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Bill

SF 2104

Data on fully denied claims requirement to be submitted to the all-payer claims database

2025-2026 Regular Session Introduced by Liz Boldon and 2 co-sponsors

Requires health insurers to report fully denied insurance claims to Minnesota's all-payer claims database, expanding transparency of claim rejections statewide.

Referred to Health and Human Services
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Bill Summary · SF 2104

Legislative bill overview

SF 2104 requires health insurance carriers to submit data on fully denied claims to Minnesota's all-payer claims database (APCD). Currently, the database captures approved and partially denied claims, but fully denied claims are excluded. This bill would mandate the inclusion of complete denial information in the state's centralized health care claims repository.

Why is this important

Fully denied claims represent a significant but invisible portion of health care utilization and costs. Including this data would give policymakers, researchers, and regulators a more complete picture of insurance coverage patterns, potential access barriers, and which treatments or services are being systematically rejected. This transparency can inform decisions about coverage standards, identify disparities in claim denials, and help detect potentially inappropriate denial patterns.

Potential points of contention

  • Insurance industry burden: Carriers may argue that submitting additional data creates compliance costs and administrative overhead, particularly for smaller insurers
  • Patient privacy concerns: Fully denied claims contain sensitive health information; expanding APCD scope raises questions about data security, de-identification standards, and appropriate access controls
  • Data interpretation challenges: Denied claims lack context about medical necessity determinations; policymakers may misinterpret denial patterns without understanding clinical reasoning behind decisions

Compiled from official sources — confirm details with the bill’s official record.

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