The Centers for Medicare & Medicaid Services is proposing that Medicare Advantage insurers verify and update their provider directories at least every 90 days. The proposal, announced October 16, would apply starting in contract year 2028, so it would not help anyone choosing a plan this fall.
Under the proposed rule, plans would also report a directory accuracy score to CMS, and members who rely on a wrong listing would be protected from a higher bill.
What the proposal would require of plans
The 90-day check is the core of it. Plans would have to confirm that the providers in their directories are still correctly listed, and update the entries that are out of date, at least once every 90 days instead of on whatever schedule each plan sets now.
Each plan would report an accuracy score to CMS, and the scores would be shown publicly on plans’ directories. CMS says the rule would also hold enrollees harmless: someone who relies on an inaccurate listing and ends up with an out-of-network provider would pay no more than the in-network cost-sharing amount.
CMS Administrator Dr. Mehmet Oz said, “CMS has been working to improve data connectivity and accuracy in provider directories across the healthcare system.” The release does not use the term “ghost networks,” the nickname for directories padded with doctors who are not actually available.
Why the date matters more than the rule
Anyone in a Medicare Advantage plan has until December 7 to switch, and that window is already open. The Open Enrollment Period runs October 15 to December 7, with new coverage starting January 1, provided the plan gets the request by December 7.
The CMS proposal comes too late for that decision. Members choosing a 2027 plan still have to depend on directories as they exist now, and the 90-day rule does not apply to them yet.
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How the rule ties to the 2026 spending law
The directory section is one of three that CMS is implementing from the Consolidated Appropriations Act, 2026, which was signed February 3. A CMS fact sheet on the proposed rule names them as sections 6219, 6220 and 6224.
Section 6220, the REAL Health Providers Act, covers the directories. It starts in contract year 2028 with verification standards, annual accuracy reporting and the cost-sharing protection. In contract year 2029, CMS would have to display the accuracy scores in a machine-readable format and plans would have to show them prominently in their directories.
Section 6219 changes Part D cost sharing. For full-benefit dual eligible people at or below 100 percent of the federal poverty level, the generic drug copayment would fall from $1 to $0 for plan years starting January 1, 2028.
Section 6224 targets pharmacy benefit managers, the middlemen who negotiate drug prices for Part D plans. They would face limits on payments tied to drug use, annual reporting on their compensation, and enforcement that includes giving money back to CMS for violations.
What happens next and what is still open
This is a proposal, not a final rule. The comment period lasts 60 days after the rule is published in the Federal Register, and CMS has not stated that publication date or the closing date for comments.
CMS also says it expects to release another proposed rule with policy and technical changes for Medicare Advantage and Part D later this fall. The final directory requirements could change after public comments, and CMS has not given dollar figures for what the changes would cost plans.
The CMS newsroom lists the announcement on October 16, and further steps on the rule will show up there.
Checking a doctor before December 7
People already in a Medicare Advantage plan get a second chance that is easy to overlook. The same Medicare page lists a Medicare Advantage Open Enrollment Period from January 1 to March 31, only for people already in a Medicare Advantage plan, with coverage starting the first of the month after the plan gets the request. It is a narrower fix, but it exists if a doctor turns out to be missing after the new year.
Medicare’s own guidance on plan provider networks says to confirm a doctor is in the plan when making an appointment, and to check that providers are in any plan being considered during Open Enrollment. Medicare says a plan should give at least 30 days’ notice when a provider that a member sees regularly is leaving.
The stakes differ by plan type. In an HMO, care from an out-of-network provider is usually not covered outside of emergencies and urgent care, while a PPO lets members see out-of-network providers at a usually higher cost. Anyone worried that a network change could interrupt care can call 1-800-MEDICARE.
The directory on a plan’s website is the starting point, but it is the plan that decides who is in network. A phone call to the doctor’s office asking whether they accept that exact 2027 plan, by name, closes the gap that a 90-day rule would eventually narrow.
Are the doctors on the 2027 plan list really in network?
A directory can list a doctor who left the network months ago, and the new CMS rule would not reach plan year 2027. A member who picks a plan on a wrong listing by December 7 can end up with a doctor who is out of network when care is needed.
The 2027 Medicare Open Enrollment Decision Kit includes a provider call script for confirming each doctor with the doctor’s office and the plan, plus the Open Enrollment calendar that keeps the dates in view. The kit’s Part 2 is a drug and doctor coverage check, built for this step.
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
