Community Personal Assistance Services (CPAS) Program from Maryland Medicaid / Medical Assistance

Last updated: February 29, 2024


Overview of the Community Personal Assistance Services Program

Maryland’s Community Personal Assistance Services (CPAS) Program provides personal care services for persons who are elderly or disabled and require assistance with day-to-day activities. Intended to enable persons to continue to live at home, program participants receive assistance with Activities of Daily Living (ADLs) and Instrumental Activities of Daily Living. These activities include bathing, personal hygiene, dressing, mobility, meal preparation, eating, and light housecleaning.

Personal assistance services offered under this program may be provided by licensed agency workers or program participants have the option to self-direct their own care. Self-directed services allows the hiring of a relative or friend to provide care. This includes an adult child or spouse, given that person is at least 18 years old and not the program participant’s guardian or acting as the program representative (making program decisions on the program participant’s behalf). Furthermore, the “caregiver” must become employed by a Medicaid Personal Assistance Agency. A fiscal intermediary handles the financial aspects of employment responsibilities, such as tax withholding and caregiver payments.

Program participants must reside in their own home, the home of a friend or relative, or an adult foster care home. Services cannot be provided to persons living in assisted living residences.

CPAS services are an entitlement; meeting the state’s Medicaid eligibility requirements guarantees one will receive benefits. Put differently, there is never a waiting list for benefits.

The Community Personal Assistance Services (CPAS) Program is a Medicaid State Plan program. Self-directed personal assistance services, available via CPAS, is a 1915(j) state plan option. CPAS was previously called the Medical Assistance Personal Care (MAPC) Program. Medicaid Maryland is called Medical Assistance, and Medicaid for the elderly is called Medical Assistance for the Aged, Blind, and Disabled.

 HCBS Medicaid Waivers versus HCBS State Plan Medicaid?
While home and community based services (HCBS) can be provided via a Medicaid Waiver or a state’s Regular Medicaid Plan, HCBS through Medicaid State Plans are an entitlement. Put differently, meeting the program’s eligibility requirements guarantees an applicant will receive benefits. On the other hand, HCBS via Medicaid Waivers are not an entitlement. Waivers have a limited number of participant enrollment slots, and once they have been filled, a waitlist for benefits begins. Furthermore, HCBS Medicaid Waivers require a program participant require the level of care provided in a nursing home, while State Plan HCBS do not always require this level of care.


Benefits of the Community Personal Assistance Services Program

Via the CPAS Program, the following benefits are available.

– Personal Assistance Services – assistance with bathing, grooming, personal hygiene, toileting, mobility, transferring (i.e., bed to a chair), preparing meals, shopping for essential items, basic housecleaning, etc.
– Nurse Monitoring – oversees the provider of personal care services
– Supports Planning – provides assistance with self-direction, as well as accessing services (including those that are non-Medicaid)

Persons eligible for CPAS may also be eligible for other Medicaid services, such as physician visits, hospitalization, home health care, laboratory services, durable medical equipment, and disposable medical supplies.

The costs associated with room and board for the beneficiary is not covered by this Medicaid program.


Eligibility Requirements for the MD Medicaid CPAS Program

The CPAS Program is for Maryland residents of all ages who are eligible for Maryland’s State Medicaid Plan / Medical Assistance, or specific to seniors, the Medical Assistance for the Aged, Blind, and Disabled program. The criteria below is relevant for the elderly (65+ years of age).

 The American Council on Aging provides a Maryland Medicaid Eligibility Test for seniors. 
Financial Criteria: Income, Assets & Home Ownership

In 2024, the individual applicant income limit is $350 / month. Married couples, regardless of if one or both spouses are applicants, can have a monthly income up to $392. Maryland state residents eligible for SSI (Supplemental Security Income) automatically qualify for Medicaid / Medical Assistance.

 While many home and community based services Medicaid programs allow a non-applicant spouse to retain a larger portion of a couple’s income and assets, the Community Personal Assistance Services Program does not. In contrast, Maryland’s Community Options Waiver does allow a non-applicant spouse a Monthly Maintenance Needs Allowance from his/her applicant spouse and a Community Spouse Resource Allowance.

In 2024, the asset limit is $2,500 for a single applicant. For married couples, the asset limit is slightly higher at $3,000. This hold true whether one or both spouses are applicants.

Some assets are not counted towards Medicaid’s asset limit. These generally include an applicant’s primary home, household furnishings and appliances, personal effects, and a vehicle.

While there is a 60-month Look-Back Rule in which Medicaid checks past asset transfers of those applying for Nursing Home Medicaid or home and community based services via a Medicaid Waiver, it is not relevant for the Community Personal Assistance Services Program.

