No Surprises Act Arbitration in Maryland
Physicians and facilities in Maryland initiated 5,060 federal IDR disputes in the second half of 2025 — the 31st-highest volume in the country, and 0.4% of the national total. We work these claims for Maryland practices from our office in California; the process is federal and runs identically in every state.
What the Numbers Show
| Period | Disputes initiated in Maryland |
|---|---|
| Q3 2025 (July–September) | 2,118 |
| Q4 2025 (October–December) | 2,942 |
| Second half of 2025 | 5,060 |
| Of which air ambulance transport | 227 |
Source: CMS, Federal IDR Supplemental Tables, Q3 and Q4 2025, Table 7 (dispute initiations by state or territory). CMS notes that batched disputes covering items or services in several states are counted in each of those states, so state figures sum to more than the national total. National win-rate figure from Table 12 for the same period: 977,661 of 1,145,039 payment determinations. Published by CMS here.
Which Process Applies to a Maryland Claim
Maryland is one of the states CMS flags as having a specified state law or All‑Payer Model Agreement. That does not remove you from the federal process — it means the route depends on the claim. Where a state law governs the payment dispute and the plan is one the state can reach, the state process applies. Where it does not — most commonly with self‑funded ERISA plans, which states cannot regulate — the federal process applies.
This distinction is the single most expensive thing to get wrong in Maryland. Filing federally on a claim the state governs, or the reverse, gets the dispute closed as ineligible: the fee is spent, the deadline has usually passed, and the claim is gone. In 2025 about one in five initiated disputes nationally was found ineligible.
The practical answer usually starts with a question the EOB can settle: is the patient's plan self‑funded? Self‑funded employer plans made up the large majority of federal disputes nationally — 486,734 of 719,118 initiations in the fourth quarter of 2025 alone. If the plan is self‑funded, the state law almost certainly does not reach it, and the federal process is where the claim belongs.
What we check before anything is filed
- Whether the patient's plan is self-funded, fully insured, a government plan or a FEHB carrier — this decides state versus federal more often than anything else.
- Whether the item or service falls under the federal protections: emergency care, or ancillary services at an in-network facility, or non-emergency care where notice and consent was not validly obtained.
- Whether the 30-business-day open negotiation period was properly opened and completed, and whether the four-business-day window to initiate has passed.
- Whether claims can be batched, which is usually what decides the economics.
We are paid out of what is recovered. If the claims do not survive these checks, filing them costs you money and we say so before anything is submitted.
Start With Your Own Numbers
The federal data says what happened across hundreds of thousands of disputes. It says nothing about your claims — and it is your denials, your QPAs and your dates that decide whether there is anything worth pursuing.
Send us a sample of EOBs. We tell you which claims are eligible, what the timing looks like, and whether the arithmetic works at $15 per party per dispute. That review costs nothing and carries no obligation.