CFC, CPAS, CO, or ICS: What Determines Placement?

Family Caregivers, Home Care Recipients

If you’re researching Maryland Medicaid home care, you may be seeing multiple program names:

  • Community First Choice (CFC)
  • Community Personal Assistance Services (CPAS)
  • Community Options Waiver (CO)
  • Increased Community Services (ICS)

It’s not always clear how these programs differ — or why one person is approved under CFC while another is placed in CO or ICS.

In Maryland, program placement is determined by eligibility criteria, level of care, and state review — not personal preference. Understanding what drives that decision can help you prepare for the assessment process and set realistic expectations.

1. Nursing Facility Level of Care (NFLOC)

The most important factor is whether the person receiving care meets Nursing Facility Level of Care.

If they meet NFLOC, they may qualify for:

  • Community First Choice (CFC)
  • Community Options Waiver (CO)
  • Increased Community Services (ICS)

If they do not meet NFLOC but still need assistance with daily living, CPAS may be the appropriate program [1][2].

2. Medicaid Coverage Group

The person receiving care must have full Maryland Medicaid.

Waiver programs such as CO and ICS may include additional financial eligibility rules beyond standard Medicaid coverage [3][4].

3. Type and Intensity of Services Needed

The state reviews:

  • Number of hours required
  • Type of assistance needed
  • Risk of institutionalization
  • Complexity of medical needs

Individuals with more extensive or complex needs may be routed toward waiver programs like CO or ICS.

4. Program Capacity

CFC and CPAS are entitlement programs and do not have enrollment caps.

CO and ICS are waiver programs and have limited slots. Availability may influence placement timing.

Quick Comparison of Maryland Medicaid Home Care Programs

Below is a simplified overview of how these programs differ:

ProgramLevel of Care RequiredWaitlist Possible?Program Type
CFCNursing Facility Level of CareNoEntitlement
CPASAt least 1 ADL (no NFLOC)NoEntitlement
CONursing Facility Level of CareYesWaiver
ICSNursing Facility Level of CareYesWaiver

This table is a high-level summary. Final placement depends on assessment results and state approval.

5. Assessment and Plan of Service

Final placement is based on:

  • The functional assessment
  • The developed Plan of Service
  • Review by the Maryland Department of Health

Families do not select the program. Eligibility and state criteria determine the pathway.

Why This Matters for Individuals Who Need Care and Family Caregivers

The program determines:

  • Whether there is a waitlist
  • Authorized hours
  • Available services
  • Administrative requirements

In our experience, most families pursuing paid caregiving are ultimately placed in either CFC or CO.

Understanding likely placement early can reduce confusion and delays.

If you are unsure which program may apply, our team can help you review the factors before and during the assessment process. Call Concierge Home Care of Maryland or request a callback for personalized guidance.

References and Resources

[1] Maryland Community First Choice (CFC): Program eligibility and level of care criteria.

[2] Maryland Community Personal Assistance Services (CPAS): Eligibility and service guidelines.

[3] Maryland Community Options Waiver (CO): Waiver eligibility and enrollment structure.

[4] Maryland Increased Community Services (ICS): Program overview, eligibility, and waiver enrollment limitations.

Family Caregivers, Home Care Recipients

CFC, CPAS, CO, or ICS: What Determines Placement?

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