This page is for operators, clinical leaders, and investors opening, expanding, relocating, or maintaining a licensed behavioral health or substance use disorder program in Maryland.

Table of Contents

Additional Maryland Licensing Guides

In Maryland, Accreditation Comes Before the License

Most states license first and let accreditation follow. Maryland runs that order backward, which changes how the whole planning calendar has to work.

Most states license a program and let accreditation follow. Maryland reverses the order. Under COMAR 10.63, the Maryland Department of Health, Behavioral Health Administration (BHA) issues what it calls an accreditation-based license, and for nearly every community-based program type it will not issue that license until the program holds accreditation from an organization the state has approved. The current approved list is ACHC, CARF, the Council on Accreditation, and The Joint Commission. Before applying, you also sign an Agreement to Cooperate with the Core Service Agency, Local Addictions Authority, or Local Behavioral Health Authority in each jurisdiction where you will operate. The accreditation survey, the local agreements, and the BHA application each run on their own calendar, which is exactly what makes sequencing them correctly the hard part.

Three other facts shape a Maryland plan. The Maryland Health Care Commission (MHCC) controls who may open a Level 3.7 alcohol and drug intermediate care facility or add hospital-level psychiatric capacity. That control changed on October 1, 2026. Chapters 68 and 69 of 2026 now let a medically managed residential facility open without a full Certificate of Need if it files written notice with MHCC at least 45 days ahead and the Commission finds the project not inconsistent with the State Health Plan, more efficient, and in the public interest. We have not found any MHCC review that reaches outpatient care or residential Levels 3.1 through 3.5. COMAR 10.63 itself is also up for replacement: the Maryland Department of Health published a full proposed rewrite in the August 21, 2026 Maryland Register, comments closed September 21, 2026, and the department’s revisions page does not yet show the new text adopted. Confirm which version governs your application on the day you file. Finally, in an April 17, 2026 alert, BHA said applications are reviewed in the order received, called offers to expedite a license for money misinformation, and urged providers to be cautious about consultants who make “any guarantee or promise of licensure.”

Primary Regulatory Agencies

Straight from BHA’s, MHCC’s, and OHCQ’s own published descriptions of their roles.

Maryland Department of Health, Behavioral Health Administration (BHA), which licenses community-based mental health and substance use disorder programs under COMAR 10.63
Maryland Health Care Commission (MHCC), which reviews Certificates of Need for psychiatric hospital capacity and for Level 3.7 alcohol and drug intermediate care facilities, and since October 1, 2026 also rules on the 45-day notice exemption those facilities can use instead
Office of Health Care Quality (OHCQ), which licenses and surveys hospitals and other health care facilities after MHCC approval
Maryland Board of Professional Counselors and Therapists, which issues the alcohol and drug counselor credentials and the LGPC and LCPC counseling licenses
Core Service Agencies, Local Addictions Authorities, and Local Behavioral Health Authorities, the county-level bodies that sign the Agreement to Cooperate before BHA will license a program

Maryland Behavioral Health Licensing Snapshot

A reference table, not analysis, drawn from the statutes cited in each row.

Primary SUD Regulator	BHA, under COMAR 10.63
Primary Mental Health Regulator	BHA under COMAR 10.63 for community-based programs, with hospital-level psychiatric care licensed by OHCQ after MHCC approval
Residential Treatment	Available at ASAM Levels 3.1, 3.3, 3.5, and 3.7 under accreditation-based licenses, plus community mental health residential programs
Outpatient Treatment	Available as Outpatient Level 1, Intensive Outpatient Level 2.1, and Partial Hospitalization Level 2.5, plus outpatient mental health programs
Withdrawal Management	Added as a Withdrawal Management Service on top of an Outpatient Level 1, Level 2.1, Level 2.5, or residential Level 3.1 through 3.7 license (COMAR 10.63.02.02). A Level 3.7 withdrawal management unit also sits inside MHCC’s intermediate care facility review
Facility License Required	Yes, a BHA license for community-based programs, after accreditation and a signed Agreement to Cooperate
Certificate of Need	Reviewed by MHCC for Level 3.7 alcohol and drug intermediate care facilities and hospital-level programs. Since October 1, 2026, a Level 3.7 facility can skip a full Certificate of Need by filing notice with MHCC at least 45 days ahead, but only if the Commission finds the project not inconsistent with the State Health Plan, more efficient and effective, and in the public interest (Chapters 68 and 69 of 2026)
National Accreditation	Required before BHA issues an accreditation-based license, from ACHC, CARF, COA, or The Joint Commission
Inspection	BHA can inspect after licensing and whenever significant concerns come up about a program or its accreditor (COMAR 10.63.02.03). In practice the accreditor’s survey carries most of the routine review
License Renewal	An accreditation-based license runs for the accreditation period plus 3 months, and the renewal application is due at least 60 days before it expires (COMAR 10.63.06.05)
Key Regulations	COMAR 10.63 (community-based behavioral health programs), COMAR 10.24.14 (alcohol and drug intermediate care facility standards), Health-General Article §19-120 (Certificate of Need, amended by Chapters 68 and 69 of 2026), COMAR 10.58.07 (alcohol and drug counselors)

