Updates to Carrier Reporting Form for Adverse Decisions and Grievances

WES MOORE Governor ARUNA MILLER Lt. Governor BULLETIN 25-15 Date: September 25, 2025 To: Insurers, Nonprofit Health Service Plans, Health Maintenance Organizations and Dental Plan Organizations (Carriers) Re: Updates to Carrier Reporting Form for Adverse Decisions and Grievances House Bill 820, Chapter 747, Acts of 2025 Senate Bill 474, Chapter 670, Acts of 2025 The purpose of this bulletin is to notify carriers of updates to the required Reporting Form for Adverse Decisions and Grievances under § 15-10A-06 of the Insurance Article. House Bill 820, Chapter 747, Acts of 2025 and Senate Bill 474, Chapter 670, Acts of 2025 each amend § 15-10A-06 of the Insurance Article, Annotated Code, effective October 1, 2025, to revise the requirement for carriers to submit specified information to the Maryland Insurance Administration (the "Administration") on a quarterly basis. House Bill 820 requires a carrier, when reporting the number of adverse decisions issued, to identify whether an artificial intelligence, algorithm, or other software tool was used in making the adverse decision. Senate Bill 474 requires the information reported to the Commissioner under § 15-10A-06 to be aggregated by zip code, as required by the Commissioner. Carriers will be required to report the top 5 zip codes for adverse decisions and the top 5 zip codes for grievance decisions, determined according to the ratio of adverse decisions/grievance decisions to clean claims in each zip code. Zip code shall be based on the location of the proposed or delivered treatment, service, or item that was the subject of the applicable adverse decision, grievance decision, or clean claim. Carriers will be required to report the zip code, the number of adverse decisions (or, as applicable, the number of grievance decisions), the number of clean claims, and the calculated ratio expressed as a percentage. The Administration has updated the required Reporting Form for Adverse Decisions and Grievances to include the information required by House Bill 820 and Senate Bill 474, and the updated form may be accessed on the Administration’s website at the following link: MARIE GRANT Commissioner JOY Y. HATCHETTE Deputy Commissioner 200 St. Paul Place, Suite 2700, Baltimore, Maryland 21202 1-800-492-6116 TTY: 1-800-735-2258 www.insurance.maryland.gov