Update: On February 3, 2026, H.R. 7148, the “Consolidated Appropriations Act, 2026,” was signed into law. This legislation enacted the Requiring Enhanced and Accurate Lists of Health Providers Act (REAL Health Providers Act), which introduces new requirements for Medicare Advantage (MA) provider directory accuracy. These provisions address persistent challenges in keeping directories up to date and build upon existing regulations.
Beginning with plan year 2028, MA organizations must comply with updated regulations. Key changes include more frequent provider data verification, updated timelines for directory changes, and the implementation of both annual accuracy analyses and public accuracy scores.
New Medicare Advantage Provider Directory Accuracy Requirements
1. Verify Provider Data Every 90 Days
MA organizations must verify provider directory information at least every 90 days. This approach aligns with the No Surprises Act, standardizing practices across different health plans by requiring a continuous and proactive process for provider outreach and verification.
- For hospitals or other facilities identified as appropriate by the Health and Human Services (HHS) Secretary, verification may occur less frequently but must be conducted at least once every 12 months.
2. Indicate Unverified Providers in the Directory
If a provider’s information isn’t verified within 90 days, MA organizations must clearly indicate in the directory that the provider’s information may not be up to date.
3. Remove Non-Network Providers Within 5 Days
When it is determined that a provider is no longer participating in the network of such plan, MA organizations must remove that provider from the online and printed directory listings within five business days.
4. Expanded Provider Directory Information Criteria
At a minimum, MA organizations must validate, update, and include the following information in their directories:
- Provider Name
- Provider Specialty
- Provider Contact Information
- Primary Office or Facility Address Where Items and Services are Furnished
- Whether the Provider Is Accepting New Patients
- Accommodations for People with Disabilities
- Cultural And Linguistic Capabilities
- Telehealth Capabilities
Annual Provider Directory Accuracy Analysis and Reports
In addition to ongoing updates, MA organizations must conduct an annual analysis of their directory accuracy and report the findings to CMS.
1. Conduct Directory Accuracy Analysis
- Analyze the provider directory information for accuracy using a random sample of providers listed in the directory.
- The random sample shall include a random sample of each specialty of providers with a high inaccuracy rate of provider directory information relative to other specialties of providers, as determined by the Secretary of Health and Human Services (HHS). Examples cited of such specialties are mental health or substance use disorder treatment.
2. Submit a Report to HHS
Provide a report to the Secretary of HHS that includes:
- The results of the directory accuracy analysis, along with the accuracy score for the provider directory information.
- This score will be based on a verification method specified by the Secretary.
Public Display of Provider Directory Accuracy Scores
Starting with plan year 2029, MA plans must display their provider directory accuracy score prominently on their provider directories.
In addition, the HHS Secretary will publish the accuracy scores in a machine-readable file on a CMS-maintained website, increasing transparency for stakeholders and beneficiaries.
Upcoming CMS Guidance Updates
CMS will issue further guidance to clarify how plans will be expected to comply, methodologies for accuracy scoring, and additional operational requirements. We encourage you to stay informed by watching for updates as CMS provides more information. Additionally, we will continue to track these developments closely and provide insights and solutions to support your success.
Time to Prepare: How Quest Analytics Can Help MA Plans
With compliance deadlines just over the horizon, reliable solutions and processes are pivotal. Quest Enterprise Services® (QES®) Accuracy is the trusted solution that helps MA organizations address challenges related to provider network adequacy and directory accuracy.
How QES Accuracy Positions You for Success:
Streamlined Provider Outreach: Automate and improve data collection workflows.
Proactive Risk Management: Eliminate bottlenecks and inaccuracies, reducing the potential for penalties.
Analytics-Driven Insights: Apply dynamic analytics to improve data management and achieve higher directory accuracy scores.
Full-Service Support: From a dedicated Client Services team to compliance solutions, we help your organization thrive amidst regulatory change.
The new requirements are a turning point for provider directory accuracy regulations, driving transparency and reliability for stakeholders across the healthcare ecosystem. By starting preparation now, MA organizations can minimize disruption, meet new compliance standards confidently, and position themselves as leaders in the industry.
Contact us today to learn how we can help you navigate the changes ahead and achieve long-term success.
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