Maryland’s 2026 HCBS Cost Survey: What Providers Need to Know
Maryland Medicaid launched its Annual Home and Community-Based Services (HCBS) Cost Survey on July 1, 2026.
For many HCBS providers, this is a new financial reporting requirement—and it is an important one.
The survey is due December 31, 2026, and Maryland Medicaid states that payments will be suspended for providers that are required to submit the survey but fail to do so by the deadline. Payments will resume once the completed survey is received.
So what is the HCBS Cost Survey, why is Maryland collecting this information now, and which providers actually have to complete it?
Why Is Maryland Requiring the HCBS Cost Survey?
According to the Maryland Department of Health (MDH), the HCBS Cost Survey is being used to help Maryland comply with the federal Centers for Medicare & Medicaid Services (CMS) Ensuring Access to Medicaid Services final rule.
A key part of that federal rule focuses on payment adequacy for Medicaid HCBS.
Maryland must be able to track how Medicaid provider payments relate to compensation paid to direct care workers. MDH states that the survey data will also be used to support fair, data-driven reimbursement rates and long-term program sustainability.
In other words, this is not simply a statistical survey.
The financial information providers submit is intended to help Maryland understand the actual economics of delivering HCBS—including the relationship between Medicaid reimbursement and the workforce providing those services.
Who Is Required to Complete the Survey?
MDH's current guidance is broad.
All Medicaid-enrolled HCBS providers that delivered non-DDA HCBS during State Fiscal Year 2026 are required to complete the survey.
MDH specifically states that this applies even if CMS does not specifically require reporting for that provider's particular service category.
There is an important distinction for DDA providers:
If You Provide Only DDA Services
You do not complete the HCBS Cost Survey for those services.
DDA providers instead report their annual cost information through the DDA General Ledger Data Collection process.
If You Provide Both DDA and Non-DDA HCBS
You may have two separate reporting requirements.
MDH states that providers delivering both DDA and non-DDA services must complete:
1. The DDA GL Data Collection Tool for DDA services; and
2. The HCBS Cost Survey for applicable non-DDA HCBS.
This distinction is important because completing one does not replace the other.
What Is Maryland Trying to Measure?
One of the major areas of focus is the HCBS direct care workforce.
MDH defines a direct care worker broadly as someone employed or contracted to provide hands-on services to Medicaid members.
This can include:
Personal care aides
Nursing assistants
Home health aides
Direct support professionals
Home care aides
Registered and licensed practical nurses providing direct services
Certain clinical staff
Supervisors providing clinical supervision to direct care workers
The federal payment-adequacy requirements are one reason Maryland needs reliable information about provider costs and direct care worker compensation.
Why Does the Cost Survey Matter to Providers?
There are two major reasons.
1. It Is a Required Medicaid Submission
The current deadline is:
December 31, 2026
MDH states that Medicaid payments will be suspended for providers that fail to submit the required survey by the deadline.
Payments will resume after Medicaid receives the completed survey.
For providers that rely heavily on Medicaid reimbursement, that makes the survey an important financial compliance requirement—not something to leave until the last minute.
2. The Data Can Influence Future Rate Decisions
MDH says it plans to use the information to support data-driven reimbursement rates and long-term HCBS program sustainability.
That makes accurate reporting important for the provider community as a whole.
If Maryland is evaluating whether reimbursement appropriately reflects the cost of delivering services, the quality of the financial information submitted by providers matters.
The survey provides an opportunity for actual provider costs to become part of that analysis.
What Should Providers Be Doing Now?
MDH's Provider Quick Start Guide outlines several steps providers should take before submission.
Providers should:
Confirm the organization's primary survey contact. Myers and Stauffer, Maryland's contractor for the survey process, will use that contact for future communications and submission-portal instructions.
Download the current survey and supporting materials. MDH directs providers to the Maryland HCBS provider resources maintained by Myers and Stauffer. Providers offering Home Delivered Meals services are directed to a separate Home Delivered Meals Cost Survey workbook.
Gather the organization's financial documentation. Providers should begin organizing the records needed to complete and support the survey rather than waiting until the submission deadline.
Use the available training and Q&A resources. MDH's Quick Start Guide directs providers to recorded training sessions, survey-tab training videos, and live technical assistance sessions.
Wait for individualized portal instructions before submitting. The Quick Start Guide specifically instructs providers not to email completed surveys or attempt portal submission before receiving the appropriate access instructions.
Do Not Treat the Survey as Just Another Form
The HCBS Cost Survey is fundamentally a financial reporting exercise.
Providers may need information from accounting records, payroll systems, financial statements, workforce records, and other supporting documentation to complete it accurately.
That is why preparation matters.
Before completing the survey, providers should make sure the financial information being used is complete, reconciled, and understandable.
If the accounting records do not clearly separate costs, payroll, or other required information, those issues are much easier to address before the submission deadline than while trying to complete the final workbook.
How Balanced Accounting Services Can Help
Balanced Accounting Services can prepare the Maryland HCBS Cost Survey for Medicaid providers.
BAS can assist with:
Reviewing and organizing financial records
Reconciling financial information used in the survey
Reviewing payroll and workforce-related financial data
Identifying missing or inconsistent information
Mapping financial records into the required survey format
Preparing survey workpapers and supporting schedules
Completing the HCBS Cost Survey workbook
Reviewing the completed survey for consistency and submission readiness
For organizations that provide both DDA and non-DDA HCBS, BAS can also help manage the separate financial reporting requirements for the DDA GL Data Collection and the HCBS Cost Survey.
The goal is not simply to enter numbers into a workbook.
It is to make sure the information submitted is supported by the provider's actual financial records and accurately reflects the cost of delivering services.
2026 HCBS Cost Survey Deadline
December 31, 2026
Providers that have not started the process should begin identifying their required financial and workforce information now.
Official Resources
Maryland Medicaid — Annual HCBS Providers Cost Survey Includes applicability, deadline, payment-suspension guidance, direct care worker definitions, and current provider resources.Maryland Medicaid HCBS Cost Survey
Maryland Department of Health — HCBS Cost Survey Provider Quick Start Guide Provides Maryland's step-by-step process for preparing for and submitting the 2026 survey.HCBS Cost Survey Provider Quick Start Guide
Maryland DDA — GL Data Collection Tool For providers that deliver DDA Medicaid services.DDA GL Data Collection Tool
CMS — Ensuring Access to Medicaid Services Final Rule The federal Medicaid access rule underlying Maryland's new HCBS cost-reporting initiative.CMS Ensuring Access to Medicaid Services Final Rule
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