Maryland Medicaid Waiver Services Covered: Complete CFC, COW, and CPAS Benefits List

Every Program Covers Different Things

One of the most frustrating parts of Maryland's home care system is that three programs with overlapping names cover different services, have different eligibility rules, and work under different legal authorities. A family applying for Community First Choice might assume it covers assisted living — it doesn't. Someone on the Community Options Waiver might not realize CFC services are also available to them. And CPAS, the least-known program, has a lower medical threshold that many families overlook entirely.

Here's what each program actually covers, and where the gaps are.

Community First Choice (CFC) Services

CFC is a Medicaid state plan option — not a waiver. That distinction means it operates as an entitlement: everyone who qualifies gets served. No waitlist, no enrollment cap.

CFC covers:

• Personal assistance with ADLs — bathing, dressing, grooming, eating, transferring, toileting, mobility assistance. This is the core benefit — hands-on help with the daily activities your parent can no longer manage independently.
• Personal assistance with IADLs — meal preparation, light housekeeping, laundry, grocery shopping, medication reminders. These instrumental activities aren't as medically intensive but are essential for independent living.
• Nurse monitoring — a registered nurse conducts periodic visits to evaluate the participant's health status, review the care plan, and supervise the care being provided by personal assistants. Nurse monitoring is mandatory under CFC and ensures clinical oversight even when the daily care is provided by unlicensed workers or family members.
• Personal emergency response systems (PERS) — a wearable medical alert device that connects to a 24/7 monitoring center. If your parent falls or experiences a medical emergency, they press the button and help is dispatched.
• Home-delivered meals — regular meal delivery for participants who cannot safely prepare food.
• Assistive technology — devices that support independent functioning. This can include specialized equipment for mobility, communication, or daily living tasks.
• Safety-related home modifications — grab bars, threshold ramps, minor structural changes to eliminate fall hazards and improve accessibility.
• Consumer-directed care — the option to hire family members (including, under CFC, a spouse) as paid personal care assistants through a Fiscal Management Services provider.

What CFC does not cover: assisted living facility fees, medical day care, behavioral health consultation, or family caregiver training. For those services, you need the Community Options Waiver.

Community Options Waiver (COW) Services

The COW is a 1915(c) waiver — it has a capped number of slots and a statewide waitlist. But it covers a broader range of services than CFC.

COW includes everything CFC covers, plus:

• Assisted living support — partial coverage of monthly fees in state-approved assisted living facilities. This is one Medicaid pathway to assisted living in Maryland.
• Medical day care — full-day supervised care in a licensed center providing skilled nursing, therapy, meals, and activities. Covered as part of the participant's Plan of Service. More details in our post on medical day care.
• Behavioral consultation — professional assessment and intervention for challenging behaviors associated with dementia, mental illness, or developmental conditions.
• Family caregiver training — structured education for family members providing care, covering safe transfer techniques, medication management, behavioral management, and self-care.
• Environmental assessment — professional evaluation of the home for safety hazards and modification needs.
• Respite care — temporary relief care so the primary caregiver can take a break. Available as in-home or facility-based respite.
• Transition services — support for individuals moving from a nursing facility back to the community under the Money Follows the Person initiative.

The catch: COW is not an entitlement. Even if your parent qualifies medically and financially, they must wait for a slot to open. Families often enroll in CFC first (immediately available) and simultaneously register for the COW to eventually access the broader benefit package.

Community Personal Assistance Services (CPAS)

CPAS is the least-known of the three programs, and it reaches people the other two miss. Its clinical threshold is lower — your parent needs assistance with at least one activity of daily living but does not need to meet the full nursing facility level of care that CFC and COW require.

CPAS covers:

• Personal care assistance — help with ADLs and IADLs, similar to CFC but at a lower clinical tier
• Consumer-directed care — the option to hire family members as paid caregivers (though spousal caregiving rules are less settled than under CFC)

CPAS provides a narrower personal-assistance benefit for individuals with moderate functional limitations. Because its covered services depend on the approved benefit and Plan of Service, confirm whether nurse monitoring, PERS, meals, home modifications, or day care are available in your parent's case.

Like CFC, CPAS is a state plan entitlement with no waitlist.

The Practical Comparison

Stacking Programs

When a participant receives a COW slot after waiting on the registry, the Supports Planner should review how the COW services coordinate with any existing CFC services and update the Plan of Service.

The Maryland home care navigation guide includes a program selection flowchart that matches your parent's medical status, financial situation, and care needs to the right combination of programs, with step-by-step application instructions for each.

See more Maryland guides →