A patient walks into your office with a Medicare Advantage card in her hand. She found your practice in her plan’s online directory, so she booked a visit. But your office moved across town last spring. Or your doctors stopped accepting new patients months ago. Now she feels frustrated, and your front desk spends the morning apologizing.
Sound familiar? Directory errors cause headaches for patients and practices alike. Now CMS wants to tackle the problem.
On October 20, 2026, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule, CMS-4214-P, in the Federal Register. The proposed Medicare Advantage provider directory rule would require plans to verify their listings more frequently and report how accurate those listings are. These changes could also affect your practice.
Let’s walk through what CMS proposed, when the requirements could take effect, and how your team can prepare.
One important reminder: This is a proposed rule, not a finalized regulation. If CMS finalizes it, the new requirements would take effect beginning in contract year 2028. Practices should not treat these proposed requirements as current law.
What CMS Proposed
The proposal implements Sections 6219, 6220, and 6224 of the Consolidated Appropriations Act, 2026,which became law on February 3, 2026. Among these provisions, Section 6220, known as the REAL Health Providers Act, focuses on improving Medicare Advantage provider directory accuracy.
The proposed rule would establish several new requirements for Medicare Advantage (MA) organizations. CMS proposes to:
Verify provider listings regularly. MA organizations would verify provider directory information at least once every 90 days. Hospitals and certain facilities would have a longer verification interval of at least once every 12 months.
Remove departed providers quickly. Plans would remove providers from their directories within five business days after determining that those providers are no longer participating in their networks.
Report provider directory accuracy. Plans would conduct annual accuracy analyses using samples of their provider listings and report their accuracy scores to CMS.
Protect patients from unexpected costs. If an enrollee schedules an appointment with a provider listed as in-network in the plan’s directory but later receives covered services from that provider after the provider has left the network, the proposed rule would limit the enrollee’s cost-sharing responsibility to the lesser of the in-network amount or the otherwise applicable cost-sharing amount, subject to the proposal’s conditions.
Why the push? CMS points to a significant problem. During three rounds of online directory reviews conducted between June 2022 and June 2024, the agency examined 11,360 providers and 18,852 locations across Medicare Advantage organizations. It found that 44.29 percent of the location listings contained at least one inaccuracy.
These inaccuracies included incorrect addresses and phone numbers, as well as listings that incorrectly indicated a provider was available at a particular location or participating in a plan’s network.
In other words, more than four in ten reviewed location listings had at least one inaccuracy. The proposed rule aims to address these problems and help patients find accurate information when choosing healthcare providers.
The Timeline, If Finalized
CMS would not implement these proposed requirements overnight. Here is the expected schedule:
- October 20, 2026: CMS published the proposed rule in the Federal Register.
- December 15, 2026: Public comments are due by 5 p.m. Eastern Standard Time.
- Contract year 2028: If finalized, the proposed directory verification, removal, accuracy reporting, and patient cost-sharing protection requirements would begin.
- Contract year 2029: CMS would make provider directory accuracy scores publicly available in a machine-readable format, and plans would display their scores in their provider directories.
Notice the words “if finalized.” CMS will review public comments before issuing a final rule. The agency may revise some provisions before finalization.
Until then, the proposed 2028 requirements are not current regulatory obligations. However, Medicare Advantage plans already have existing provider directory responsibilities, including updating information submitted to CMS/HHS within 30 days of becoming aware of a change and attesting to its accuracy at least annually. The proposed rule would build on these existing requirements.
Want to weigh in? Healthcare practices and other interested stakeholders can submit comments by December 15, 2026. Use file code CMS-4214-P and follow the submission instructions in the Federal Register notice. Feedback from healthcare providers, practice managers, and administrative teams could help CMS shape the final requirements.
Why Your Practice Should Care
The proposed rule places its primary regulatory duties on Medicare Advantage organizations, not directly on individual healthcare practices. So why should your practice pay attention?
Because plans need accurate information from their participating providers to meet their proposed verification and reporting responsibilities.
If CMS finalizes the rule, practices can expect more frequent requests to confirm information such as:
- Practice addresses and suite numbers
- Contact numbers and office hours
- Provider availability and network participation
- Whether providers are accepting new patients
- Changes in practice locations or services
There is another important consideration. CMS proposes requiring Medicare Advantage organizations to include contractual provisions obligating participating providers to maintain current and accurate directory information. Although the new verification and reporting requirements would fall on the plans, healthcare practices could have additional contractual responsibilities if the proposal becomes final.
Reviewing existing payer agreements and establishing a reliable process for reporting changes can help your practice prepare.
Public accuracy scores could also create additional pressure for plans to keep their directories current. Under the proposal, patients and plan shoppers would eventually be able to see how accurately a Medicare Advantage plan maintains its provider listings. Plans with lower accuracy scores may have greater incentives to work with providers to correct outdated information. This is a potential operational impact, not a guaranteed outcome.
Patients stand to benefit, too. More accurate phone numbers and addresses mean fewer wasted trips, fewer scheduling frustrations, and fewer unexpected out-of-network expenses. Your administrative team may also spend less time resolving avoidable directory-related issues.
Get Ready Now
You do not need to wait for CMS to finalize the proposed rule before improving your directory management practices. Accurate provider information already matters to patients who rely on online directories to find healthcare services.
Here are some practical steps your team can take:
Pick one owner. Assign one person, such as your practice manager, to oversee provider directory information. Having a designated owner creates a consistent process for tracking updates and communicating changes to health plans.
Check every location. Review the addresses, suite numbers, and phone numbers associated with each provider. Include satellite offices and other practice locations.
Update your hours. Make sure the operating hours reported to health plans match the hours posted on your website and office entrance.
Keep new-patient status current. Notify health plans when providers begin or stop accepting new patients. This helps prevent patients from scheduling appointments based on outdated availability information.
Set a 90-day reminder. A quarterly internal review would help your practice prepare for the verification frequency CMS proposes.
Keep a simple log. Document when you confirmed your information with each health plan, what details you reviewed, and when you submitted updates.
Start with your most-used plans. Send each Medicare Advantage plan a clean, updated copy of your practice information. Establish a routine for reviewing and confirming these details regularly.
Taking these steps now can help your practice prepare if CMS finalizes the proposed requirements for 2028. Even if the final rule changes, maintaining accurate provider information can improve patient experiences and make administrative operations more efficient.
Build Habits That Last
Compliance goes more smoothly when your entire team follows the same processes. American Medical Compliance (AMC) offers online compliance training and resources for healthcare providers, including practice managers responsible for keeping daily operations organized and compliant.
Our resources help healthcare teams strengthen compliance practices, improve operational efficiency, and build greater trust with patients and partners.
Enroll your large team in our customized, free course development program today. Build training around your practice’s specific needs and help your employees develop the knowledge and skills to support your organization’s compliance goals.
Sources:
- Federal Register, Vol. 91, No. 201 (October 20, 2026), FR Doc. 2026-21420, CMS-4214-P.
- CMS Fact Sheet: Medicare Program; Implementation of Sections 6219, 6220, and 6224 of the Consolidated Appropriations Act, 2026.
