Maryland Denies ABA Claims Unless an Enrolled Individual Is the Referring NPI

Maryland Medicaid Transmittal PT 76-26, issued April 3, 2026 by the Office of Medical Benefits Management, set a claim edit that has been live since July 1, 2026. If you bill Maryland Medicaid for ABA and haven't looked at your denials since summer, start there.

What the edit checks

• The Referring Provider field (Field 17b) must carry the NPI of an individual referring practitioner. A group or facility NPI is denied.
• That practitioner must be actively enrolled as a Maryland Medicaid provider, with active status in the Provider Verification System, on the date of service.
• This applies to claims with dates of service on or after July 1. It does not turn on when you submit.

The turn: the provider owns the check

The transmittal says ABA providers are responsible for ensuring the referring practitioner meets these requirements “prior to rendering and billing.” A valid license and a signed referral aren't enough. The referrer also has to be enrolled in Maryland Medicaid, and the test is applied claim by claim against the date of service. A referrer whose enrollment lapses mid-year can deny claims you submit afterward.

The referrer must also be a qualified licensed professional under COMAR 10.09.28. The transmittal points to page 7 of the Maryland ABA Provider Manual for the list of who qualifies.

Where it comes from

The transmittal cites 42 CFR § 455.440, which requires state Medicaid agencies to require the NPI of the practitioner who ordered or referred on claims for ordered or referred services. That rule is federal. Maryland is the state that wrote it into an ABA transmittal with a hard date.

Dates

Providers could submit claims with the referring practitioner through the Behavioral Health Administrative Services Organization (BHASO) before July 1, and BHASO would monitor enrollment and contact practitioners who weren't enrolled. That window closed with the effective date.

What you must do

• Billing lead: pull Maryland denials with dates of service since July 1 and look for referring-provider reasons. Resubmit what can still be corrected inside your filing window.
• Intake: for every active Maryland client, record the referrer's individual NPI, not the practice's. Replace any group NPI.
• Monthly: check each referrer's enrollment status in the Provider Verification System before the monthly claim run, since the test is the date of service.
• Owners with clients in several states: check each state's ABA billing guide for a referring-provider edit. The federal rule gives every state the same basis for one.

Questions go to mdh.aba@maryland.gov, per the transmittal.