Which Requirements Apply to Which Maryland Program

Organized this way because BHA’s own material doesn’t lay it out program by program.

Program	Accreditation Before License	Agreement to Cooperate	Certificate of Need
Outpatient Level 1, IOP Level 2.1, PHP Level 2.5	Yes	Yes	No
Residential Levels 3.1, 3.3, 3.5	Yes	Yes	No
Residential Level 3.7, including 3.7 withdrawal management	Yes	Yes	Yes, a Certificate of Need or, since October 1, 2026, a notice exemption once MHCC makes the required findings
Outpatient mental health centers, mobile treatment, psychiatric rehabilitation	Yes	Yes	No
Community residential mental health programs	Yes	Yes	No
Special psychiatric hospital or acute psychiatric unit	Not a BHA condition	Not applicable	Yes, from MHCC, then OHCQ licensure

The table leaves out an optional credential. ASAM and CARF together offer an ASAM Level of Care Certification for adult residential programs at Levels 3.1, 3.5 and 3.7, separate from the accreditation listed above. Payers wanting a second confirmation of the level BHA licensed have a place to get it, CARF’s provider search, since the certification itself may not be printed on the BHA license.

Programs Covered

Residential substance use disorder treatment at ASAM Levels 3.1, 3.3, 3.5, and 3.7
Outpatient substance use disorder treatment, including intensive outpatient and partial hospitalization
Withdrawal management services, with coordination for medication-assisted treatment where clinically indicated
Outpatient mental health treatment, including outpatient mental health centers, mobile treatment, and psychiatric rehabilitation for adults
Community residential mental health treatment and hospital-level psychiatric care

Key Licensing Requirements

Taken from BHA’s own rule text rather than paraphrased secondhand.

Accreditation from an organization approved by the Maryland Department of Health, chosen from BHA’s crosswalks for your exact program types
A signed Agreement to Cooperate with the local authority in every jurisdiction where you will operate
A COMAR 10.63 application to BHA listing every service and site, with local fire, safety, and health permits for each site
For a Level 3.7 program, a Certificate of Need or, since October 1, 2026, an approved MHCC notice exemption before the license
Counselors credentialed through the Board of Professional Counselors and Therapists, with supervision that follows the Board’s supervisor rules
A plan for the ongoing accreditation cycle, since the license lasts for the accreditation period plus 3 months and renewal is due 60 days before it ends

Frequently Asked Questions

How much does it cost to get licensed in Maryland?

BHA’s own application is a small part of the total. The real cost sits in the accreditation survey and preparation, facility buildout, staff credentialing, and policy development. Accreditation survey fees commonly run from a few thousand dollars into the low five figures depending on the accreditor and the number of programs, and most new outpatient programs budget between $200,000 and $450,000 in total pre-opening investment. Residential programs run considerably higher, and a Level 3.7 build adds the cost of an MHCC filing (a Certificate of Need application, or since October 2026 the shorter exemption notice) before the license work even begins. Those are our planning ranges, not state-published figures.

How long does Maryland behavioral health licensing take?

In our experience, a realistic range for an outpatient program is 9 to 15 months from planning to a BHA license, and residential programs commonly run 12 to 18 months, because most of the calendar belongs to the accreditation survey. A Level 3.7 program adds MHCC’s review ahead of that, and even the new exemption route needs at least 45 days’ notice. We have not found a published BHA processing time. BHA does say it reviews applications in the order received and won’t expedite one for money.

