Effective October 1, 2025, significant changes were made to the mandated reporting requirements for employers of health care providers. Prior to these changes, only hospitals, nursing homes, and health systems were subject to the mandatory reporting law. Now, all employers with employees/independent contractors/volunteers who are regulated by the Board of Physicians are subject to the mandatory reporting law. Expanded reporting now includes any person or entity that enters into an arrangement for professional services – paid or unpaid, contractual or as an employee – with an individual regulated by the Board. This may include primary schools, high schools, universities, urgent care facilities, telehealth companies, private health clinics, and staffing agencies.

The reporting requirements are not just about physicians and include all other health care providers who are regulated by the Board of Physicians including respiratory therapists, radiographers, sonographers, athletic trainers, perfusionists, naturopathic doctors, genetic counselors, and physician assistants.

The law clarifies that reporting includes any action that denies, restricts, limits, changes, removes, terminates, suspends, or places any conditions or restrictions on privileges or employment for reasons that might be grounds for disciplinary action as determined by the Maryland Board of Physicians. The Board of Physicians requires the report to be completed within ten days of the employer action.

As has been the case, the Board of Physicians may investigate and take action against any mandatory reporting entity that fails to file a mandatory report consistent with the regulations. If you have questions, reach out to an RKW attorney to learn more.

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