A patient with a new Medicare Advantage card calls the number listed for your cardiology group. It rings at a suite the practice vacated sixteen months ago. The next name is a nephrologist filed under cardiology. The third answers, and the scheduler says that physician stopped taking new patients last spring.
The patient calls a competitor and books the appointment. Nobody in your organization ever learns what happened.
A CMS national review of Medicare Advantage directories found that 48.74% of provider locations carried at least one inaccuracy: wrong phone, wrong address, or outdated patient acceptance status. The industry spends more than $2 billion a year maintaining that data.
Wes manages provider data for a 600-physician group. Every month he sends a roster file to fourteen payers. Four confirm receipt. One returns a usable error report. He finds out whether the rest landed when an office manager calls him, angry, because patients can't reach her physician. Or worse, because the only number that does reach him is the personal cell he gave a scheduler once, now published in a payer directory nobody at the practice has ever looked at.
Wes isn't failing. He's doing the job as designed, which is to verify the data, transmit the file, and hope the payer holds up its end.
The rules he can't enforce
The No Surprises Act requires plans to verify directory data every 90 days, process updates within two business days of receipt, and respond to inquiries within one business day, with penalties reaching $100 per day per affected individual. That's a real standard, but enforcement runs between the plan and a regulator. Wes isn't a party to it.
Under the CY 2026 Final Rule, MA organizations must submit directory data to CMS for Medicare Plan Finder and annually attest to its accuracy. The plan certifies a data set built from your roster. You don't see the filing and you don't approve it, and when it's wrong your patients absorb the access failure while you absorb the volume loss.
The rules nobody in your building wrote
Ask who owns the provider directory and count the answers. Credentialing owns verification. Medical staff services owns the file. Marketing owns the website. IT owns the transmission. Payer Relations owns the contract that never mentions any of it.
That's not an oversight. It's the decision made by not consciously making one, and it holds because provider data errors have never cost enough, visibly enough, to earn an owner.
What to do
Name one owner of the roster of record. If the answer takes more than four words, you don't have one.
Audit the directory the way a patient uses it. The provider portal usually looks fine. The public directory is what directs the patient. Quarterly, per payer.
Pull your roster of record for one TIN.
Pull the payer's public-facing directory for that same TIN. The public site, not the portal.
Compare five fields: name and NPI, service location, accepting-new-patients status, specialty and subspecialty, and a phone number that reaches a live scheduler.
Score it. Discrepancy rate by field and by payer, with screenshots and date stamps.
Send it to the plan's provider data team in writing with a correction deadline, and log their response against the two-business-day standard.
The window
Your payers are about to be graded in public on data you supply. Beginning with the 2027 plan year, CMS publishes MA directories directly to Medicare Plan Finder. Beginning with 2028, the REAL Health Providers Act adds annual accuracy analyses and public accuracy scores.
Pull one payer's public directory for one TIN this week and check five fields. Whatever you find is your baseline. Run it again next quarter, and the quarter after that.
Walk into your next renewal with four quarters of scored discrepancies and the plan's provider data director takes your call. Walk in with nothing and you'll be handed someone else's remediation plan, built to fix their score rather than your access problem.
Nobody negotiates the directory because nobody files it under contracting. Your patients never read the contract. They read the directory.
About the Author
Kevin W. Barron, MBA, FHFMA, FACHE is a nationally recognized healthcare contracting and payer relations executive with over 30 years of experience in healthcare finance. He is an author, speaker, and mentor to emerging leaders in healthcare finance. Follow Kevin on LinkedIn or subscribe to his weekly newsletter at https://www.KevinWatsonBarron.com
Disclaimer: This article is provided for general informational and educational purposes only. It reflects my personal views and observations based on professional experience in healthcare finance, managed care, payer relations, and revenue cycle operations. It should not be interpreted as legal, financial, regulatory, actuarial, or reimbursement advice. The content is not intended to represent the official position of my employer, any payer, provider, professional association, or other organization with which I may be affiliated. Readers should consult their own legal, financial, compliance, actuarial, or operational advisors before making decisions based on the issues discussed. Any references to payers, providers, regulations, market trends, or reimbursement practices are intended for discussion and education only and should not be construed as a statement about any specific contract, negotiation, patient matter, or confidential business arrangement.