What trips people up most often during Maryland’s licensing process?

Treating accreditation as a parallel workstream when BHA treats it as the entry ticket is the most common structural mistake in Maryland. The second most common problem is a missing or unsigned Agreement to Cooperate for one of the jurisdictions on the application. Others include choosing an accreditor that is not approved for the program types on the application, assuming the Level 3.7 Certificate of Need rule reaches every residential level, and paying for a promised speed-up that BHA has said does not exist.

Do you guarantee Maryland licensure?

No. BHA’s April 2026 provider alert cautions providers about consultants who make any guarantee or promise of licensure, and we share the caution, since the state decides the outcome. What we do commit to is not taking you on as a client unless we believe we can get you licensed, backed by a program built against BHA’s actual current requirements, sequenced so accreditation, local agreements, and the application land in the right order.

How much staff will I need to open a behavioral health program in Maryland?

It depends on service type and census, but a small outpatient program with a clinical director and two to three counselors commonly runs $210,000 to $290,000 a year in clinical payroll before benefits. Maryland’s substance abuse, behavioral disorder, and mental health counselors earn a median of $59,530 a year statewide (BLS OEWS, May 2025), just above the national median of $59,350, with the middle half earning between $50,030 and $73,220. Those figures look steep in isolation, but few Maryland operators are actually paying them in full. The state’s addiction counseling ladder, governed by the Board of Professional Counselors and Therapists, runs from Alcohol and Drug Trainee through the Certified Supervised Counselor (CSC-AD) and Certified Associate Counselor (CAC-AD) up to the graduate-level LGADC and the clinical-level LCADC. A Board-approved supervisor can oversee CAC-AD and CSC-AD counselors and trainees, so a common approach staffs the program with those counselors at lower wages while they build hours toward the next tier, with an LCADC as clinical director. The actual staffing matrix and cost estimate, mitigation strategies included, follow once the program model itself is confirmed.

Licensing

Who licenses substance use disorder and mental health programs in Maryland?

BHA licenses community-based programs for both populations under COMAR 10.63. Hospital-level psychiatric care runs through MHCC’s Certificate of Need process and OHCQ hospital licensure instead.

Does Maryland require accreditation before I can be licensed?

Yes, for the accreditation-based programs, which include nearly every outpatient and residential program type described here. A short list, including DUI education and Early Intervention Level 0.5 programs, holds a license that doesn’t require accreditation (COMAR 10.63.05), and COMAR 10.63.01.04 exempts some providers altogether, so confirm your category with BHA.

Which accreditors does Maryland approve?

The Maryland Department of Health currently approves ACHC, CARF, the Council on Accreditation, and The Joint Commission, and the National Commission on Correctional Healthcare for correctional facilities only. BHA publishes a crosswalk for each, and not every accreditor is approved for every program type.

Is the COMAR 10.63 rewrite in force yet?

Not yet, as of early October 2026. A May 16, 2025 proposal covering Chapters 01, 02, 06, and 09 was withdrawn, with the notice printed in the August 22, 2025 Maryland Register. The department then sent a full replacement package to the AELR Committee on July 10, 2026 and published it as a proposal in the August 21, 2026 Register, taking comments through September 21, 2026. Its revisions page shows no adoption date yet, so ask BHA which text governs your application on the day you file.

Facility

Do I need a physical location before I apply?

Yes. The BHA application lists the services you will provide and the physical sites where you will provide them, and it has to include local fire, safety, and health permits for each site. Zoning is handled locally, so confirm it before you sign a lease.

Does opening a second location change my license?

Yes. Adding or moving a location, or adding a service, is a license modification that needs the Department’s approval first (COMAR 10.63.06.07), and BHA’s Agreement to Cooperate form is required again for a change in locations, service array, or ownership.

Does a Certificate of Need apply to my facility?

MHCC review comes in if you are building a Level 3.7 alcohol and drug intermediate care facility or a hospital-level program. We have not found an MHCC requirement for outpatient care or for residential Levels 3.1 through 3.5. For Level 3.7 the rules changed on October 1, 2026. Under Chapters 68 and 69 of 2026 (Senate Bill 444 and House Bill 498), a new facility offering medically managed residential treatment can skip the full Certificate of Need if it files written notice with MHCC at least 45 days before opening and the Commission, in its sole discretion, finds the project not inconsistent with the State Health Plan, more efficient and effective, and in the public interest. A licensed facility that wants to change its bed count now goes through the same notice and findings, which replaced the older bed-change exemption.

