Health Insurance - Material Changes to Provider Networks - Notification and Special Enrollment Period
HB684 expands Maryland’s health insurance notice and continuity-of-care rules when provider networks change. The bill requires carriers to give enrollees more detailed notice when a primary care provider or behavioral health provider is terminated from a provider panel, including contact information for complaints, instructions for requesting transitional care, and information about the Insurance Administration. It also extends the right to continue receiving care for up to 90 days after notice of termination, so long as the termination is not for fraud, patient abuse, incompetency, or loss of licensure.
The bill also adds new requirements for carrier–health system contract terminations. For certain contracts involving hospitals and affiliated entities, both sides must give at least 90 days’ written notice before termination or nonrenewal, and carriers must make a good-faith effort to notify affected patients at least 30 days in advance. For contracts entered into, renewed, amended, or continued on or after October 1, 2026, the carrier and health system must continue contract terms for 90 days after termination or nonrenewal, including reimbursement terms and patient balance-billing protections, unless both parties agree in writing to end the contract and provide the required notices.
HB684 also changes Maryland’s insurance access-plan reporting rules. If a provider or health care facility termination will materially change a carrier’s network, the carrier must notify the Insurance Commissioner at least 60 days before the anticipated termination, keep updating the notice until the termination is resolved or effective, and file an updated access plan within five business days after the termination takes effect. The Commissioner may require corrective action and may impose a $5,000-per-day fine for late filing. The bill further directs the Commissioner to create a uniform form for transitional-care requests.
In addition, the bill creates a new special enrollment period for individuals in the Individual Exchange and in off-exchange coverage when a provider treating the enrollee or dependent is terminated from the plan’s provider panel. That special enrollment period lasts 90 days and allows the consumer to change coverage in response to the network disruption, with effective-date options tied to the termination date or the notice date. The bill also defines “provider” for these enrollment provisions and applies the same pregnancy-related special enrollment rules already in law.
The overall sentiment reflected in the voting history appears strongly favorable: the House passed the bill 121-7 and the Senate passed it 47-0. No committee transcript excerpts were provided, so there is no recorded floor or committee debate to identify specific objections. The main policy tension inherent in the bill is between consumer continuity of care and carrier/health system flexibility in managing networks and contract negotiations, but the broad bipartisan vote suggests that any concerns were limited or resolved through amendments.
HB684 amends the Insurance Article and adds a new section to the Health-General Article to regulate provider-network terminations, notice obligations, transitional care, access-plan updates, and special enrollment rights. It expands existing continuity-of-care protections beyond primary care providers to include certain behavioral health providers, imposes new advance notice and reporting duties on carriers and health systems, and authorizes administrative penalties for noncompliance. It also creates a new special enrollment period tied to provider terminations for both exchange and non-exchange individual market coverage.
The bill appears to have received very strong support in both chambers, passing the House 121-7 and the Senate 47-0. That voting pattern suggests broad agreement on the need for stronger consumer protections when provider networks change and for clearer notice requirements during carrier-health system contract disruptions. No committee transcript was provided, so there is no documented opposition in the available materials.
The main areas of potential contention are the bill’s added compliance burdens on carriers and health systems, including 60- and 90-day notice requirements, mandatory continuation of contract terms for 90 days after termination or nonrenewal, and the $5,000-per-day penalty for late access-plan updates. Carriers and health systems may view these provisions as limiting their leverage in contract negotiations and network management, while consumer advocates are likely to support them as necessary to protect patients from abrupt care disruptions. The bill’s expansion of special enrollment rights and transitional-care obligations also shifts administrative responsibility to carriers and the Insurance Administration.