Maryland DDA Training Attestations: What COMAR Requires and How to Be Ready by January 5
Maryland DDA providers now attest to staff training each quarter. What COMAR 10.22.02.11 requires and how to be ready for the January 5 report.
compliance · DSP · IDD
Training & eTracking Solutions · · 6 min read
If you run a DDA-licensed or DDA-certified agency in Maryland, training records are now something you report every quarter. Since October 2025, the Developmental Disabilities Administration (DDA) has asked providers to sign a Quarterly Provider Training Attestation. The first-quarter report was due October 5. The next one, covering training completed in October, November and December, is due January 5.
That gives you about three months to make sure your training records can back up your signature. This guide covers what the rule requires, what you are signing, and a simple way to stay ready.
What you sign each quarter
The current DDA Quarterly Provider Training Attestation (revised March 17, 2026) asks providers to initial statements confirming that:
- All staff working for or contracted with the agency are trained under the DDA waiver, COMAR and DDA policy at the time they deliver services.
- Staff meet the standards and timelines in the waiver and the DDA Provider Training Matrix.
- You understand you cannot bill for services provided by staff who had not met the required training standards and timelines at the time of service.
- DDA or its designee may ask for a training roster or other proof of training at any time.
If you can't attest that everyone is trained, the form asks for the number and percentage of staff who meet the standards, the number who don't, and your plan to fix it this quarter.
Put simply, a gap in training is now a billing risk, not just something a surveyor might find later.
The rule behind it: COMAR 10.22.02.11
Maryland's staff training rule for DDA licensees is COMAR 10.22.02.11, Staffing Requirements. It sets two deadlines.
Before staff are assigned independent duties, the licensee must make sure, with appropriate documentation, that staff and care providers:
- receive adequate training for their assigned duties
- complete the Administration's approved training for the needs of the people they serve, such as training in seizure disorders, principles of behavior change, management of disruptive behaviors, medication administration, and the aging process and special needs of the elderly
- receive bloodborne pathogens training that follows OSHA's standard, 29 CFR 1910.1030
Within 3 months of hire, all staff and care providers must receive Administration-approved training in eight areas:
- Community integration and inclusion
- Individual-directed, outcome-oriented planning
- General characteristics and needs of individuals served
- First aid and CPR, based on American Red Cross or other nationally recognized guidelines
- Fundamental rights of individuals with developmental disabilities
- Communicable diseases
- Supporting individuals and families in making choices
- Communication skills
The same regulation also requires written job descriptions that spell out the training and experience each position needs.
The matrix adds timelines and renewals
The DDA Provider Training Matrix turns the regulation into a topic-by-topic list with an audience, a timeframe and an authority for each item. A few details catch agencies off guard:
- CPR and first aid: within 90 days of hire, then every 2 years.
- Communicable diseases and bloodborne pathogens: within 90 days of hire, then annually. For employees with occupational exposure, OSHA's standard also calls for bloodborne pathogens training at initial assignment and at least once a year after that.
- Medication administration: DSPs who give medications need it before they administer any. The matrix lists the Certified Medication Technician process under COMAR 10.39.04.06, with a refresher every 2 years.
- Mandt: listed for DSP staff within 90 days of hire, with annual refreshers and in-person requirements for certain chapters.
- Suggested topics: HIPAA, trauma-informed care, the Fatal Five and a few others are marked as suggested rather than required.
The matrix gives a 90-day window for some topics that COMAR places before independent duties. When the two seem to differ, plan for the earlier deadline, and check with DDA if you're unsure.
Matching each requirement to training
Here is how the COMAR topics line up with courses in the Training & eTracking Solutions (TES) catalog. Hands-on certifications stay hands-on. For those, you track the certificate rather than assign an online course.
