Health Insurance - Material Changes to Provider Networks - Notification and Special Enrollment Period
SB 521 makes several changes to Maryland insurance law governing health benefit plans that use provider panels. The bill expands notice requirements when a primary care provider or behavioral health provider is terminated from a carrier’s network, requiring notice to include contact information for complaints, instructions for requesting transitional care, and information for the state insurance complaint office. It also extends the right of affected enrollees to continue receiving care for up to 90 days after notice of termination, and it adds a requirement that providers furnishing that transitional care accept carrier payment and applicable patient cost-sharing as payment in full.
The bill also creates a new set of rules for “material changes” to provider networks involving health systems. Carriers and health systems must give each other at least 90 days’ written notice before terminating or nonrenewing a contract, carriers must make good-faith efforts to notify affected patients at least 30 days in advance, and both parties must continue to follow contract terms for 90 days after termination or nonrenewal for contracts entered into, renewed, amended, or continued on or after October 1, 2026. During that 90-day period, reimbursement terms and patient balance-billing protections remain in effect, and the Insurance Commissioner must develop a uniform form for requests to continue care.
SB 521 also expands special enrollment rights in the individual market and outside the exchange. If an enrollee or dependent is a regular patient of a provider who is terminated from the plan’s provider panel, the individual may qualify for a 90-day special enrollment period both on and off the Individual Exchange. Coverage effective dates are adjusted so consumers can select whether coverage begins the first day of the month after plan selection or the first day of the month in which the provider termination became effective. The bill takes effect October 1, 2026.
The bill’s impact on state law is to add a new Health-General provision applicable to health systems and to amend multiple Insurance Article provisions on provider panel notices, access plans, transitional care, and special enrollment periods. It broadens the scope of protected providers beyond primary care to include behavioral health providers, imposes new timing and content requirements on carriers and health systems, and gives the Insurance Commissioner additional oversight and enforcement tools, including a daily fine for late access-plan updates.
The overall sentiment appears strongly favorable. The bill passed the Senate unanimously and the House by a wide margin, indicating broad bipartisan support for stronger consumer protections during network disruptions. No committee transcript was provided, but the voting history suggests the measure was viewed as a patient-access and continuity-of-care bill rather than a controversial policy change.
SB 521 amends the Insurance Article to require earlier and more detailed notice of provider and health system network terminations, to extend transitional care obligations, and to create new special enrollment periods for affected consumers. It also adds a new Health-General section requiring health systems to comply with the contract-termination notice rules in the Insurance Article. The bill affects carriers, health systems, providers, enrollees, and the Insurance Commissioner, and it adds enforcement authority through access-plan review and civil fines for late filings.
The bill appears to have received broad support with little visible opposition. It passed the Senate 45-0 and the House 129-3, suggesting strong bipartisan agreement on the need for clearer notice, continuity of care, and enrollment flexibility when provider networks change. The available record does not include committee testimony or floor debate, but the vote totals indicate the measure was generally well received.
The main policy issues underlying the bill are the burden on carriers and health systems versus the consumer protections it creates. Potential points of contention include the 90-day continuation-of-contract requirement after termination or nonrenewal, the expanded notice obligations to patients and the Commissioner, and the new special enrollment periods that may increase administrative complexity for carriers. The bill also imposes a $5,000-per-day fine for late access-plan updates, which could be a concern for insurers, while patient advocates and affected enrollees would likely support the added continuity-of-care protections.