Maryland Workers' Compensation Medical Bills: Payment and Dispute Guide

Maryland's rules combine three different controls that should not be confused: the provider's statutory bill-submission period, the payer's regulatory payment-or-denial period, and the Commission process used to resolve an unpaid or reduced bill. The correct result still depends on compensability, authorization, medical necessity, coding, the applicable maximum reimbursement, prior payment, and claim-specific orders.

This guide reflects Maryland statutes, regulations, Commission forms, and CompHub materials available October 14, 2026. It is general operational information for healthcare providers and reimbursement teams, not legal advice or a determination of payment, interest, standing, good cause, or hearing procedure in an individual claim.

Maryland medical-bill workflow at a glance

1. Verify the claim and reimbursement route

Before calculating a fee, confirm that the bill belongs in the Maryland workers' compensation system. Match the employee, employer, injury date, Commission claim number, carrier or self-insured employer, TPA, bill-review vendor, and adjuster. Determine whether the accidental injury or occupational disease has been accepted, controverted, or found compensable, and whether the treatment relationship or authorization is disputed.

• Confirm the exact Maryland claim and payer responsible for the injury date.
• Review accepted body parts, prior orders, utilization or authorization history, and any current hearing issues.
• Separate a fee-calculation dispute from compensability, causation, authorization, and medical-necessity disputes.
• Do not use a health-plan EOB, liability claim, or Maryland PIP workflow as a substitute for workers' compensation processing.
• Preserve public claim inquiry results and payer routing details without adding unnecessary patient information to the dispute package.

2. Control the 12-month bill-submission rule

Maryland Labor and Employment §9-660(d) requires a provider to submit its bill within 12 months from the latest of three dates: when the medical service or treatment was provided, when the employer or insurer accepted the compensation claim, or when the Commission determined the claim compensable. The latest-trigger language matters when treatment predates acceptance or adjudication.

A bill submitted after that period is not automatically payable. The statute says the employer or insurer may not be required to pay unless the provider files an application for payment with the Commission within three years from the latest of the same trigger dates and the Commission excuses the late submission for good cause. Providers should not treat the three-year provision as an ordinary billing deadline; it is a conditional exception requiring Commission action.

3. Calculate the Maryland reimbursement amount

Labor and Employment §9-663 authorizes the Commission to regulate medical fees and requires periodic review of its guide. COMAR 14.09.08 provides the calculation framework. The rule uses current-year coding and payment inputs for many services, but Maryland law, Commission regulations, policies, and guidelines take precedence over conflicting CMS program rules.

For coding, billing, reporting, and reimbursement, COMAR 14.09.08.05 directs authorized providers to use the CPT or HCPCS code and modifier in effect on the service date. It also calls for current-year RVU and GPCI values and identifies the Baltimore and Surrounding Counties locality. Hospital rates, ambulatory surgery, anesthesia, evaluation services, and other categories may follow different provisions, so a generic Medicare percentage is not a complete calculation.

• Identify the service date, provider type, setting, code, modifier, units, and billed charge.
• Select the applicable COMAR payment section rather than applying one formula across every setting.
• Retain the source year, RVU or payment rate, locality, conversion factor, packaging rule, and arithmetic used.
• Check whether an HSCRC hospital rate or another Maryland-specific rule controls.
• Reconcile line-level reimbursement against prior payment, credits, refunds, and patient-account activity.

4. Build a complete CMS-1500 submission

The 45-day reimbursement provision is tied to the payer's receipt of the CMS-1500. A clean operational file should contain the completed form, itemized service information, focused clinical records supporting the treatment, authorization or referral evidence when relevant, the expected-payment calculation, and proof of the exact submission received.

1. Validate patient, employer, insurer, claim, provider, tax, NPI, service, diagnosis, and charge information.
2. Match codes, units, modifiers, place of service, and dates to the source documentation.
3. Attach the focused reports needed to support work relationship, authorization, necessity, and service delivery.
4. Document the Maryland reimbursement calculation separately from the billed charge.
5. Transmit through the payer's recognized channel and retain clearinghouse, portal, fax, or mail proof.
6. Archive every corrected claim or supplement without overwriting the original submission history.

5. Track the 45-day payment or denial requirement

COMAR 14.09.08 provides that if the employer or insurer does not pay the fee calculated under the chapter or file a notice of denial within 45 days after receiving the CMS-1500, the Commission may assess a fine and award interest under §§9-663 and 9-664 and COMAR 14.09.06.02. A partial or total denial must state the reasons in writing and be mailed to the provider within that 45-day period.

A provider ledger should therefore show the CMS-1500 receipt date, denial mailing date, amount paid, amount denied, stated reasons, any corrected or additional documentation, and the date and terms of any Commission order. Preserve the payer's written denial rather than relying on a call note or portal status.

6. Contest a denial through the Commission process

COMAR 14.09.08 allows a provider to contest a partial or total denial by submitting the Commission's Claim for Medical Services form with the required supporting materials. The Commission reviews the submission and can issue a decision without a hearing. The regulations also provide a route to contest the Commission's order, while the Commission's Issues form identifies medical expenses as a hearing issue and includes healthcare providers among the parties who may raise issues.

Use the procedure that matches the unresolved issue. A Claim for Medical Services filing, objection to an order, and Issues request are not interchangeable. Confirm current CompHub filing steps, service requirements, representation rules, and deadlines before submitting. A provider should also distinguish its fee claim from the injured worker's disability or treatment-authorization dispute.

Provider quality-control checklist

• Correct Maryland claim, employer, insurer, TPA, adjuster, and compensability posture verified.
• Treatment, acceptance, and Commission compensability dates captured for §9-660 analysis.
• Original bill submitted within the applicable 12-month period or late-bill route reviewed separately.
• CMS-1500, clinical support, calculation, transmission, and receipt retained.
• Service-date code, modifier, setting, payment section, locality, values, and arithmetic documented.
• Payment or written denial tracked through day 45 after receipt.
• Partial payments, adjustments, denial reasons, and remaining balance reconciled by line.
• C-51 package contains the bill, denial, records, calculation, and proof required by the current rule and form.
• Interest, fine, and post-order payment triggers analyzed separately.
• Current CompHub procedure, service, hearing issue, and requested relief confirmed before escalation.

Related Millennova Legal resources

Explore Millennova Legal's workers' compensation reimbursement support, state workers' compensation guides, Maine medical-bill guide, Connecticut payment-dispute guide, and Pennsylvania fee-review guide. Maryland automobile PIP follows a different pathway discussed in the Maryland PIP provider guide.

Maryland primary sources