The Maryland Health Care Commission (MHCC) is releasing COMAR 10.25.06 for informal comment. MHCC currently collects data on paid commercial claims from Maryland payors for inclusion in the Medical Care Data Base (MCDB), Maryland’s All-Payer Claims Database (APCD). Although nearly half of states with similar databases currently collect information about denied claims, MHCC does not. The Maryland Health Care Commission (MHCC) is in ongoing discussions with the Maryland Insurance Administration (MIA), the Health Services Cost Review Commission (HSCRC), the Maryland Department of Health (MDH), the Prescription Drug Affordability Board (PDAB), and the Health Education and Advocacy Unit (HEAU) about the value that data on denied claims would add to a variety of public health initiatives. While Maryland collects some information on insurance denials, the State lacks individual service-level information regarding denials. The current data that the state receives on prior authorization is typically organized into broad service categories, such as “Durable Medical Equipment,” but not the level of specificity to comprehensively identify individual denied services, such as “Continuous Glucose Monitors.” Collecting denied claims will provide insights into payors operating in the state, utilization management procedures and identify patterns in health services that are routinely denied. MHCC is collaborating with other states regarding the collection of denied claims in their APCDs. Eleven of the twenty-five APCD states are currently collecting denied claims.

The draft regulations require payors to begin reporting denied claims in 2027.

For further details and the response due date, please visit the Response for Public Comments page.