Staffing

What credentials do addiction counselors need in Maryland?

The Board of Professional Counselors and Therapists issues the Alcohol and Drug Trainee status and the CSC-AD, CAC-AD, LGADC, and LCADC credentials. The CAC-AD is a bachelor’s-level credential requiring at least 1 year and 1,000 hours of clinically supervised experience, the LGADC is a graduate-level license that may not practice independently or supervise others (COMAR 10.58.07.04), and the LCADC is the full clinical license an LGADC works toward.

Who can supervise my counselors?

Only a Board-approved alcohol and drug counselor supervisor. That pool includes LCADCs, CPC-ADs, LCPCs, and licensed clinical marriage and family therapists, plus CAC-ADs who have held the certificate for at least 2 years. Every supervisor also needs 3 years of documented alcohol and drug counseling experience with 3,000 hours of direct client contact, plus supervision coursework, 18 CEUs of approved supervision training, or a recognized national supervisor credential (COMAR 10.58.07.02 and .14). An LGADC builds the 2 years and 2,000 hours of supervised experience the LCADC requires under one of those approved supervisors.

Do mental health programs use a different credentialing process?

Counselors are licensed by the same Board as LGPC and LCPC. Social workers and psychologists aren’t on this Board’s credential list, so verify each of their licenses with the board that issued it.

Operations

What is the Agreement to Cooperate?

It is a written agreement between your program and the Core Service Agency, Local Addictions Authority, or Local Behavioral Health Authority in each jurisdiction where you operate. BHA requires it with an initial application, a renewal, an added service, or a change of location or ownership. The agreement has to cover cooperation on complaint investigations and on moving clients if the program closes. Some counties have a separate Core Service Agency and Local Addictions Authority instead of a single Local Behavioral Health Authority. BHA’s own licensing primer covers that case: a program offering both mental health and substance use services in one of those counties needs an agreement from the Core Service Agency and a second one from the Local Addictions Authority.

Can I pay to speed up my BHA application?

No. In its April 17, 2026 alert, BHA said it does not expedite applications based on recommendations or relationships, that an offer to speed up a license in exchange for money is misinformation, and that applications are reviewed in the order received. It also said any real closure of the licensing portal would be announced by provider alert, not by someone asking for payment.

How does medication for opioid use disorder fit into a Maryland license?

The Consolidated Appropriations Act, 2023 removed the federal waiver, so any practitioner whose DEA registration includes Schedule III can now prescribe buprenorphine for opioid use disorder. That lets a program build a medication pathway on-site or through a prescriber relationship. Methadone for addiction treatment is a different matter: outside narrow exceptions such as hospital care and a 3-day emergency supply, it is dispensed by an opioid treatment program holding both federal certification under 42 CFR Part 8 and a DEA narcotic treatment registration. In Maryland, Opioid Treatment Service is an add-on service under a COMAR 10.63 license, so programs without it usually coordinate with an OTP by written agreement.

Enforcement

What happens if BHA finds deficiencies?

BHA issues a notice of deficiencies, and the organization must submit a plan of correction within 10 working days of receipt. BHA can also impose sanctions such as limits on admissions, mandatory training, an approved consultant, an escrow account, or a civil money penalty (COMAR 10.63.06.14). On top of those sanctions, COMAR 10.63.06.15 lets BHA issue a directed plan of correction that can set staffing patterns, place a temporary site monitor in the program, or require periodic progress reports, and the program has to tell the people it serves that it received one.

Can I appeal a suspension or revocation?

Yes, for most actions. A written request for a hearing must be submitted within 10 working days after the notice is received, and the right is waived if the window is missed.

What if I lose my accreditation?

An accreditation-based license can only be issued to an accredited program, and its term is pegged to the accreditation period, so losing accreditation puts the license at risk. Our advice is to tell BHA as soon as an adverse decision arrives and appeal through the accreditor. If the program has to wind down, COMAR 10.63.06.10 covers discontinuing operations, and your Agreement to Cooperate already commits you to work with the local authority on moving clients.

