The short answer Maryland licenses non-Medicare home care companies as Residential Service Agencies (RSAs) under COMAR 10.07.05. Hands-on aide care involves delegated nursing tasks that generally must be performed by Maryland Board of Nursing-certified CNAs (100-hour training), making Maryland one of the strictest personal-care training states.
What Maryland requires
Maryland
RSA licensure. Any agency employing individuals to provide at least one home health care service for compensation must be licensed as a Residential Service Agency by the Maryland Department of Health under COMAR 10.07.05.
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CNA requirement for aides. Under COMAR 10.07.05.12, services involving nursing tasks routinely delegated by an RN (including personal care) may be performed for compensation only by an individual certified by the Board of Nursing (CNA, CMT, or certified medicine aide); an RN assesses whether a client can instead be served by a non-certified worker.
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CNA training = 100 hrs. Maryland CNA certification requires a Board of Nursing-approved program of at least 100 hours — 60 hours of theory/lab and 40 hours of supervised clinical practice (COMAR 10.39.02).
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Medicare HHAs. Medicare-certified home health agencies must also meet the federal 75-hour home health aide training/competency standard and 12 hours of annual in-service under 42 CFR 484.80.
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The federal baseline (applies in every state)
Federal
75-hour HHA training standard. Under 42 CFR 484.80(b), home health aides at Medicare-certified home health agencies must complete a training program of at least 75 hours, including at least 16 hours of classroom training completed before beginning at least 16 hours of supervised practical (hands-on) training.
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Competency evaluation / CNA pathway. 42 CFR 484.80(a) allows aides to qualify by completing the 75-hour training and competency evaluation program, by passing a competency evaluation alone, or by completing a state nurse aide training and competency evaluation program (CNA) and being in good standing on the state nurse aide registry.
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12-hour annual in-service. 42 CFR 484.80(d) requires home health aides to receive at least 12 hours of in-service training during each 12-month period, which may occur while the aide is furnishing care and must be supervised by a registered nurse.
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RN trainer requirements. Under 42 CFR 484.80(b)(3) and (c)(2), classroom and supervised practical training must be performed by or under the general supervision of a registered nurse with at least 2 years of nursing experience, at least 1 year of which must be in home health care; competency evaluations must likewise be performed by an RN in consultation with other professionals.
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