Mid-Atlantic Health Law TOPICS

1. In January 2024, the Maryland Department of Health and Health Services Cost 
Review Commission initiated advisory committee meetings to discuss the State’s application to the Center for Medicare and Medicaid Innovation’s Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model. AHEAD is a new model available to a small cohort of states that will include elements similar to Maryland’s Total Cost of Care Model and the Maryland Primary Care Program. The AHEAD Model is scheduled to begin in January 2026, and will pick up just as Maryland’s current waiver programs end at the end of 2025.

2. The Maryland Health Care Commission on February 22, 2024, adopted the regulations proposed in October 2023 which amended the Certificate of Need regulations. No comments were submitted during the thirty day comment period.

3. Maryland Medicaid expanded coverage for gender-affirming care, effective January 1, 2024. New covered services include hormone therapy and lab testing, voice surgery, therapy and lessons, hair removal and transplants, gender affirming surgery and other related services. This expansion follows the enactment of the Trans Health Equity Act in Maryland.

4. In January 2024, the Maryland Department of Labor circulated draft regulations to implement the Family and Medical Leave Insurance Program (also known as the Maryland Time to Care Act). These regulations are not officially proposed but are instead being used to solicit comments and feedback to the Department. The Maryland General Assembly is also considering further amendments to the Act. Employers will be required to contribute to the state fund beginning in Fall 2024, unless the employer secures alternative coverage for the required benefits. The benefits are scheduled to become available to covered employees in 2026. 

Darci M. Smith
410-576-4153 • dsmith@gfrlaw.com