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 all disputes initiated across the states and territories. We work these claims for Maryland practices from our office in California. The federal process itself runs the same way everywhere, but CMS flags Maryland as having a specified state law, so which route a given claim takes depends on the plan behind it — set out below.
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. Nationally, 15.0% of disputes closed in January–September 2026 were found ineligible — about one in seven.
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.
Common Questions About Filing From Maryland
Does Maryland run its own arbitration process, or does my claim go federal?
CMS flags Maryland as having a specified state law or All-Payer Model Agreement covering certain out-of-network payment disputes, so both routes exist and which one applies depends on the plan rather than on the claim. Self-funded employer plans are governed by ERISA, which states cannot regulate, so those disputes go through the federal process even here. Where the plan is fully insured and the state law reaches it, the state process applies. A dispute filed in the wrong forum is closed as ineligible, and by then the deadline has usually passed.
How many federal IDR disputes came from Maryland?
5,060 federal IDR disputes were initiated in Maryland in the second half of 2025 — 0.4% of all disputes initiated across the states and territories, and the 31st highest volume of any state or territory. The quarterly split was 2,118 in the third quarter and 2,942 in the fourth. These are counts of disputes filed, not of underpayments: a low number says how often practices here use the process, not how often they are underpaid.
Is federal IDR volume in Maryland rising or falling?
Volume rose 39% between the quarters of the second half of 2025 — from 2,118 disputes initiated in the third quarter to 2,942 in the fourth. Across all states and territories the change over the same two quarters was +10.1%, so Maryland moved faster than the national pace. A rising count means the process is being used more here, not that payers are underpaying more: CMS publishes filings, not underpayments, and the two are not the same measurement.
Are air ambulance claims counted separately for Maryland?
Yes. Of the 5,060 disputes initiated in Maryland, 227 involved out-of-network air ambulance services, which CMS reports as its own category because the No Surprises Act treats air ambulance transport under separate provisions. Ground ambulance sits outside the federal process entirely.
What decides whether a Maryland claim is eligible at all?
Eligibility, not the merits, is where most filings are lost: 15.0% of disputes closed nationally in January–September 2026 — about one in seven — were found ineligible and never reached a decision (18.7% in the second half of 2025). The causes are the same everywhere — the wrong forum, a missed window, or a service the protections do not cover. The federal timetable is a 30-business-day open negotiation period, then a four-business-day window to initiate that begins on the 31st business day after that period started.