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Do I need accreditation to get licensed?

Sometimes—but not always. Here’s the simple rule: licensing / accreditation are different tools, and whether you need accreditation depends on what services you plan to provide and which program rules apply to your agency type. Many first-time founders get stuck because they assume one of these is true: “Accreditation replaces licensing.” “I need accreditation for every license.” “If I get accredited, I’m automatically approved.” None of those assumptions hold up in real licensing review. Why people get confused Licensing feels like forms. Accreditation also feels like forms. So people assume they’re the same. But reviewers are not approving paperwork. They’re approving whether your agency is set up correctly for the pathway you selected:

"Service scope (what you will and will not provide)”

Staffing qualifications Supervision structure Required documentation that matches your service scope Accreditation may be required in some pathways. In others, it’s optional—or not relevant at all. When accreditation IS required (common example: Behavioral Health) In behavioral health, Maryland’s rules are clear: some community-based behavioral health programs must be accredited in order to be licensed. So in this space, the question is usually not “Do I need accreditation?” but: “Is my behavioral health program type one of the ones that requires accreditation-based licensing?” If you apply for a behavioral health license that requires accreditation and you are not set up for that pathway, your application submission can be returned or delayed—because the requirement is part of the licensing route, not an optional add-on. Plain example: You set up a behavioral health program as if it’s a simple license application, but the program category requires accreditation. Now you’re rebuilding your timeline, your required documentation, and often your staffing plan to match the correct pathway. When accreditation is usually NOT required (common example: many DDA setups) For DDA providers in Maryland, the base expectation is that providers meet DDA licensing requirements under COMAR 10.22.02.

However, Maryland’s DDA licensing rules also include a key point that founders miss: the Director may waive the DDA license requirement if a person is licensed or certified by another State agency OR accredited by certain national accreditation agencies (examples listed include CQL and CARF). This does not mean “accreditation is required to be licensed.” It means: in some cases, accreditation may be used as a basis for a waiver decision. Plain example: A founder assumes, “DDA always requires accreditation.” That can lead to unnecessary expense and months of delay. The real question is: Do you need DDA licensing, or do you qualify for a waiver based on another credential? Either way, reviewers still expect your setup to be coherent: service scope, staffing qualifications, supervision structure, and required documentation must match what you are applying to provide. Autism Waiver: it’s usually about being properly licensed/certified, not “accredited by default” For Autism Waiver agencies, the language you’ll see is typically that providers must be approved as Medicaid providers and be appropriately licensed or certified for the services they deliver. In practice, this means Autism Waiver readiness is often driven by:

whether you hold the right license or certification for your service scope, and whether your staffing qualifications and supervision structure match the service model Some providers hear “Medicaid” and assume “accreditation must be required.” Not automatically. Medicaid enrollment is strongly tied to provider screening and verification of licensure where applicable—but that is not the same thing as a universal accreditation requirement. Plain example: A founder spends months chasing accreditation before they’ve even stabilized their service scope and staffing model for the Autism Waiver services they want to provide. The application doesn’t move faster. It gets more complicated. A fast way to decide what applies to you Ask these three questions before you build your timeline: 1) What is my service scope—support, developmental disability services, or clinical treatment? This is the biggest driver of whether accreditation shows up as a licensing requirement. 2) Which licensing pathway does my service scope fall under? Behavioral health has program categories where accreditation is built into licensing. DDA has licensing rules and also waiver language in specific cases. Autism Waiver commonly points you toward licensure/certification and Medicaid provider approval. 3) If accreditation is involved, is it required for my specific program type—or am I doing it because someone told me to? If you can’t answer this clearly, you’re at high risk for a returned or delayed application.

Where HPI comes in (pre-application) This is exactly where agencies lose months—because they start building around assumptions. HPI supports setup decisions before application submission by helping you: confirm whether your pathway is licensing only or accreditation-based licensing tighten your service scope so it matches the pathway align staffing qualifications and supervision structure to your service model align required documentation to what you are actually applying to provide That’s how you avoid building the wrong timeline and paying for the wrong path. Bottom line Do you need accreditation to get licensed? Behavioral Health: sometimes yes, depending on program type—accreditation can be required to receive the license. DDA: licensing requirements apply, but there are waiver provisions where accreditation (or other state licensure/certification) may be considered. Autism Waiver: usually framed as appropriate licensure/certification plus Medicaid provider approval—accreditation is not a universal default. The safest move is to treat this as a setup decision, not a paperwork question.

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References

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