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MDH outlines AOT and CCBHC planning steps; DLS questions costs and statewide readiness
Summary
The department described plans to implement Assisted Outpatient Treatment for jurisdictions that did not opt in and to consider Certified Community Behavioral Health Clinic grants; DLS asked for cost and timeline clarifications and MDH said it will proceed with planning and stakeholder engagement.
Maryland Department of Health officials described preliminary plans to implement Assisted Outpatient Treatment (AOT) in jurisdictions that did not elect to run local programs and summarized the state’s interaction with federal CCBHC planning funding.
Naomi Kimura’s DLS analysis set out the statutory requirement that local jurisdictions either implement AOT or allow MDH to operate AOT in their jurisdiction; DLS included the BHA work plan and listed $3,000,000 appropriated in both fiscal 2025 and fiscal 2026 to develop the program. DLS noted that MDH released an RFP for local spending plans with a January 30, 2025 deadline and reported no jurisdictions submitted plans by that deadline. DLS asked MDH to estimate what percentage of AOT services would be billable to Medicaid and to describe an implementation plan if jurisdictions did not opt in.
Deputy Secretary Alyssa Lord and other MDH staff told the subcommittee the department is planning a statewide MDH‑run AOT program implemented regionally and has hired an AOT director, drafted implementation strategies and examined other states’ approaches. MDH said it cannot at this time produce a firm percentage of AOT services billable to Medicaid because service volumes will vary, but it referred the committee to written responses showing which services are expected to be billable. MDH also said the department plans to draft regulations, a staffing plan and program materials and to increase stakeholder engagement.
On Certified Community Behavioral Health Clinics (CCBHCs), MDH confirmed it received a SAMHSA planning and demonstration award of about $900,000 for FY25 but has not yet accepted or declined the award. MDH cautioned that CCBHC participation carries significant budgetary obligations if the State were to implement benefits statewide; MDH estimated a one‑time implementation cost of about $227,000,000 and referenced other states with different cost experiences.
DLS recommended deleting the 1% provider rate increase and reducing certain general fund appropriations it judged could be billable to Medicaid; MDH acknowledged DLS’ fiscal concerns but urged additional time to evaluate CCBHC costs and noted that CCBHCs already operating in Maryland have increased access.
The subcommittee asked for follow‑up materials on potential fund reallocation options to support statewide AOT implementation and clarification on the planned reversions DLS cited.
