This section includes, when applicable, a record of public comments as well as the resulting staff summary, analysis, and recommendations.

Draft non-substantive updates to the Noncontrolled Prescription Drug Dispenser Data Submission Manual

Public comment period
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Instructions

In collaboration with stakeholders, MHCC considered updates to the Noncontrolled Prescription Drug Dispenser Data Submission Manual (dispenser manual). Draft updates are non-substantive and clarify certain processes for reporting noncontrolled prescription drug (non-CDS) dispense information to the State-Designated Health Information Exchange (CRISP). Notice of the proposed updates to the dispenser manual was printed in the Maryland Register on April 17, 2026; Volume 53, Issue 8.

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In collaboration with stakeholders, MHCC considered updates to the Noncontrolled Prescription Drug Dispenser Data Submission Manual (dispenser manual). Draft updates are non-substantive and clarify certain processes for reporting noncontrolled prescription drug (non-CDS) dispense information to the State-Designated Health Information Exchange (CRISP). Notice of the proposed updates to the dispenser manual was printed in the Maryland Register on April 17, 2026; Volume 53, Issue 8.

The MHCC is soliciting public comments on proposed updates to the dispenser manual. Please submit any questions and comments to mhcc.noncds@maryland.gov. For more information, visit MHCC's dedicated non-CDS webpage.

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For Questions Contact:
Email
mhcc.noncds@maryland.gov
Phone number

COMAR 10.25.03 User Fee Assessment of Payers, Hospitals, and Nursing Homes

Public comment period
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Instructions

The Maryland Health Care Commission proposes to amend Regulation .02 under COMAR 10.25.03 User Fee Assessment on Payers, Hospitals and Nursing Homes.  Notice of Proposed Action was printed in the Maryland Register on April 1, Volume 53, Issue 7

Comments may be sent to Alexandra Bryden, Chief of Staff, Maryland Health Care Commission, 
4160 Patterson Avenue 
Baltimore, MD 21215

For Questions Contact:
Email
alexandra.bryden@maryland.gov
Phone number

Proposed Permanent Regulations COMAR 10.25.06 to Collect Uncovered Services (Denials)

Public comment period
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Instructions

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.Read more

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.

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For Questions Contact:
Email
kenneth.yeates-trotman@maryland.gov
Phone number

COMAR 10.25.10 Maryland Trauma Physician Services Fund

Public comment period
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Instructions

The Maryland Health Care Commission proposes to amend Regulation .07 under COMAR 10.25.10 Maryland Trauma Physician Services Fund. Notice of Proposed Action was printed in the Maryland Register on March 20, 2026, Volume 53, Issue 6

Comments may be sent to Alexandra Bryden, Chief of Staff, Maryland Health Care Commission, 
4160 Patterson Avenue 
Baltimore, MD 21215

For Questions Contact:
Email
alexandra.bryden@maryland.gov
Phone number

Advancing the Integration of Social Needs Screening and Closed-Loop Referral Systems through the State-Designated Health Information Exchange, CRISP

Public comment period
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Instructions

The RFI seeks information on digital platforms that support social risk screening and data collection and enable referral coordination and billing between providers, community-based organizations (CBOs), and payers. Responses will be used to support market research, understand current technological capabilities, and shape future policies in the State that advance the integration of social needs screening and closed-loop referral platforms with the State-Designated Health Information Exchange (CRISP). The RFI is an enterable PDF; responses can be entered directly into the PDF or provided as a separate attachment. CBOs, providers, payers, technology vendors, and consumer representatives are encouraged to respond to some or all questions in the RFI.

For Questions Contact:
Email
kelly.scott@maryland.gov

CommuniCare 18 Nursing Homes Acquisitions

Public comment period
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Instructions

On February 9, 2026, the Commission posted applications for the acquisition of 18 Maryland nursing homes currently owned by CommuniCare. The Commission is soliciting public comment on these acquisitions for the next 30 days. Please send all comments via email using the email address:

Maryland Health Care Commission

For Questions Contact:
Email
jeanne-marie.gawel@maryland.gov
Phone number

10.24.06 Data Reporting by Non-Hospital Healthcare Facilities

Public comment period
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Instructions

Notice of Proposed Action [25-185-P] Volume 52 Issue 19 Maryland Register September 19, 2025

The Maryland Health Care Commission proposes to amend Regulations .01 and .02, repeal existing Regulation .03 and recodify existing Regulation .04 to be Regulation .03 under COMAR 10.24.06 Data Reporting by Non-Hospital Healthcare Facilities. 

Comments may be sent to Wynee Hawk, Director, Center for Health Care Facility Planning and Development, Maryland Health Care Commission, 4160 Patterson Avenue, Baltimore, MD 21215 or call 410-764-3261 (office) or 410-925-1218 (cell) or email to mhcc_regs.comment@maryland.gov.