| COMAR 10.22.02.11 topic | When | TES course or how to track it |
|---|---|---|
| Seizure disorders (C)(2)(a) | Before independent duties | Seizure Disorders |
| Principles of behavior change (C)(2)(b) | Before independent duties | Principles of Behavior Change for Direct Support Professionals (MD) |
| Aging and special needs of the elderly (C)(2)(e) | Before independent duties | Aging and the Special Needs of the Elderly for Direct Support Professionals (MD) |
| Bloodborne pathogens (C)(3) and communicable diseases (D)(6) | Before independent duties; within 3 months | Communicable Diseases: Identification, Treatment and Prevention (MD) |
| Community integration and inclusion (D)(1) | Within 3 months | Promoting Community Integration and Inclusion for Direct Support Professionals (MD) |
| Individual-directed, outcome-oriented planning (D)(2) | Within 3 months | Individual Planning for Direct Support Professionals (MD) |
| General characteristics and needs (D)(3) | Within 3 months | General Characteristics - An Introduction to Developmental Disabilities (MD) |
| Fundamental rights (D)(5) | Within 3 months | Fundamental Rights for Direct Support Professionals in Maryland (MD) |
| Supporting individuals and families in making choices (D)(7) | Within 3 months | Supporting Individuals and Families in Making Choices for Direct Support Professionals (MD) |
| Communication skills (D)(8) | Within 3 months | Communication Skills for Direct Support Professionals (MD) |
| First aid and CPR (D)(4) | Within 3 months; matrix renewal every 2 years | Hands-on certification. Upload and track the card. |
| Medication administration, management of disruptive behaviors (C)(2)(c)–(d) | Before the duty begins | Separately certified training (for example, CMT and your agency's behavior support training). Track the certificates in the same record. |
DDA's own Provider Training Matrix lists Training & eTracking Solutions among its resource links for several of these topics.
One place to see who is ready
Knowing the rule is one thing. Proving it every quarter for every staff member is harder, especially across sites and shifts.
The TES Maryland Community Pathways Waiver - Direct Support Professional (DSP) pathway is built from the audience column of the DDA Provider Training Matrix. For each DSP, it shows:
- which requirements are complete and which are still outstanding
- when each item is first due, such as within 90 days of hire
- which items renew, like the annual communicable diseases course and the 2-year CPR and first aid cycle, with renewal opening 30 days before the due date
- items you document rather than train online, like CPR and first aid and Mandt
The pathway also covers related matrix topics with courses such as Incident Management, Fatal Five and Health Insurance Portability and Accountability Act (HIPAA) (DSP).
A quarter-end checklist
Use this before you sign the next attestation:
- Pull a roster of everyone who delivered waiver services this quarter, including contractors.
- For each new hire, confirm the before-independent-duties training was done before their first solo shift.
- Check every hire from the last 90 days against the eight 3-month topics.
- Look for CPR and first aid cards and medication technician certificates that expire this quarter.
- Confirm annual communicable diseases and bloodborne pathogens training is current.
- Make sure job descriptions list the training each position requires.
- Save the roster and certificates where you can produce them quickly if DDA asks.
- If anyone falls short, write down the numbers and your plan to close the gap.
Ready before January 5
You don't need a new spreadsheet every quarter. You need one record that shows what each staff member has done and what is coming due.
To see how the Maryland DSP pathway maps courses to the DDA matrix, browse the pathway in the TES catalog. Organizations can request a team purchase from that page. If your agency already uses TES, sign in to check your team's status before the quarter closes.
Common questions
- When is the next Maryland DDA quarterly training attestation due?
- January 5. That report covers training completed in October, November and December. DDA's form lists October 5, April 5 and July 5 as the due dates for the other quarters.
- Which training must Maryland DSPs complete before working on their own?
- Under COMAR 10.22.02.11(C), staff must complete the Administration's approved training for their duties before independent duties, such as seizure disorders, principles of behavior change, management of disruptive behaviors, medication administration, and the aging process and special needs of the elderly. They also need bloodborne pathogens training that follows OSHA's standard.
Sources
- COMAR 10.22.02.11 Staffing Requirements · State regulation text (Library of Maryland Regulations)
- DDA Quarterly Provider Training Attestation (revised March 17, 2026) · · State agency form
- DDA Provider Training Matrix · · State agency training matrix
- 2025 Waiver Changes: Provider Opportunities and Requirements · · State agency presentation; quarterly attestations begin October 6, 2025
- DDA CCS and Provider Training · State agency page linking the training matrix and attestation form
- 29 CFR 1910.1030 Bloodborne Pathogens · Federal standard incorporated by reference in COMAR 10.22.02.11(C)(3)
