el and AHEAD Model to improve care quality, health outcomes, and cost-efficiency.
Notice is hereby given that the public and interested parties are invited to submit written comments to the Commission on the following topic:
Discussion on Principles for Physician Payment, as presented at the December 10, 2025 Commission meeting. Based on Commissioner discussion, potential principles have been revised from the original presentation. Please see the revised potential principles for comment below.
WRITTEN COMMENTS ON THE DISCUSSION POINTS OUTLINED BELOW AND ON THE STAFF PRESENTATION SHALL BE SUBMITTED TO [email protected] ON OR BEFORE January 5, 2026.
Background
The HSCRC has identified rising costs of hospital-based physicians as a financial challenge facing hospitals. These costs include the need to supplement insurance reimbursements, provide payment for coverage, and respond to market dynamics that include the involvement of private equity-backed companies in employing physician groups.
A recent review of data suggests that physician costs can explain a large share of the difference between regulated margins and operating margins in the state.
Under Maryland statute, the Commission cannot provide funds to support physician costs. There has been resulting interest in whether additional state programs or policies would further the goals of the model. The HSCRC is interested in public comment on principles for potential state initiatives regarding physician costs.
Of note, the new AHEAD agreement does not provide for additional Medicare funds to cover physician costs through hospital global budgets.
Potential Principles for Comment
HSCRC will develop principles to support decision-making on potential physician cost initiatives. Examples of such principles might include:
- Funding for physicians should focus on hospital-based physicians necessary for the administration of an efficient hospital.
- Funding for physicians should facilitate the goals of the model, including improving quality, improving health outcomes, and reducing overall costs.
- Funding for physicians should be paired with efforts to reduce underlying cost drivers.
- Funding for physicians should support care delivery innovations that solve broader challenges of the health care delivery system.
- Funding for physicians should be available fairly to all hospital-based physicians.
- Funding for physicians should be aligned with EQIP, MDPCP, and/or other value-based payment programs within the state.
- Funding for physicians should be coordinated with CMS so that Medicare and Medicaid participate.
