Maryland’s Prompt Pay law is stated in § 15-1005 of the Insurance Article. It applies to health policies issued in Maryland by insurers, nonprofit health services plans, health maintenance organizations, Medicaid managed care organizations, and the Medicaid mental health administrative serviced organization (carriers). It does not apply to Medicare, including Medicare Advantage plans, or the Federal Employee Health Benefit Program. It also does not apply to self-funded benefit plans offered b employers, where the insurer provides only administrative services. Property and casualty claims, including PIP and Worker’s Compensation claims, are not subject to the law.
This law requires payment within 30 days of receipt of a “clean” claim. Clean claims, and the information a carrier may request, are defined in COMAR 31.10.11. If a claim is not clean or is in dispute, notice stating the specific information required to process the claim must be sent within 30 days. Interest is required to be paid along with late claim payments. For a detailed understanding of the law, you should read the statute and regulations.
To file a complaint about a possible violation of the Prompt Pay law, you can use our online system.
If you have multiple complaints about the same carrier, please provide a representative sample of no more than ten claims. Include the date of service, date of submission, how it was submitted (electronic or paper), and a copy of the claim form and member identification card, if available. If additional information was requested by the carrier, include the claim number, and the date of re-submission.
Section 15-1008 of the Insurance Article limits when a carrier may retroactively deny reimbursement of a health claim that has already been paid to the provider. In general, a carrier is limited to six months from the date a claim is paid to retroactively deny the claim.
If the retroactive denial is due to fraud or miscoding, there is no time limit for the denial. If the retroactive denial is due to coordination of benefits, the time limit is 18 months from the date of payment, and the carrier must give notice that includes the primary carrier’s name and address. In a case involving a coordination of benefits, you have six months to file the claim with the primary carrier.
A carrier can reimburse itself by reducing future payments owed to a provider if the carrier provides timely notice of the retroactive denial.
To file a complaint about retroactive denial of claims, you can use our online system. Maryland’s credentialing law is in § 15-112 of the Insurance Article. The statute deals with multiple aspects of how carriers contract with providers for participation on a provider panel. “Within 30 days of receiving an application, a carrier must send notice of the carrier’s intent to continue to process the application or a rejection of the application. If a carrier proceeds with processing the application, the carrier has 120 days after the date of the notice to accept or reject the provider for participation and send notice of the decision. If an application is incomplete, the carrier must return the application within 10 days.
Webinar - Provider Panels: The Credentialing ProcessView hard copy of Webinar HERE.View Webinar below: 
Section 15-112.1 of the Insurance Article requires a carrier to accept the uniform credentialing form submitted to it by a provider. A carrier may not request information that is not part of the uniform credentialing form. The Council for Affordable Quality Healthcare, Inc. (CAQH) online form has been designated as the uniform credentialing form.
It is always best to consult with an attorney if you have questions relating to signing a provider panel contract.
To file a complaint about credentialing delays or problems, you can use our online system.
A provider who is an on-call physician and who accepts assignment of benefits for health care services rendered to an insured in a hospital, and covered under a preferred provider individual or group insurance policy is reimbursed based on § 14-205.2 of the Insurance Article. The claim should be billed with CPT code 99026 or its successor. The insured cannot be billed any amount other than coinsurance, copayment, or deductible.
A provider who is a hospital-based physician and who accepts assignment of benefits for health care services rendered to an insured in a hospital, and covered under a preferred provider individual or group insurance policy is reimbursed based on § 14-205.2 of the Insurance Article. The insured cannot be billed any amount other than coinsurance, copayment, or deductible.
A provider who is an on-call physician who does not accept assignment of benefits may charge the patient usual billed charges. The carrier may reimburse the patient directly. The carrier is required only to pay the allowed amount as defined in the member’s policy or certificate of coverage.
A provider who provides out-of-network services, and is not an on-call or hospital-based physician, may collect usual billed charges from the patient. A physician who provides the disclosure described in § 14-205.3 of the Insurance Article may be paid directly based on an assignment of benefits. The carrier is required to pay only the allowed amount as defined in the member’s policy or certificate of coverage.
- Complaints about the amount of payment
If you have a complaint that the amount paid is less than the amount specified in your contract with the carrier (or the carrier’s provider panel subcontractor), or the member’s policy or certificate of coverage if you are out-of-network, you may file a complaint through our online system. Partial denials of claims, including denials of the amount between the allowed amount and billed charges, are subject to § 15-10D-02 of the Insurance Article. An appeal must be filed with the carrier prior to filing a complaint with the Maryland Insurance Administration. If you have multiple complaints about the same carrier, please provide a representative sample of no more than 10 claims. Include the date of service, date of submission, how it was submitted (electronic or paper), and a copy of the claim form, EOB, appeal, appeal response, and member identification card, if available.
Health care providers can now more easily tell where to file a complaint about a patient’s health plan. Starting in 2021, a new law requires health plans regulated by the Maryland Insurance Administration to put “MIA” on insureds’ identification cards. Medicaid managed care organizations must put “MDH” on identification cards for plans regulated by the Maryland Department of Health. The information will need to be on cards for plans issued or renewed on or after January 1, 2021.
If a card has “MIA” printed on it, health care providers can file a complaint with the Maryland Insurance Administration on behalf of their patients. If a card does not have either “MIA” or “MDH” printed on it, health care providers may still be able to file a complaint with the Maryland Insurance Administration. The plan may not have renewed or issued new cards yet. The Maryland Insurance Administration will review the complaint and if necessary will direct the health care provider to the correct agency that regulates the patient’s plan if it is not the Maryland Insurance Administration.
The new identification card law does not apply to short term, limited duration medical plans or indemnity plans. These plans are regulated by the Maryland Insurance Administration, and you may file a complaint on behalf of a patient covered by one of these plans.
The No Surprises Act requires health care providers and facilities to make publicly available a one page notice regarding protections under the law. The Centers for Medicare and Medicaid Services (CMS) published a model notice providers and facilities may use to meet the requirements. The Maryland Insurance Administration and the Health Education and Advocacy Unit of the Office of the Attorney General developed text regarding protections under Maryland law, and where patients may file a complaint. The CMS notice with the Maryland-specific text is here. Providers and facilities may, but are not required to, use this template as a way to comply with federal law.
- Lunch with MIA: The federal no surprises act - What health care providers need to know
March 16, 2022
View video HERE
