Overview of Maryland’s Increased Community Services Program
Maryland’s Increased Community Services Program, or ICS, assists nursing home residents 18+ years old in transitioning back home or into their communities (i.e., assisted living residence). In addition to transitional services, such as payment of one-time security deposits and utility set-up fees, a variety of home and community based services (HCBS) are available to assist one in living independently. These long-term services and supports include home delivered meals, medical day care, personal care assistance, homemaker services, and personal emergency response systems.
While services offered under the ICS Program may be provided by licensed care workers employed by a provider agency, program participants have the option to self-direct their own attendant care (personal care) services. This allows program participants to hire, manage, and even fire their own “participant-employed attendant” (caregiver), given the individual is enrolled as a Medicaid provider. Relatives can be hired to provide care, but a spouse or parent of a dependent child is prohibited from this role. A financial management services agency handles the financial aspects of employment responsibilities, such as background checks, tax withholding, and caregiver payments.
Services can be received in one’s home, the home of a loved one, or an assisted living residence.
ICS is not an entitlement program; meeting eligibility requirements does not equate to immediate receipt of program benefits. The number of participant slots is limited, and when these slots are full, a waitlist for program participation forms.
Maryland’s Increased Community Services Program is part of HealthChoice, the state’s Section 1115 Demonstration Medicaid Waiver, through which statewide managed care is authorized. Medicaid in Maryland is called Medical Assistance (MA).
Benefits of the Increased Community Services Program
Follows is a list of home and community based services available via the ICS Program. An individualized service plan determines the exact services and supports a program participant receives.
– Adult Medical Day Care – daytime supervision and care, including nursing services, in a community group setting
– Assisted Living Services* – i.e., personal care assistance, homemaker services, and medication management in an assisted living facility
– Assistive Technology
– Attendant Care Services / Personal Assistance Services – assistance with daily living activities
– Behavioral Consultation Services – to assist a program participant’s caregiver in understanding and managing behavioral issues.
– Case Management
– Day Habilitation / Senior Center Plus – a structured program, usually in a senior center, that provides care and supervision, socialization, and activities. Unlike with Adult Day Health Care, medical services are not provided.
– Environmental Assessments
– Family Training Services – training for unpaid family caregivers, such as addressing individualized needs
– Home Delivered Meals
– Home Modifications – for accessibility
– Nursing Monitoring
– Nutritionist / Dietician Services
– Participant Training – learning skills to plan meals, manage money, and self-direct one’s caregiver (i.e., how to choose, train, manage, and fire the caregiver)
– Personal Emergency Response Systems
– Supports Planning
– Transition Services – payment of onetime expenses (i.e., security deposit, utility fees / deposits, essential home furnishings) to assist one in moving from a nursing home back into the community
* While services may be provided in an assisted living residence, the cost of room and board is not covered by the Increased Community Services Program.
ICS participants can also receive other Medicaid services, such as physician visits, hospitalization, home health care, laboratory services, durable medical equipment, disposable medical supplies, pharmacy, and coverage of Medicare premiums, deductibles, and co-payments.
Eligibility Requirements for Increased Community Services Program
The ICS Program is for Maryland residents who are 18+ years old and have been residing in a nursing home for a minimum of three months. They must be eligible for Medical Assistance / Medicaid nursing home coverage for a minimum of 30 of those days. They cannot be eligible for a home and community based services Medicaid Waiver, such as the Maryland Home and Community Based Options Waiver (HCBOW), also called the Community Options Waiver. Furthermore, the cost of one’s care services outside of the nursing home cannot exceed the cost of their nursing home care. Additional Medicaid eligibility criteria follows:
Financial Criteria: Income, Assets & Home Ownership
Income
ICS is unique in that one must have income over 300% of the Federal Benefit Rate (FBR). This figure increases annually in January, and in 2024, this means an applicant must have income over $2,829 / month. An applicant can keep $2,829 / month in income, but income over this amount must go towards one’s care costs.
When both spouses are applicants, each spouse is considered individually, and therefore, each spouse must have income greater than $2,829 / month. Income over this amount must be paid towards care costs. When only one spouse is an applicant, the income of the non-applicant spouse is not counted towards the income eligibility of their spouse. Furthermore, monthly income from the applicant spouse can be transferred to the non-applicant spouse as a Spousal Income Allowance, also called a Monthly Maintenance Needs Allowance.
