FAQs and Provider Directory Requirements: Key Tips and Targets

One of the top questions health insurers have asked us lately is: Will I still need to have a provider directory verification process in place by January 1, 2022?

Simply put, yes.

In this blog, we’re highlighting the essential points you need to know about the FAQs and provider directory requirements.

FAQs About the Provider Directory Requirements

Protecting Patients and Improving the Accuracy of Provider Directory Information

On August 20, 2021, the Departments1 released the FAQs which stated while regulations may not be issued until after January 1, 2022, health plans and providers are still expected to implement these new processes on January 1, 2022, and apply a good faith, reasonable interpretation of the statute – make the effort. Read our overview on the FAQs.

“Good faith compliance” means plans and issuers must honor cost-sharing that would apply as if the service or item was furnished by a participating provider if a member is provided inaccurate information by the plan or issuer under either the displayed provider directory or through information provided in response to a request from the individual about a provider’s network participation status.

Tip: Don’t stop. Complete your process during this time.

The new guidance doesn’t delay the need to design and implement the new standards for provider directory accuracy as contained in the Consolidated Appropriations Act (CAA). The focus is on having those policies, protocols, and procedures in place between now and January 1, 2022. Health plans and providers should be well underway in taking proactive actions now to meet January 1, 2022, deadline. That way, over time we can begin the process of improving the overall accuracy of our public-facing, member-facing provider directories.

“In our conversations with regulators, the tone is, when – not if,” Scott Westover, SVP Network and Regulatory Strategy, Quest Analytics

Hear the full Regulatory Review from Scott Westover below. 

Target: Say Yes to Regulators

The expectation is that health plans and providers are using this time to be ready for that enforcement. According to Scott Westover, health plans will want to be ready to demonstrate that they have a process in place and be able to say:

1. Yes, we have a process for outreach and attestation.
2. Yes, we can comply with the updates to provider information.
3. Yes, we can be responsive in the time required for

→getting back to our members who raise an issue

→our providers who change their data

→changing our provider directory in that 2-business day timeline

Hear the full Regulatory Review from Scott Westover.


Recommended Resources

Surprise Bill Resource Center

Find more information, guides, videos, and tools to help you meet deadlines on our Surprise Bill Resource Center.





Provider network adequacy analysis with a composite score of 61.6. Learn how we can assist your efforts to make your provider data accurate and network adequate. Book a complimentary strategy session with a Quest Analytics expert to get started on your quest for success.



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  1. The Departments – collectively, the Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Treasury