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    Billing & Compliance
    September 8, 20267 min read

    The HOPE Act Rate Study Cost Report Is Due September 30: What Maryland OMHCs, PRPs, and SUD Programs Need to Submit

    For OMHC, PRP, and SUD Level 2 (IOP and PHP) leaders who received the Myers and Stauffer cost survey and have not finished it, or have not started.

    On this page

    Somewhere in your inbox is an email from July with a spreadsheet attached. It came from Myers and Stauffer, on behalf of the Maryland Department of Health, and it asked for your program's costs. It was due August 28. Then, on August 21, the state gave everyone until September 30.

    If you filed it, this article is a checklist to confirm you filed it well. If you did not, you have three weeks, one more office hour, and a real reason to get it done.

    What this is

    The Heroin and Opioid Prevention Effort (HOPE) and Treatment Act of 2017 required the state to study what behavioral health services actually cost and to use that to modernize how Medicaid pays for them. In 2026 the General Assembly created the Behavioral Health Rate Methodology Modernization Workgroup (SB 39 and HB 772, Chapter 218, Laws of 2026) and set a timeline. MDH hired Myers and Stauffer LC, a rate-setting firm, to run the study.

    The first phase covers three provider types: Outpatient Mental Health Clinics, Psychiatric Rehabilitation Programs, and SUD Level 2 programs, meaning ASAM 2.1 intensive outpatient and 2.5 partial hospitalization. Every licensed provider in those categories was included; there was no sampling. Myers and Stauffer will analyze the submissions and deliver rate models and a final rate analysis report to MDH by January 31, 2027. Later phases will reach the remaining levels of care.

    In plain terms: the numbers you submit this month are the numbers the state will use to argue about your rates next year.

    The dates

    The cost survey and instructions were released July 24, 2026. Training webinars ran July 28 and 30 (recordings are on the Myers and Stauffer page). Office hours were held August 5 and August 18. The original due date was August 28.

    On August 21, MDH extended the deadline to September 30, 2026, and added one more office hour: Wednesday, September 9, 2026, 3:00 to 4:00 PM. That is the last scheduled live support before the deadline.

    The FAQ is blunt about further extensions: none were going to be considered beyond the original date, and the state only moved once because of the volume of provider feedback. Plan on September 30 being firm.

    Is it mandatory?

    The FAQ says MDH "requests that providers selected for the rate study participate fully." It does not name a penalty for not filing. Read the next sentence, though, because it is the one that matters: if participation is limited, the department "may supplement the analysis with publicly available or other external data sources that may not fully reflect provider operations or costs."

    That is the consequence. If your program's costs are not in the data set, the rate model will be built from someone else's, or from proxies. Programs that run lean on paper but carry real costs in supervision, documentation time, transportation, and no-shows are exactly the ones that lose when the model is built without them. Filing is how you get your cost structure counted.

    Newly established providers do not get an exemption or a deferral, and there is no "modified" participation. The survey is expected to be completed fully.

    What you are submitting

    The instrument is the MD BH Cost and Information Survey, an Excel workbook, with a separate instructions document. Both are on the Myers and Stauffer Maryland BHA resource page, along with the FAQ, the training slides, and both training recordings.

    Three rules from the FAQ that trip people up:

    One survey per Maryland Medicaid provider number, with every site under that number on the same survey. If your provider number is 9999900 and you operate sites 00, 01, and 02, all three go on one workbook, identified on the Location Info tab. If your organization holds several provider numbers, put all of them on one survey and list the locations.

    RRP is reported under PRP. If you run a PRP, Residential Rehabilitation Program services are reported under PRP; the RRP modifiers sit inside the PRP procedure codes. Room and board is not Medicaid-billable and is not part of the PRP codes.

    Supported employment goes in "other." It has its own codes (H2023, H2024, H2024-21, H2026, H2026-21, and S9445-52) and is reported in the "other" category, not folded into PRP.

    The FAQ also settles the SUD level question: Level 1 is outpatient under COMAR 10.63.03.06, Level 2 is IOP (2.1) under 10.63.03.03 and PHP (2.5) under 10.63.03.07. Only Level 2 is in this phase.

    What to pull before you open the workbook

    The survey asks for cost and operational information for a defined reporting period. Before you sit down with it, have these ready, by program and by site:

    • Your general ledger for the period, with expenses categorized by program. If your books do not separate OMHC from PRP, you will need an allocation basis (staff time, square footage, or client count) and you will need to document it.
    • Payroll by position and program: salaries, benefits, and the share of each person's time that goes to each program. Supervisors, billing staff, and administrators who serve more than one program need an allocation.
    • Service volume for the period: units billed by procedure code, encounter counts, and enrolled clients by program. This is the denominator for everything.
    • Occupancy and overhead: rent or mortgage, utilities, insurance, technology, transportation, and the administrative costs that support every program.
    • Contracted services and subcontractors.
    • Your Medicaid provider numbers and every site address under each.

    If the general ledger and the billing system disagree on volume, reconcile them before you submit. Myers and Stauffer reviews each submission and will contact providers to clarify or request additional information. A submission that cannot be reconciled is the one that gets the follow-up call.

    What to do this week

    1. Confirm receipt if you never did. The July 22 letter asked every provider to email MDBHACostSurvey@mslc.com with the name and contact information of the person responsible, plus the provider name and Medicaid provider number. If that never went out, send it now so the follow-up questions reach the right person.
    2. Download the current versions of the survey, the instructions, and the FAQ from the Myers and Stauffer page. The FAQ was updated August 24.
    3. Watch one training recording if nobody on your team attended in July. They cover the workbook tab by tab.
    4. Attend the September 9 office hour with your specific questions written down. Cost allocation across programs and how to report a site that opened mid-period are the two questions most practices actually have.
    5. Assign one owner and one reviewer. The owner fills it in; the reviewer checks that volume ties to billing and that payroll ties to the general ledger.
    6. Submit before the last week of September. If Myers and Stauffer needs a clarification, you want that to happen before the 30th, not after.

    Confidentiality

    Submissions go to Myers and Stauffer, not to MDH. MDH and the Maryland Health Care Commission receive only aggregated, de-identified information, and the FAQ says the same about the public. The firm cites HIPAA administrative simplification safeguards and the Maryland Department of Information Technology security policy. The FAQ also answers the question many small programs asked directly: participating does not expose you to additional regulatory review if your costs or staffing model differ from larger providers, because your data is aggregated before the state sees it.

    Why this is worth the time

    Maryland's community behavioral health rates have not been built from provider cost data in a structured way before. This study is the state's stated path to a "transparent, cost-based reimbursement methodology," and it is the workgroup's evidence base going into the 2027 session. A program that files a complete, reconciled survey has done the one thing it can do to make the next rate conversation reflect what it actually costs to run the service.

    Primary sources

    Questions about the survey: MDBHACostSurvey@mslc.com. Questions about the workgroup: andre.chappel@maryland.gov.