Overview
Electronic health networks (EHN) operating in the State (also referred to as a clearinghouse or network) exchange electronic health care transactions between providers and payors; services include verifying the accuracy of claims submitted, reporting on errors identified during the data cleaning process, and formatting transactions to align with national standards established under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). COMAR 10.25.07, Certification of Electronic Health Networks and Medical Care Electronic Claims Clearinghouses (regulations) is the EHN regulatory framework, which includes requirements for certification by MHCC and submitting electronic health care transactions to the State-Designated Health Information Exchange, CRISP.
EHN Certification
COMAR 10.25.07 requires government and private payors that accept electronic health care transactions originating in Maryland to only accept transactions from MHCC certified EHNs. Certification is valid for a two-year period and requires a network to be accredited or certified by a nationally recognized organization where standards related to privacy and confidentiality, business practices, physical and human resources, technical performance, and security are evaluated. More information on the certification process as well as a list of MHCC-certified EHNs, is available on the EHN certification information page.
Reporting Electronic Health Care Transactions
State law (Chapter 791 (Senate Bill 748) and Chapter 790 (House Bill 1022), Public Health - State Designated Exchange - Clinical Information, 2021) requires EHNs to submit electronic health care transaction information to CRISP for public health and clinical purposes. CRISP is required to develop and implement supporting policies and procedures for EHNs. Transaction data will provide valuable information to support the State’s participation in the Achieving Healthcare Efficiency through Accountable Design (AHEAD) Model.
COMAR 10.25.07 supports implementation of the law. Final regulations became effective on November 10, 2025. The MHCC engaged stakeholders in an iterative process to amend the regulations:
May 2024 – Draft amendments to COMAR 10.25.07 released for informal public comment
July 2024 – Stakeholder working session to discuss draft regulations
December 2024 – Proposed amendments published in the Maryland Register for public comment
August 2025 – Reproposed amendments published in the Maryland Register for public comment
November 2025 - Final regulations
Guidance
Regulatory guidance prepared by MHCC serves as a resource for EHNs required to report electronic health care transactions to CRISP.
Regulatory Guidance: Electronic Health Networks Reporting of Electronic Health Care Transactions
CRISP developed draft technical submission guidance in collaboration with MHCC and EHNs.
DRAFT Electronic Health Care Transactions Technical Submission Guidance
CRISP anticipates finalizing the technical submission guidance in Q1 2026. For more information, visit CRISP’s EHN website or email Meg LaMar at Megan.Lamar@crisphealth.org.
Town Hall
The MHCC will convene a virtual Town Hall on January 30, 2026 from 10:00 – 11:00am EST to discuss drivers for using information from electronic health care transactions and regulatory guidance to support EHN’s implementation of the law. Stakeholders are encouraged to register for the EHN Town Hall in advance.
Legally Protected Health Information
State law (Chapter 248 (Senate Bill 786) and Chapter 249 (House Bill 812), Health – Reproductive Health Services – Protected Information and Insurance Requirements, 2023). The law prohibits the disclosure of legally protected health information by health information exchanges (HIEs) and EHNs operating in the State with some exceptions. Legally protected health information includes mifepristone data, the diagnosis, procedure, medication, and related codes for abortion care, and other sensitive health services with a date of service after May 31, 2022, as determined by the Secretary of Health and defined in COMAR 10.11.08.
The MHCC convened virtual Town Halls and prepared implementation guidance to support implementation of the law.
Implementation Guidance: Electronic Health Networks (May 2024)
Implementation Guidance: Health Information Exchanges (May 2024)
Resources and Supporting Documents:
For more information on electronic health care transactions reporting and legally protected health information, contact Anna Gribble at anna.gribble1@maryland.gov.
Additional Resources
Electronic Health Networks Overview (2023)
Informational flyer overviewing the role of EHNs and MHCC certification.
Briefing Paper: Public Health – State Designated Exchange – Clinical Information (2021)
Legislative update on funding availability and sustainability to support the requirements of Chapters 790 and 791 of the 2021 laws of Maryland.
Electronic Healthcare Network Accreditation Commission (EHNAC)
Information on accreditation programs that ensure the privacy and security of protected health information.
Health Information Trust Alliance (HITRUST)
Provides common risk and compliance management frameworks, related assessment, and assurance methodologies to support an organization’s information risk management and compliance objectives.