The Centers for Medicare & Medicaid Services (CMS) is moving forward with two related efforts to improve the accuracy and availability of provider information: implementing new Medicare Advantage provider directory requirements and developing a National Provider Directory intended to serve as a standardized source of information across the healthcare system.
On October 20, CMS published a proposed rule implementing the Requiring Enhanced and Accurate Lists of (REAL) Health Providers Act, which was enacted in February as part of the Consolidated Appropriations Act, 2026. Beginning in 2028, the law will require Medicare Advantage organizations to verify provider information more frequently, measure directory accuracy, and provide additional protections to beneficiaries who rely on incorrect listings.
The proposed rule also addresses how these requirements could complement CMS’s efforts to modernize provider information systems, including Medicare Plan Finder and the developing National Provider Directory (NPD). It acknowledges an important question: who is responsible for the accuracy of provider information when a national system modifies data originally submitted by health plans?
Addressing Persistent Problems with Provider Directories
Accurate provider directories help beneficiaries select health plans, find clinicians, and determine whether services will be covered at in-network rates. Yet federal reviews have repeatedly identified problems with the information Medicare Advantage organizations make available.
In the proposed rule, CMS reports that reviews conducted between 2022 and 2024 found at least one inaccuracy at 44.29% of the provider locations examined. The agency has not published those reviews separately. Errors can include incorrect contact information, inaccurate addresses, and providers listed as participating in networks when they are not.
Beginning with contract year 2028, Medicare Advantage organizations generally must verify provider directory information at least every 90 days, although certain facilities are subject to a 12-month verification interval. Listings that have not been verified within the required period must indicate that the information “may not be up to date.” Plans must also remove providers determined to be no longer participating in their networks within five business days of that determination.
The REAL Act requires annual assessments of directory accuracy using random samples. CMS proposes a standardized scoring methodology that would assign letter grades based on several measures, with network participation accounting for 40% of the overall score.
As proposed, 35% of each accuracy sample would consist of mental health and substance use disorder treatment providers, currently the only specialty group CMS designates as having high directory inaccuracy rates. CMS is seeking comments on whether additional specialties should be included.
Under the proposed schedule, plans would submit their first accuracy reports in April 2029, based on 2028 data. CMS would begin publishing scores in 2029, and Medicare Advantage organizations would be required to display their scores prominently in their directories.
The legislation also provides financial protections for beneficiaries who rely on inaccurate directory information. If a provider was listed as in-network when a beneficiary made an appointment but is out of network when care is furnished, cost sharing would be limited to the lesser of the in-network amount or the amount that would otherwise apply. Under the proposal, the plan would bear the burden of demonstrating that the provider was not listed when the appointment was made. If it cannot produce the necessary records, the protection would apply in the beneficiary’s favor.
CMS is also proposing requirements beyond those specified in the REAL Act, including a 10-year archive capable of showing whether a provider was listed on any given date and provisions in provider contracts requiring accurate directory information and records of appointment dates.
Building a National Source of Provider Information
While REAL focuses on Medicare Advantage organizations, CMS is pursuing a broader initiative intended to improve the information on which provider directories depend.
CMS’s National Provider Directory, currently in preview release, allows users to search for providers, lets providers view and update their own records, and offers data downloads and Fast Healthcare Interoperability Resources (FHIR) API testing for developers. CMS notes on the site that directory data is integrated from multiple sources and refreshed on variable schedules, and that some records may not reflect the most recent updates.
The initiative builds on existing federal provider information systems, including the National Plan and Provider Enumeration System (NPPES), which maintains National Provider Identifier records. However, identifying a provider is not the same as establishing where that provider practices, which health plans the provider accepts, or whether the provider is available to see patients.
The proposed rule lists CMS-maintained data sources, including NPPES and the NPD, among acceptable methods for routine provider information verification. CMS indicates that plans might be able to use the NPD for this purpose once it is fully operational. The agency has not yet approved any CMS-maintained source for calculating the elements of the annual accuracy score.
Recent contracting activity provides another indication that the initiative is moving beyond planning. In September, healthcare data company H1 announced that CMS had selected it to provide data sourcing and licensing, aggregation, and quality assurance services for the NPD. The work includes licensing provider information from outside sources and evaluating data for errors and gaps.
Who Is Responsible When Provider Data Changes?
CMS already requires Medicare Advantage organizations to submit provider directory information for publication through Medicare Plan Finder, the federal tool beneficiaries use to compare coverage options. Existing requirements also direct organizations to update submitted information within 30 days of learning of changes and attest to its accuracy at least annually.
The proposed rule notes that information collected from Medicare Advantage organizations is expected to be compatible with the NPD and may ultimately feed into the national system.
Questions about reconciling information from different sources are already relevant to Medicare Plan Finder. Under procedures described in a May 2026 CMS testing memorandum, the agency checks National Provider Identifiers, provider names, and provider types against NPPES, and where plan-submitted information conflicts, Plan Finder displays the NPPES values. In a September office-hours Q&A, CMS indicated that it does not proactively notify plans when NPPES information replaces submitted values, although validation reports may identify such substitutions.
The proposed rule anticipates a potentially more complex exchange of information involving the NPD. CMS describes a possible process in which Medicare Advantage organizations submit provider information, the NPD could incorporate and supplement that information using additional sources, and plans subsequently publish directories informed by the national system.
CMS expressly acknowledges that this arrangement could raise questions about responsibility for directory accuracy.
Under the proposed approach, Medicare Advantage organizations would remain accountable for the information they submit, verify, and attest to, as well as the rigor of their verification procedures, rather than information added or modified by the NPD from sources outside their control. Plans would retain an independent obligation to verify directory information on the required schedule.
CMS anticipates developing a process that would allow plans to reconcile discrepancies between their verified records and information returned by the NPD before publication.
The agency says it will provide further guidance on how accountability is divided between plan-originated and NPD-enriched information. That guidance could include a safe harbor as the NPD develops the capability to accept validated data programmatically from healthcare providers and organizations. CMS is seeking comments on how such a technology-based approach might work.
Accuracy Is One Part of Access
Improving provider directories could make it easier for beneficiaries to identify clinicians who participate in their health plans and reduce the likelihood of unexpected out-of-network costs.
However, directory accuracy and access to appointments are not identical measures. A provider may be correctly identified as participating in a network but may not be accepting new patients or have appointments available within a reasonable period.
A 2023 Senate Finance Committee secret-shopper review of Medicare Advantage mental health directories found that approximately one-third of listings were inaccurate or unreachable, and investigators obtained appointments in only 18% of attempts. Even a fully accurate directory would address only part of that gap.
The findings help explain the concern about so-called ghost networks, in which provider directories may suggest access to clinicians who cannot be reached or are unavailable to deliver the services beneficiaries seek.
The REAL Act’s verification and public reporting requirements establish additional accountability for the accuracy of published information. Whether those improvements translate into more reliable access to care will depend on the quality of the underlying data and how the information is maintained and used.
Next Steps
CMS is accepting comments on the proposed rule through December 15. The rule also addresses provisions of the Consolidated Appropriations Act, 2026, concerning Medicare Part D cost sharing for certain low-income beneficiaries and pharmacy benefit manager compensation.
The REAL Act requirements are scheduled to begin in 2028, with public reporting of directory accuracy scores beginning in 2029. Meanwhile, development of the National Provider Directory continues.
