Plan of Service Maryland Medicaid: What It Is, What It Controls, and How to Change It

The Document That Controls Everything

When your parent qualifies for Community First Choice (CFC), CPAS, or the Community Options Waiver in Maryland, the state doesn't just flip a switch and send caregivers. Instead, the assigned Supports Planning Agency creates a document called the Plan of Service (POS). This document specifies exactly what care your parent receives, how many hours per week, what types of services are covered, and — if using consumer-directed care — how much the personal care budget is.

The Plan of Service is the single most consequential document in your parent's home care arrangement. If a service isn't in the POS, Medicaid won't pay for it. If the authorized hours don't match your parent's actual needs, the gap comes out of pocket. Understanding how the POS works — and how to challenge it — gives families real leverage over the care their parent receives.

How the Plan of Service Gets Created

The POS development follows a specific sequence:

Step 1: The clinical assessment. A registered nurse from the local health department conducts an interRAI Home Care evaluation. This standardized instrument measures your parent's functional limitations across activities of daily living (bathing, dressing, eating, transferring, toileting), instrumental activities (cooking, cleaning, managing finances), cognitive status, and behavioral health. The interRAI results generate a clinical profile that determines both program eligibility and the level of care authorized.

Step 2: The person-centered planning meeting. The Supports Planner convenes a meeting with your parent, family members, and any involved professionals (physicians, therapists). The meeting is supposed to be person-centered — meaning your parent's preferences, goals, and daily routines drive the conversation, not just the clinical data.

During this meeting, the Supports Planner and family discuss:

• What daily care tasks your parent needs help with and when
• Whether to use the agency model (a licensed RSA sends its staff) or consumer-directed care (your parent hires their own assistants)
• What additional services to include: home-delivered meals, personal emergency response systems, nurse monitoring, home modifications, assistive technology
• How to allocate the personal care budget across services

Step 3: The written POS. The Supports Planner drafts the formal Plan of Service, specifying:

• Authorized weekly care hours
• Service types and frequencies
• Budget allocation (for consumer-directed participants)
• Goals and expected outcomes
• The reassessment schedule

Your parent (or authorized representative) reviews and signs the POS. Signing doesn't mean you can't challenge it later — but it does authorize Medicaid to begin funding services per the plan's terms.

What Families Get Wrong About the POS

Treating it as final. The POS is not a one-time determination. It's reviewed at least annually, and it can be amended at any time if your parent's medical or functional condition changes. If your parent's dementia worsens, if they start falling more frequently, or if a new medical condition adds care complexity, you have the right to request a reassessment and a POS revision.

Not attending the planning meeting. Families who send only the care recipient — particularly a parent with cognitive decline — to the planning meeting often end up with a POS that understates care needs. Seniors with dementia routinely self-report higher function than they actually have. A family member who observes the parent daily provides the context the Supports Planner needs to authorize appropriate hours.

Accepting hours that are too low. The interRAI assessment generates a clinical score, and the state uses that score to calculate authorized hours. But clinical algorithms don't perfectly capture every situation. If you believe the authorized hours are insufficient, you have options (see below).

How to Request Changes

If the Plan of Service doesn't reflect your parent's actual care needs, you can:

1. Request a reassessment. Contact the Supports Planning Agency and explain why the current hours or services are insufficient. Provide specific examples — "Mom fell twice this week," "Dad needs help with meals that aren't currently covered." The Supports Planner can request a new interRAI evaluation from the local health department.

2. Request a POS amendment. The Supports Planner can adjust the plan between formal reassessments if circumstances change. A hospitalization, a new diagnosis, or the loss of a secondary caregiver are all grounds for an amendment.

3. File an administrative appeal. If the state denies eligibility, reduces authorized care hours, or removes a service from the plan, your parent has the right to appeal to the MDH Office of Health Services Appeals Unit. The appeal must be submitted within 90 days of the adverse notice. And this is critical: if the state is reducing existing services (not denying new ones), filing the appeal within 10 days of the notice date preserves the current service level during the appeal — your parent's care continues at the pre-reduction level until the hearing is resolved.

More on the appeal process in our post on how to appeal a Medicaid denial in Maryland.

Preparing for the Planning Meeting

Go in with documentation:

• A written log of your parent's daily care needs, with specific times and tasks
• Recent medical records showing diagnoses, hospitalizations, and functional limitations
• A list of medications (some medications create care dependencies that the interRAI assessment alone won't capture)
• Notes on any safety incidents — falls, wandering episodes, medication errors, emergency room visits

The better your documentation, the stronger the case for appropriate hours and services. The Maryland home care navigation guide includes a care log template and an assessment preparation checklist designed specifically for Maryland's interRAI evaluation — helping families translate their daily observations into the clinical language that drives POS allocations.

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