Maryland Healthcare AI in Utilization Management Act (HB 820): AI Compliance Requirements
Maryland HB 820 (effective October 1, 2025) regulates the use of AI in health insurance utilization management and prior authorization decisions. Mirrors California SB 1120. Requires that AI support — not replace — clinician judgment in medical necessity determinations. Applies to health insurers, pharmacy benefit managers, and private review agents operating in Maryland.
Key Facts
October 1, 2025
Maryland Insurance Administration enforcement (existing healthcare law penalties apply)
What Your Business Must Do
4 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.
Clinician Oversight of AI Decisions
CriticalAI systems used in utilization management or prior authorization must be used as a tool to support licensed clinician review — not to autonomously make or override medical necessity determinations. A licensed clinician must make the final decision.
Individual Clinical Information Requirement
High PriorityAny AI-assisted utilization management decision must be based on the individual patient's full clinical information, not solely on statistical models or population-level data.
Non-Discriminatory AI Application
High PriorityAI tools must be applied fairly and equitably across all enrollees. Carriers must implement policies prohibiting AI systems from producing discriminatory outcomes based on protected characteristics.
AI Utilization Reporting
Medium PriorityMaintain records and reports on AI tool use in utilization management decisions, including audit trails sufficient to demonstrate compliance with Maryland Insurance Administration requirements.
Frequently Asked Questions
Does Maryland Healthcare AI in Utilization Management Act (HB 820) apply to my business?
Maryland HB 820 (effective October 1, 2025) regulates the use of AI in health insurance utilization management and prior authorization decisions. Mirrors California SB 1120. Requires that AI support — not replace — clinician judgment in medical neces. Use ComplianceIQ's free scanner to get a personalized assessment in under 5 minutes.
What is the penalty for non-compliance?
The maximum penalty under Maryland Healthcare AI in Utilization Management Act (HB 820) is: Maryland Insurance Administration enforcement (existing healthcare law penalties apply). Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Maryland Healthcare AI in Utilization Management Act (HB 820)?
The 4 requirements above cover the core obligations. The fastest path to compliance is: (1) conduct an AI risk assessment, (2) document your AI systems, (3) implement transparency disclosures where required. ComplianceIQ generates all required documents automatically.
Official Source
https://mgaleg.maryland.gov/mgawebsite/legislation/details/hb0820?ys=2025RSDon't leave compliance to chance
ComplianceIQ scans your AI tools, tells you exactly which regulations apply, and generates all required documents — in 30 minutes.
Start your free compliance scan