Foxx Chubby Health Policy Consulting

We partner to do work we believe in for people we care about. So thankful for the opportunity to participate with . Looking forward to many more chances to help improve the state of our behavioral health system.

If you need help integrating quality and compliance into your practice... [email protected]. We'd love to partner with you.

The Entrepreneurial Journey Vol 5-Mental Health Policy Starting & Growing a Community-Based Behavioral Health Business in MarylandThis webinar is designed to help current and aspiring community-based behavioral h...

Late this afternoon, I got a panicked text from a client.
She’s a seasoned clinician, owns a community-based mental health organization, and recently took on the challenge of becoming a surveyor.

Her text read:
“I’m about to leave a survey. We have to talk. We need to meet for a full day every month to go through everything.”

When she called, she explained what she had just experienced on her first survey: the organization she visited hadn’t updated documentation, reviewed policies, or completed basic administrative tasks in the entire three years since they were accredited.

I reminded her: “That’s why we built your compliance system the way we did. The task list tracks progress on every standard, cycles through annual policy reviews, and documents strategy along the way. And remember—we redesigned your communications process so the work is lighter and more sustainable.”

Later, after reflecting, she told me: “Thank you. Now I get it. I am so thankful you stayed on us.”

This is why we do the work. At Foxx Chubby HPC, we design systems that prevent panic. When compliance and quality are woven into daily operations, they stop being overwhelming tasks and start being part of the culture. That’s when you know it’s working.

If your compliance feels more like panic than process, let’s talk. www.foxxchubbyhpc.com or [email protected]

Home | Foxx Chubby Partnering with Owners to Deliver Quality Community-based Mental Health Services In Maryland Foxx Chubby Health Policy Consulting assists owners of community-based mental health organizations in creating evidence based and compliant clinical and business practices. Our website offers additional support for owners by providing and highlighting resources and forums.

🚨 Maryland BHA Releases Proposed COMAR 10.63 Rule Update 🚨
🗓️ Public Comment Deadline: June 16, 2025

The Maryland Behavioral Health Administration (BHA) has released proposed updates to COMAR 10.63, and there are a few important highlights providers should know:

🔑 A key callout: This proposed action does not include changes to COMAR Sections 10.63.03, .04, or .05, which cover service descriptions, criteria, and delivery requirements for both accreditation- and non-accreditation-based licensed services. Based on yesterday's press release, there could be more changes coming.

🔧 Many of the proposed updates aim to clarify and codify existing requirements or operational expectations that providers have been expected to follow—but which had not been fully outlined in previous regulations.

📌 The overall focus appears to be on alignment, reinforcement, and transparency, rather than introducing entirely new standards.
Here’s what’s changing (and why it matters 👇):

🔍 COMAR 10.63.01 – General Compliance & Reporting
✅ Mandatory Corporate Compliance Plans & Officers
✅ Alignment with federal and accreditation standards
✅ Codified Critical Incident Reporting
✅ Site standards, recordkeeping, and telehealth delivery expectations
✅ Audio-only telehealth excluded unless otherwise permitted
✅ Requirements for planned and unplanned service discontinuation

👥 COMAR 10.63.02 – Staffing
✅ Role-based onboarding and annual training
✅ Ongoing background checks + exclusion list monitoring
✅ Definitions of Organizational vs. Program-Level staff
✅ Defined roles: Clinical Director, Program Director, Rehabilitation Specialist, Peer Support

📋 COMAR 10.63.06 – Licensure Process
✅ Codifies existing licensing and renewal processes
✅ Emphasis on documentation, disclosure, and program integrity

⚖️ COMAR 10.63.09 – Corrective Actions & Sanctions
✅ Framework for deficiency notices, corrective plans, and sanctions
✅ Public notification requirements for sanctioned providers
✅ Reinforces transparency and accountability

🗣️ We’re hosting a safe-space community discussion on May 28 to review the proposed rule and prepare public comments. Join us on Zoom at 12:30 PM.
🔗 https://lnkd.in/erzv3_GW

This is not a BHA event—this is a community provider space to share insights, ask questions, and prepare real feedback.

Source of truth information:
Press release: https://lnkd.in/eDhpm6RG
Proposed Rule: https://lnkd.in/eXzsTEbM

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