The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would implement the Requiring Enhanced and Accurate Lists of (REAL) Health Providers Act, enacted as part of the Consolidated Appropriations Act, 2026.
The proposal would establish new requirements for certain Medicare Advantage (MA) plans intended to improve the accuracy and transparency of their provider directories and provide protections for beneficiaries who rely on inaccurate directory information.
MA provider directories are publicly available listings that help beneficiaries identify providers contracted with and participating in their MA plan's network, including information about their specialties, practice locations, and whether they are accepting new patients.
In reviews conducted from 2022 through 2024, CMS found that 44.29% of the provider directory location listings reviewed contained at least one inaccuracy. Among the specialties examined, ophthalmology had the lowest inaccuracy rate at 38.34%, compared with 45.73% for primary care, 45.67% for oncology, and 47.66% for cardiology.
Beginning in 2028, MA plans would be required to:
- Verify provider directory information at least every 90 days, update provider directories within 30 days of receiving new information, and remove providers within five business days of determining they are no longer participating in the plan's network.
- Identify provider information that cannot be verified with a notice indicating that the information may be outdated.
- Conduct annual assessments of provider directory accuracy and report their findings to CMS. Beginning in 2029, plans would be required to display their accuracy scores in their directories.
- Limit patients' cost sharing when they rely on inaccurate directories. If a provider was listed as in-network when an appointment was scheduled but was out-of-network when services were provided, the plan would be required to limit the patient's cost sharing for those services to the lower of the in-network or otherwise applicable amount, provided the services would otherwise be covered by the plan.
CMS is also proposing new requirements for MA plans to include provisions in their provider contracts that would obligate participating providers to:
- Maintain accurate and up-to-date provider directory information, including practice locations, contact information, and other required details.
- Provide documentation of the earliest date a patient's appointment was scheduled, when requested to determine whether the patient qualifies for protections against unexpected out-of-network costs.
The proposed rule also includes additional Medicare Part D reforms related to prescription drug cost sharing for certain low-income beneficiaries and new transparency and accountability requirements for pharmacy benefit managers.
The Academy will submit comments to CMS on or before the Dec. 15, 2026 deadline. We will continue to monitor for and provide updates, including when CMS issues the final rule.
