Client Alert: 2025 Legislative Changes for CCRCs
Date: May 29, 2025
House Bill 938 was passed in the Maryland legislature and signed by the Governor into law on May 6, 2025. This bill requires the appointment of an alternate subscriber (resident) to the governing body of a continuing care provider that has only one subscriber (resident) on the governing body. It also authorizes the alternate member to attend all meetings of the governing body, and to vote only if the regular subscriber (resident) is unable to fulfill the subscriber's (resident’s) duties as a regular member of the governing body. The provider shall confer with the Resident Association before the alternate subscriber (resident) joins the governing body, and the alternate subscriber (resident) may report on nonconfidential matters, policies, deliberations, and actions of the governing body to the Resident Association in the same way as the current subscriber/resident who is on the governing body. This law becomes effective on January 1, 2026.
For providers with one resident on the Board, this new legislation means that two residents will have to be appointed to the Board – a regular member and an alternate member. The alternate member should also receive the Board orientation, and any other trainings offered to the Board, all Board meeting materials and minutes, and be ready to vote as a regular Board member in the absence of the regular member. Therefore, two residents will be attending all Board meetings.
Security Guards
The law concerning security guards was passed in 2023; amended in 2024; and became effective 1/1/2025. The law requires Maryland businesses or individuals employing security services or loss prevention personnel to:
- License these employees as security guards through the Maryland State Police.
- Register as a “Security Guard Employer,” necessitating online registration and proof of insurance submission to the Maryland State Police Licensing Division.
- Assure that the security guard receives 12 hours of initial security training that is approved by the Maryland Police Training Commission or be a police officer within the three years immediately preceding the application for a security guard.
A “security guard” means any individual who, regardless of whether the individual is described as a security guard, watchman, private patrolman or any other title: (1) is an employee of a security agency and provides security guard services on behalf of the agency; or (2) is an employee of a security guard employer and provides security guard services to the security guard employer. A “security guard employer” is a person who employs a security guard who provides security guard services to the security guard employer.
Security guard services include any activity that is performed for compensation as a security guard to protect any individual or property, except the activities of an individual while performing as:
- a marine guard or ship watchman, regardless of whether the guard or watchman is stationed aboard a ship or on a pier;
- a special police officer appointed and while performing under Title 3, Subtitle 3 of the Public Safety Article or § 16–16 of the Code of Public Local Laws of Baltimore City; or
- an unarmed employee of a bar, tavern, or restaurant.
Click here to go to the site that provides information on registering as a security guard employer; registering as a security guard; and security guard training.
Screening and Medical Records
Senate Bill 740, which was signed into law on May 20, 2025, authorizes that each health care facility (i.e., nursing homes, assisted living, adult day care) may screen each patient for information on whether the patient is a service member community member, and if screened, requires recording the information in the medical record. The health care facility may identify service member community members as a vulnerable population and comply with the National Patient Safety Goal to Improve Health Care Equity established by The Joint Commission.
The Joint Commission defines "service member community member" to mean an (active) service member, a veteran, a spouse of a service member or veteran, a child of a service member or veteran, or a stepchild of a service member or veteran.
Under The Joint Commission*, organizations are required to do the following:
- Identify an individual to lead activities to improve health outcomes for all patient groups;
- Assess the patient’s health-related social needs;
- Analyze quality and safety data to identify differences in health outcomes;
- Develop an action plan;
- Take action when the organization does not meet the goals in its action plan; and
- Inform key stakeholders about progress to improve health outcomes for all.
This law becomes effective 10/1/2025.
*R3 Report Issue 38: National Patient Safety Goal to Improve Health Care Equity/
The Joint Commission
The information contained here is not intended to provide legal advice or opinion and should not be acted upon without consulting an attorney. Counsel should not be selected based on advertising materials, and we recommend that you conduct further investigation when seeking legal representation.