For Questions Contact:
Email
wynee.hawk1@maryland.gov
Phone number

Value-Based Arrangements Request for Provider Feedback

Public comment period
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Instructions

SB0834/Ch. 298, HB 1148/Ch. 297(2), 2022 - Health Insurance – Two–Sided Incentive Arrangements and Capitated Payments – Authorization requires the Maryland Health Care Commission (MHCC) to aggregate the (1) the number and type of value–based arrangements entered into in accordance with the authority established under the law; (2) quality outcomes of the value–based arrangements; (3) the number of complaints made regarding value–based arrangements; (4) the cost–effectiveness of the value–based arrangements; and (5) the impact of two–sided incentive arrangements on the fee schedules of health care practitioners included in the target budget that are not eligible providers.

In addition to meeting these requirements, MHCC is interested in seeking provider feedback on value-based arrangements in the commercial fully-insured market.  

Provider Feedback

Provider feedback should be shared via email or this form. Providers submitting feedback should submit their answers in numbered response to the questions. Please see attached

Submission Guidance

Please submit your responses by email or using this form. All submissions should be directed to Shankar Mesta at Shankar.Mesta@maryland.gov. Please ensure your submission is completed by September 23rd, 2025.

If you have any questions or need assistance with the submission process, feel free to reach out to Shankar Mesta at Shankar.Mesta@maryland.gov.

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For Questions Contact:
Email
Shankar.Mesta@maryland.gov
Phone number

COMAR 10.25.07 Certification of Electronic Health Networks and Medical Care Electronic Claims Clearinghouses

Public comment period
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Instructions

Notice of Proposed Action [24-165-R] Volume 52 Issue 15 Maryland Register August 8, 2025

The Maryland Health Care Commission proposes to amend Regulations .01, .02 and .05, adopt new Regulation .09, amend and recodify existing Regulations .09 and .10 to be Regulations .10 and .11, and recodify existing Regulation .11 to be Regulation .12 under COMAR 10.25.07 Certification of Electronic Health Networks and Medical Care Electronic Claims Clearinghouses. This action was considered by the Commission at an open meeting held on June 12, 2025, notice of which was given through publication in the Maryland Register, in accordance with General Provisions Article, §3-302(c), Annotated Code of Maryland. Because substantive changes have been made to the original proposal as published in 51:24 Md. R. 1086 - 1088 (December 2, 2024), this action is being re-proposed at this time.  Comments will be accepted through September 8, 2025. A public hearing has not been scheduled.

Statement of Purpose

The purpose of this action is to re-propose amendments and a new regulation to COMAR 10.25.07 Certification of Electronic Health Networks and Medical Care Electronic Claims Clearinghouses.

Legislation passed by the Maryland General Assembly in 2021 (Chapter 790/House Bill 1022 and Chapter 791/Senate Bill 748, Public Health—State Designated Exchange—Clinical Information) requires the Maryland Health Care Commission (MHCC) to adopt regulations to support a State health improvement program, mitigate a public health emergency, and improve patient safety by requiring MHCC-certified electronic health networks (EHNs) to provide electronic health care transaction information to the State-designated health information exchange (HIE) for clinical and public health purposes. 

Legislation passed by the Maryland General Assembly in 2025 (Chapter 615/House Bill 1104, Maryland Department of Health—AHEAD Model Implementation—Electronic Health Care Transactions and Population Health Improvement Fund) clarifies that electronic health care transaction information may be used to support the State’s participation in the Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model and any successor models, among other things. 

The re-proposed amendments clarify and build upon proposed regulations published in Volume 51, Issue 24 of the Maryland Register on December 2, 2025 based on certain public comments received and new legislation passed during the 2025 Maryland legislative session pertaining to the AHEAD Model.

Re-proposed amendments

  1. Adds EHNs and the State-designated HIE to the scope of the chapter;
  2. Modifies when EHNs must demonstrate compliance with Health-General Article, §4-302.5, Annotated Code of Maryland;
  3. Allows electronic healthcare transaction information to be used for public health and clinical purposes to facilitate the State’s participation in the AHEAD Model;
  4. Clarifies required components and processes for the State-designated HIE in developing the Electronic Health Care Transactions Technical Submission Guidance;
  5. Extends the implementation timeline for the State-designated HIE and EHNs; and
  6. Adds requirements for the State-designated HIE and EHNs to report to MHCC on their implementation of the regulations.

Re-proposed amendments build upon previous amendments that:

  1.  Add definitions for improvement of patient safety, mitigation of a public health emergency, State-designated HIE, and state health improvement program;
  2. Adds a regulation requiring MHCC-certified EHNs to submit certain electronic health care transactions to the State-designated HIE for public health and clinical purposes;
  3. Requires the State-designated HIE to develop and publish Electronic Health Care Transactions Technical Submission Guidance;
  4. Prohibits EHNs from charging a fee for providing electronic health care transaction information; and
  5. Allows EHNs to request a one-year exemption from certain reporting requirements.
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For Questions Contact:
Email
anna.gribble1@maryland.gov
Phone number