What’s Included and What Isn’t

What we help with in Maryland

We help behavioral health and SUD operators sequence accreditation, the Agreement to Cooperate, and the BHA application so each step lands in the right order, and we help determine whether a Level 3.7 Certificate of Need applies to a specific build.

What falls outside that scope

We don’t handle CMS, Medicare, or Medicaid enrollment and billing matters, and marketing isn’t something we provide directly either. Our focus is licensing, certification, and accreditation, not payer credentialing. If you need marketing help, we’re happy to point you toward people who specialize in it.

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.

Maryland’s Behavioral Health Administration has publicly cautioned providers about licensure outcomes. In keeping with the spirit of that guidance, we don’t offer a guarantee on Maryland engagements, but we stand behind our own commitment: we won’t take on a program we don’t believe we can get licensed.

Sequencing accreditation and BHA licensing for a Maryland program? Let’s talk it through.

Sources

COMAR 10.63.01.02 and 10.63.01.05: Requirements for Licensed Community-Based Behavioral Health Program (checked October 7, 2026)
COMAR 10.63.01.04: Exempt Providers (checked October 7, 2026)
COMAR 10.63.02.02: Covered Programs and Services (checked October 7, 2026)
COMAR 10.63.02.03: Requirements for a Program with an Accreditation-Based License (checked October 7, 2026)
COMAR 10.63.05: Programs Requiring a Non-Accreditation-Based License (checked October 7, 2026)
COMAR 10.63.06.02: License Application Process (checked October 7, 2026)
COMAR 10.63.06.05: Issuance and Duration of Licenses (checked October 7, 2026)
COMAR 10.63.06.07: License Modification (checked October 7, 2026)
COMAR 10.63.06.10: Discontinuation of Program Operations (checked October 7, 2026)
COMAR 10.63.06.12 and .14: Notice of Deficiencies and Intermediate Sanctions (checked October 7, 2026)
COMAR 10.63.06.15: Directed Plan of Correction (checked October 7, 2026)
COMAR 10.63.06.19 and .20: Hearing Rights and Procedures (checked October 7, 2026)
Maryland Department of Health: COMAR 10.63 Regulatory Revisions (checked October 7, 2026)
BHA: Accreditation Based Licensing (checked October 7, 2026)
BHA: Alert Regarding Licensing Misinformation, April 17, 2026 (checked October 7, 2026)
BHA: Agreement to Cooperate form (checked October 7, 2026)
BHA: Introduction to Accreditation and Licensing Requirements (checked October 7, 2026)
Maryland General Assembly, Health-General §19-120: Certificate of Need (checked October 7, 2026)
Maryland General Assembly, Chapter 69 of 2026 (HB 498): Certificate of Need, Intermediate Health Care Facilities (checked October 7, 2026)
Maryland General Assembly, Chapter 68 of 2026 (SB 444): Certificate of Need, Intermediate Health Care Facilities (checked October 7, 2026)
Department of Legislative Services, Fiscal and Policy Note for HB 498 (2026): Certificate of Need, Intermediate Health Care Facilities (checked October 7, 2026)
MHCC: Hospital Certificate of Need (checked October 7, 2026)
COMAR 10.24.14: State Health Plan, Alcoholism and Drug Abuse Intermediate Care Facility Treatment Services (checked October 7, 2026)
MHCC: Certificate of Need, Hygea Detox at Camp Meade (Level 3.7 and 3.7WM) (checked October 7, 2026)
OHCQ: Programs (checked October 7, 2026)
COMAR 10.58.07: Alcohol and Drug Counselors, Requirements for Certification and Licensure (checked October 7, 2026)
COMAR 10.58.12.02: Licensed Clinical Professional Counselors, Definitions (checked October 7, 2026)
SAMHSA: Waiver Elimination (MAT Act) (checked October 7, 2026)
eCFR, 42 CFR 8.11: Opioid treatment program certification (checked October 7, 2026)
21 CFR 1306.07 (Cornell LII mirror, eCFR returned errors): Administering or dispensing of narcotic drugs (checked October 7, 2026)
CARF International: ASAM Level of Care Certification and Find a Provider (checked October 7, 2026)
American Society of Addiction Medicine: Level of Care Certification (checked October 7, 2026)