Bifurcated

Maryland No Surprises Act & IDR Rules

Last verified: July 2026 · For informational purposes only, not legal advice

Quick answer: Maryland is a bifurcated state. Some disputes are governed by Maryland's own specified state law, while others default to the federal No Surprises Act IDR process depending on the plan type and service involved.

How it works

Maryland uses an All-Payer Model Agreement (APMA) rather than a standard specified state law. It determines the out-of-network rate for emergency and non-emergency items and services involving HMO, PPO, or EPO plans governed by Maryland law, plus hospital-based or on-call physicians paid directly by a PPO or EPO. The federal IDR process applies mainly to air ambulance services and certain provider types not covered by the APMA.

Key dates

Federal No Surprises Act protections took effect January 1, 2022. State-specific protections vary — check the official source below for exact effective dates in this state.

Official source: Centers for Medicare & Medicaid Services — Maryland enforcement letter and specified state law documentation (cms.gov/nosurprises)

See the full Maryland breakdown

Detailed rules, plan-type exceptions, and recent changes for Maryland — all in one AI-powered lookup.

Unlock Maryland — $9.99