There is a minimum income allowance, set at $2,555 / month (eff. 7/1/24 – 6/30/25). This allows an applicant spouse to supplement their non-applicant spouse’s monthly income, bringing their income up to this amount. There is also a maximum income allowance, which in 2024, is $3,853.50 / month. While this potentially allows a non-applicant spouse a higher income allowance, any additional amount above the minimum income allowance is dependent on one’s shelter and utility costs. A Spousal Income Allowance, however, can never push a non-applicant’s total monthly income over $3,853.50.
Assets
In 2024, the asset limit is $2,000 for a single applicant. For married couples, with both spouses as applicants, the asset limit is $3,000. When only one spouse is an applicant, the assets of both the applicant and non-applicant spouse are limited. This is because Medicaid considers the assets of a married couple to be jointly owned. In this case, the applicant spouse can retain up to $2,000 in assets and the non-applicant spouse is allocated a larger portion of the couple’s assets as a Community Spouse Resource Allowance.
The CSRA allows the non-applicant spouse to keep 50% of the couple’s assets, up to $154,140. If the non-applicant’s share of assets falls under $30,828, they can keep 100% of the assets, up to $30,828.
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.
Assets should not be given away or sold under fair market value within 60-months of long-term care Medicaid application. This is because Medicaid has a Look-Back Rule and violating it results in a Penalty Period of Medicaid ineligibility.
Home Ownership
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take it. For eligibility purposes, Medicaid in MD considers the home exempt (non-countable) in the following circumstances.
– The applicant lives in the home or has Intent to Return, and in 2024, their home equity interest is no greater than $713,000. Home equity is the current value of the home minus any outstanding mortgage. Equity interest is the portion of the home’s equity value that is owned by the applicant.
– The applicant has a spouse who lives in the home.
– The applicant has a minor child who lives in the home.
– The applicant has a disabled relative who lives in the home.
Learn more about the potential of Medicaid taking the home.
Medical Criteria: Functional Need
An applicant must require a Nursing Facility Level of Care (NFLOC). For the Increased Community Services Program, the assessment tool used to make this level of care determination is the interRAI Home Care (HC). This assessment contains twelve categories relative to daily living. Points are assigned based on the amount and level of assistance required. The higher the score, the greater the level of care need. Several categories are Activities of Daily Living (ADLs), which are essential for day-to-day functioning, and include mobility, eating, toileting, bathing, and dressing / grooming. Relevant to many persons with Alzheimer’s disease or a related dementia, cognition, such as decision making ability, memory, and comprehension, are also considered. A diagnosis of dementia, in and of itself, does not mean one will meet a NFLOC.
Qualifying When Over the Limits
Having income and / or assets over Medicaid’s limit(s) does not mean an applicant cannot still qualify for MD 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.
The Increased Community Services Program is unique in that there is not an income limit per se, only that one’s care services outside of a nursing home cost less than would Medicaid-funded nursing home care. Therefore, income planning strategies are not relevant for the ICS Program.
When persons have assets over the limits, trusts are an option. Irrevocable Funeral Trusts are pre-paid funeral and burial expense trusts that Medicaid does not count as assets. Medicaid Asset Protection Trusts, which protect assets from being counted, can also be utilized, but must be created well in advance of the need for long-term care. For married couples with a significant amount of “excess” assets, Medicaid Divorce is an option. There are many other strategies available 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 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, there are additional planning techniques that not only help one meet Medicaid’s financial criteria, but can also protect assets from Medicaid’s Estate Recovery Program. These strategies often violate Medicaid’s 60-month Look-Back Rule, and therefore, should only be implemented with careful planning. 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 when over the income and / or asset limit(s).
How to Apply for Maryland’s Increased Community Services Program
Before You Apply
Maryland’s Increased Community Services Program is for persons who have too much income to qualify for a HCBS Medicaid Waiver. The American Council on Aging offers a Medicaid Eligibility Test to determine if one might meet Medicaid’s eligibility criteria.
As part of the application process, applicants will need to gather documentation for submission. Examples include copies of Social Security and Medicare cards, bank statements up to 60-months prior to application, proof of income, and 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.
The Increased Community Supports Program is approved for a maximum of 100 beneficiaries. If all of the participant sots are taken, persons will be put on a wait list and receive assistance in the order in which they applied.
Application Process
To apply for the Increased Community Services Program one should call Maryland Access Point (MAP) at 1-844-627-5465. Persons can also call MAP for program related questions and information. A functional assessment will be completed as part of the application process.
Learn more about the ICS Program.
The Maryland Department of Health’s (MDH) Office of Long Term Services and Support administers the Increased Community Services Program.
Approval Process & Timing
The Maryland Medicaid 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. Furthermore, if a waitlist exists, persons might spend many months waiting to receive benefits from the Increased Community Services Program.