 Use our Spend Down Calculator to determine if you might have assets over MD Medicaid’s countable limit.

Home Ownership
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take it. For Maryland’s Community Personal Assistance Services Program, the home is exempt (non-countable) as long as the applicant lives in it. However, if they live outside of their home, they must have Intent to Return in order for it to remain exempt. It is important to note that other MD Medicaid programs, such as the Community Options Waiver and Nursing Home Medicaid, have additional requirements for home exemption. Learn more.


Medical Criteria: Functional Need

While many Medicaid long-term care programs require an applicant to have a Nursing Facility Level of Care (NFLOC) need, the Community Personal Assistance Services Program does not. For CPAS, an applicant must need only require assistance with one Activity of Daily Living (ADL). ADLs are essential for day-to-day functioning, and include mobility, eating, toileting, bathing, and dressing / grooming. While a diagnosis of Alzheimer’s disease or a related dementia does not mean one will automatically meet the level of care need, it is common for persons with dementia to require assistance with ADLs.

 Maryland seniors who require personal care assistance, but require a Nursing Facility Level of Care might want to consider the Community First Choice Program. Additional home and community based services are available via CFC, and like CPAS, there is no waiting list for program benefits.


Qualifying When Over the Limits

Having income and / or assets over Medicaid’s limit(s) does not mean an applicant cannot still qualify for Medicaid. There are a variety of planning strategies that can be used to help persons who would otherwise be ineligible to become eligible. Some of these strategies are fairly easy to implement, and others, exceedingly complex. Below are the most common.

Maryland has a Medically Needy Spend-Down Program for applicants who have high medical expenses relative to their income. Via this program, applicants are permitted to spend “excess” income on medical expenses and health care premiums, such as Medicare Part B, in order to meet Medicaid’s income limit.

When persons have assets over the limits, one option is to “spend down” excess assets. Examples include paying off debt, making home improvements, such as updating heating and plumbing, and purchasing pre-paid funeral and burial expense trusts called Irrevocable Funeral Trusts. A Medicaid-Compliant Annuity, which takes a lump sum of assets and converts them into an income stream, also can lower countable assets. There are many other options when the applicant has assets exceeding the limit.

Inadequate planning or improperly implementing a Medicaid planning strategy can result in a denial or delay of MD Medicaid benefits. Professional Medicaid Planners are educated in the planning strategies available in Maryland to meet Medicaid’s financial eligibility criteria without jeopardizing Medicaid eligibility. Furthermore, while Medicaid’s 60-month Look-Back Rule does not apply to the Community Personal Assistance Services Program, it does apply to Nursing Home Medicaid and other long-term care Medicaid programs (i.e., Maryland’s Community Options Waiver). As more extensive Medicaid-funded care might be required in the future, it is vital that one not violate the look back rule. Medicaid planning strategies should ideally only be implemented with careful planning and well in advance of the need for long-term care. However, there are some workarounds, and Medicaid Planners are aware of them. For these reasons, it is highly suggested one consult a Medicaid Planner for assistance in qualifying for Medicaid / Medical Assistance when over the income and / or asset limit(s). Find a Medicaid Planner.


How to Apply for the MD Medicaid CPAS Program

Before You Apply

Prior to submitting an application for CPAS, applicants need to ensure they meet the Maryland Medicaid eligibility criteria. Applying when over the income and / or asset limit(s) will be cause for denial of benefits. The American Council on Aging offers a free Medicaid Eligibility Test to determine if one might meet Medicaid’s eligibility criteria. Take the Medicaid Eligibility Test.

As part of the application process, applicants will need to gather documentation for submission. Examples include copies of Social Security and Medicare cards, previous bank statements, proof of income, copies of life insurance policies, property deeds, and pre-need burial contracts. Unfortunately, a common reason applications are held up is required documentation is missing or not submitted in a timely manner.


Application Process

To apply for CPAS, persons should contact the Office of Long Term Services and Supports at 410-767-1739 or Maryland Access Point (MAP) at 844-627-5465. Persons can also contact their local MAP office. A functional needs assessment competed by the local health department will be completed as part of the application process.

Persons can learn more about the Community Personal Assistance Services Program here and here.  The Maryland Department of Health’s (MDH) Office of Long Term Services and Supports administers the CPAS Program.


Approval Process & Timing

The Maryland Medicaid (Medical Assistance) application process can take up to 3 months, or even longer, from the beginning of the application process through the receipt of the determination letter indicating approval or denial. Generally, it takes one several weeks to complete the application and gather all of the supportive documentation. If the application is not properly completed, or required documentation is missing, the application process will be delayed. Based on federal law, Medicaid offices have up to 45 days to review and approve or deny one’s application (up to 90 days for disability applications). Despite the law, applications are sometimes delayed even further.

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