Last week, the Medicare Rights Center submitted comments to help guide implementation of the Requiring Enhanced and Accurate Lists of Health Providers Act (REAL Health Providers Act). This law, which goes into effect in 2028, requires Medicare Advantage (MA) plans to maintain complete and accurate provider directories.
Inaccurate Directories Are a Longstanding Problem
MA provider directories are wildly inaccurate and have been for years. For example, in 2018, the Centers for Medicare & Medicaid Services (CMS) found that 52% of provider locations listed in directories were inaccurate.
MA provider directories are wildly inaccurate and have been for years.
Accurate locations are important, but the problem goes deeper. Some plans have “ghost networks” that look more robust than they are because the underlying plan directories list providers who are not in the plan, no longer practicing, or not accepting new patients. This is especially concerning when it comes to behavioral health.
In advance of a 2023 Senate Finance Committee hearing on mental health care directories, committee staff conducted secret shopping investigations and demonstrated how inaccurate provider directories could keep enrollees from scheduling appointments: “Staff reviewed directories from 12 different plans in a total of 6 states, calling 10 systematically selected providers from each plan, for a total of 120 calls. Of the total 120 provider listings contacted by phone, 33% were inaccurate, non-working numbers, or unreturned calls. Staff could only make appointments 18% of the time.”
Committee staff demonstrated how inaccurate provider directories could keep enrollees from scheduling appointments.
Enrollees May Not Get Timely Help
When enrollees can’t access the care they need inside the plan’s network, they may experience harmful delays and extreme costs. Some may not be able to find an in-network provider in a timely manner or at all. Those who do go out of the network may not realize it comes with extra cost. All affected enrollees may be forced to fight with their plan to get coverage for their care. Such access barriers can lead to higher acuity and more expensive care needs, including hospitalizations and emergency room visits.
When enrollees can’t access the care they need inside the plan’s network, they may experience harmful delays and extreme costs.
The REAL Health Providers Act
Earlier this year, Congress passed and President Trump signed HR 7148, the Consolidated Appropriations Act of 2026. That bill included the REAL Health Providers Act which will require MA plans to submit and maintain accurate provider directories and to protect beneficiaries who rely on inaccurate directories from being charged extra for getting care from non-network providers.
Focus on Accuracy, Accountability, and Accessibility
CMS and the Office of the National Coordinator for Health Information Technology (ONC) invited comments on implementation of REAL, specifically seeking information about data sources, verification, and accuracy, and beneficiary cost-sharing protection and notices.
Medicare Rights focused on getting this information to current or potential MA enrollees.
In our comments, Medicare Rights focused on getting this information to current or potential MA enrollees to ensure that they get up-to-date information for better plan choices and have easy ways to provide feedback or request remediation if they rely on inaccurate listings.
Implementation Is Key
A statutory framework requiring accurate directories is important, but how CMS and ONC implement this law will largely determine how effective and useful it is for people with Medicare.
At Medicare Rights, we will continue to urge the administration and Congress to prioritize Medicare beneficiaries and make navigation within the program more seamless while holding plans accountable for access-to-care barriers.
Read our comments here.
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