The executive order, “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Health Care Pricing Information,” has understandably created buzz in the health care industry. This policy directive builds upon the 2019 Executive Order 13877, “Improving Price and Quality Transparency in American Healthcare To Put Patients First,” and aims to further federal efforts towards enhancing data transparency, data quality, consumer choice, and supporting the implementation of the No Surprises Act. As stated in the order, “It is the policy of the United States to put patients first and ensure they have the information they need to make well-informed healthcare decisions.”
For those of you involved with health systems or health plans who may not typically engage with pricing information directly, it’s vital to understand the impact of this executive order, particularly regarding network adequacy and provider directory accuracy.
Key Takeaways from The 2025 Executive Order
The 2025 executive order calls for the Secretaries of the Treasury, Labor, and Health and Human Services to carry out specific actions by May 26, 2025. These actions include:
- Require the disclosure of the actual prices of items and services, not estimates.
- Issue updated guidance or proposed regulatory action ensuring pricing information is standardized and easily comparable across hospitals and health plans
- Issue guidance or proposed regulatory action updating enforcement policies designed to ensure compliance with the transparent reporting of complete, accurate, and meaningful data.
Impact on Network Adequacy and Provider Directory Accuracy
While the Executive Order focuses on healthcare price transparency, its implications on network adequacy and provider directory accuracy are profound. Zach Snyder, Vice President of Government Affairs at Quest Analytics®, highlights, “The focus of the Administration is on provider directory accuracy here, that is clear.” The renewed emphasis on enforcement and accountability could bring new compliance requirements and operational shifts for your organization.
As we move forward, Quest Analytics will closely monitor developments related to network adequacy and provider directory accuracy, particularly in light of the No Surprises Act, efforts to improve data quality, and increased access to de-identified claims data.
Advancing No Surprises Act Implementation
Central to the 2025 Executive Order is the advancement enforcing the No Surprises Act, particularly Section 116, which mandates that health plans actively reach out and verify the information of their healthcare providers. Current regulations require a structured approach to provider outreach, attestation, removal, and updates to provider directories every 90 days. Additionally, you must respond to member inquiries about a provider’s status within one day and update your provider directory within two business days upon learning of any provider changes.
While these processes may already be part of your workflow, we foresee the possibility of additional guidance and requirements. For instance, some regulators require outreach metrics and claims data as part of their provider directory accuracy reporting. Although it is unclear if similar requirements will be included in future updates to the No Surprises Act, it is advisable to stay informed and ready for any developments.
Improving Data Quality
As the Administration prioritizes data accuracy and cost reduction, the No Surprises Act and other federal regulations are expected to evolve to enhance data quality. These changes may involve new or amended regulations to incorporate additional provider data elements to improve the quality of the information you provide and manage.
Recent requirements for provider directory accuracy and audit trends focus on ensuring that the healthcare providers listed in the directory are actively seeing patients, accurately associated with the appropriate network, and indicating whether they are accepting new patients. The goal is not to gather more data but to achieve reliable, higher-quality data.
Increased Accessibility to De-Identified Claims Data
The Executive Order directs the expansion of access to de-identified claims data, making it available to researchers, innovators, providers, and entrepreneurs. The administration believes this will facilitate the development of tools that empower patients to make more informed decisions regarding healthcare goods and services.
From the perspective of Quest Analytics, this could mean that the Department of Health and Human Services (HHS) or the Centers for Medicare & Medicaid Services (CMS) may explore ways to incorporate claims data into network adequacy and provider directory requirements.
How to Prepare for Regulatory Updates
Given the potential for new regulatory requirements, adopting a proactive approach now will help you have a smooth transition in the future. Here’s how to start preparing for anticipated changes.
1. Evaluate Your Current Provider Data Accuracy Process
Start by evaluating your existing processes. What do they look like today? Which departments are involved?
Need help assessing your current processes? Use our Provider Directory Accuracy Assessment Toolkit for a step-by-step guide to assess and enhance your current processes. Download Now!
2. Engage Stakeholders
Bring together all relevant stakeholders. Share with them the emerging trends and foster a collaborative decision-making process. As a health plan, you must determine how to meet future regulatory requirements and enhance the accuracy of your data.
3. Integrate and Utilize Data
Consider the data sets that you currently use. How are you integrating data sources? Are you leveraging reliable claims data effectively? How can you integrate additional data elements to comply with the provider directory requirements?
4. Audit Provider Data
Conduct an audit of your provider data. Identify who has attested to their data in the last 90 days and who hasn’t. Identify providers listed at more than 10 locations.
By taking these steps, you can help your organization be prepared for regulatory changes.
Looking Ahead
The directives laid out in the Executive Order reflect the Administration’s pursuit of a modern-day, data-driven, transparent, and patient-first healthcare industry. To thrive in this environment, leveraging intelligent data platforms, establishing reliable processes for compliance and provider attestation, and employing automated data management systems are key. Discover how Quest Enterprise Services® (QES®) Accuracy can support you in these endeavors, and start transforming your healthcare delivery model today.
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