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What MDH Just Said: Medicaid Wants to Start Paying for Food — and It's Asking Operators What to Build
The Maryland Department of Health plans to let Medicaid managed care plans cover medically tailored meals and other nutrition services starting in 2028 — and it's collecting input from providers and community organizations through October 14.
By Aaron Payne · August 21, 2026
The Maryland Department of Health (MDH) is designing a way for Medicaid to pay for food — medically tailored meals first, with other nutrition services on the table — starting in calendar year 2028. Before it writes the rules, it’s asking providers, community organizations, and enrollees what the program should look like. Feedback is due by 5:00 PM on Wednesday, October 14, 2026.
Who this applies to
Anyone who serves Maryland Medicaid enrollees and deals with food and nutrition as part of care — assisted living facilities (ALFs), residential service agencies (RSAs, the license home care agencies operate under), adult medical day care, and the community organizations that handle meal delivery and nutrition programs. If you’ve ever discharged a client to a home with an empty refrigerator, or watched a resident’s health turn on their diet, this is the state asking you to describe that problem on the record.
One scope note: this program runs through Medicaid managed care — the HealthChoice managed care organizations (MCOs, the private health plans that administer most Maryland Medicaid benefits). It is not a change to the waiver programs or their fee-for-service billing. But the people involved overlap heavily with the clients and residents Maryland’s care operators already serve.
What’s actually happening
MDH plans to use a federal mechanism called In Lieu of Services and Settings (ILOS) — which lets Medicaid managed care plans cover approved alternatives to traditional medical services when they’re medically appropriate and cost-effective. Think of it as the state saying: if a $12 medically tailored meal prevents a $12,000 hospital readmission, Medicaid should be allowed to buy the meal.
In MDH’s own words from the Request for Information:
“MDH intends to include Medically Tailored Meals as one of the approved ILOS… In addition to Medically Tailored Meals, MDH is considering approving other evidence-based nutrition ILOS for Calendar Year 2028 and beyond.”
The department says it’s gathering input on “the types of services and interventions, eligible populations, procurement of services, enrollee needs, health care provider needs, community organization needs, and other priority needs.”
Two built-in limits worth knowing: under the federal rules, each MCO chooses whether to offer these services, and each enrollee chooses whether to accept them. Nobody is required to participate.
The dates that matter
- RFI feedback due: 5:00 PM, Wednesday, October 14, 2026
- Target launch: calendar year 2028 for the first approved services
What to do about it
- Read the background page at health.maryland.gov/AHEAD/Pages/ILOSRFI.aspx — it’s short, and it frames what MDH is weighing.
- Submit your perspective through the RFI form or by email to [email protected]. You don’t need policy language — operators’ concrete observations are exactly what an RFI is for. What nutrition gaps do you see at admission and discharge? What would it take for a provider your size to participate? Who’s falling through the cracks now?
- If meal service is part of your operation or your referral network, flag the procurement question specifically — MDH is asking how it should buy these services, and that answer decides who gets to be a vendor in 2028.
- Watch for the summary. MDH says submissions won’t be published individually, but it will issue a summary of the feedback it receives.
The fine print
An RFI is not a regulation — it’s the step before the design. Nothing changes for your license, your billing, or your service plans today. The original announcement came through the Maryland Department of Aging’s Q3 2026 newsletter (August 21, 2026), and the program details live on MDH’s AHEAD page linked above. As always, verify specifics with the agency before acting on them.
The Care Insider is not affiliated with or endorsed by the Office of Health Care Quality or the Maryland Department of Health. This is operator-to-operator plain-language explanation, not legal advice — always read the original guidance.