ANNAPOLIS, Md. - Maryland's highest court on Sept. 30 held that a health maintenance organization (HMO) member who has been billed by a health care provider for a covered service does not have an implied private cause of action under Maryland Code, Health-General Article, Section 19-710(p), but is not precluded from bringing an action under the state's Consumer Protection Act (David Scull, et al. v. Groover, Christie & Merritt, No. 71, Md. App.; 2013 Md. LEXIS 609).