk

An operator with a license in jeopardy is exactly the person a bad promise finds. In an April 17, 2026 provider alert, BHA said it does not expedite applications for a fee, that applications are reviewed in the order received, and that providers should be cautious about consultants who make any guarantee or promise of licensure. The state decides the outcome, so the useful help is a correction plan that answers BHA’s findings and an accreditation record that supports it.

Frequently Asked Questions

How long do I have to respond to a BHA notice of deficiencies?

Under COMAR 10.63.06, the organization must submit a plan of correction within 10 working days of receiving the notice. The licensing unit director can extend that by up to 30 days, and BHA can require a faster response when the risk warrants it.

Can I appeal a BHA suspension or revocation in Maryland?

Yes, for most actions. The organization must submit a written request for a hearing within 10 working days after receiving the notice. If the request is not submitted in that window, the right to a hearing is waived.

Is there a separate process to reinstate a revoked Maryland license?

Nothing in COMAR 10.63.06 describes a separate reinstatement track. A program that loses its license generally applies again, with accreditation intact and a corrected record. COMAR 10.63.06.06 also lets BHA deny an application from an applicant whose license was revoked within the previous 10 years, so the practical work is resolving the findings before revocation takes effect.

Working through a BHA notice of deficiencies on a tight clock? Reach out here.

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