Urgent Notice: Maryland Governor Wes Moore Issues Directive that would Facilitate the Unionization of Maryland Home Care Workers

On December 8, 2025, Maryland Governor Wes Moore issued a directive instructing the Maryland Department of Health to establish and maintain a statewide “Home Health Care Provider Registry.” Unlike prior legislative activity in Maryland, which focused on studying whether a registry was feasible, the directive makes clear that the administration intends to move forward with creating and publishing a registry of home care workers in Maryland.

​For home care agencies, this marks an important shift from analysis to implementation and raises several operational and policy questions that will unfold over the coming year.
 
What the Directive Requires
 

• The Maryland Department of Health must create a publicly available registry containing information about individual caregivers employed by Residential Service Agencies (RSAs), which is how home care agencies are licensed in Maryland.
• RSAs will be required to submit, at a minimum, each employed caregiver’s:
  • full name, address, and phone number
  • employer
  • job title, and
  • completed trainings/certifications
  • additional information may be required

The registry must be updated at least quarterly and posted on the Department’s website. Information will be available to eligible organizations, explicitly including employee organizations (e.g., unions), as well as relevant employers.
 
Caregivers cannot be charged fees related to the creation or maintenance of the registry. The Directive does not address the cost and administrative burden on agencies.
 

• The Department must establish a process for caregivers to request exemptions for safety concerns (e.g., domestic violence, stalking), but there is no mention of broader concerns from the caregiver community and their families, many of whom are immigrants.
• The Department must assess whether additional regulations are needed to support implementation.

 
Why This Matters for the Home Care Industry
 
A centralized registry of individual home care workers is a significant policy development for agencies operating in Maryland. While the stated goals include improving transparency and helping Marylanders identify qualified caregivers, the registry has broader workforce and labor implications and practical concerns for agencies:

• Lower barriers for labor outreach and organizing activity
• Increased administrative burden for agencies
• Data privacy and accuracy
• Frequency of required updates
• Unclear processes for caregiver removal and protection
• Unclear processes to protect Marylanders from inaccurate or outdated information on the registry, such as if a caregiver has a subsequent criminal conviction

 
What Comes Next
 
The Maryland-National Capital Homecare Association (MNCHA) and several local home care agencies are actively opposing the directive. All HCAOA members with Maryland locations are encouraged to contact the Governor’s office and their state legislators to express concerns. HCAOA will closely monitor developments and will advocate to protect agencies and caregivers from the harmful effects that could result from this directive.