On September 19, the Centers for Medicare and Medicaid Services (CMS) released a final rule modifying Medicare Advantage (MA) disclosure requirements. The final rule, officially titled Medicare and Medicaid Programs; Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (PACE)-Finalization of Format Provider Directories for Medicare Plan Finder, implements changes specifically to MA provider directories.
What’s the Impetus for the Rule?
Goals behind the rule include:
Addressing “Ghost Networks” and Enhancing Beneficiary Choice
CMS aims to crack down on ghost networks in provider directories. Plans create ghost networks by listing doctors in a plan’s directory unavailable for patients. This is a widespread issue, as studies and investigations have found that a meaningful number of providers listed in plan directories are inaccurate or outdated.
The primary purpose of the final rule is to enhance the plan comparison process and promote informed beneficiary choice by increasing beneficiaries’ access to provider data. CMS sees the comprehensiveness and accuracy of a plan’s provider network as a vital piece of information for consumers selecting coverage.
The Problem with the Existing Process
CMS previously implemented the Medicare Plan Finder (MPF) tool and required MA organizations to maintain their own provider directories. However, the existing process was cumbersome for beneficiaries.
- Medicare Plan Finder (MPF) – MPF is an online resource where beneficiaries can explore coverage options, including plan benefits, premiums, deductibles, and Star Ratings. However, MPF does not currently include information on contracted provider networks for each plan.
- Plan Websites – CMS requires MA organizations to disclose certain information, including provider directories, on their websites.
- Cumbersome Comparison – To determine if their providers were in-network across various plan choices, prospective and current MA plan enrollees had to toggle between different MA plan websites and MPF. A central repository of provider directory information did not exist. As a result, it was difficult for beneficiaries to compare networks among various MA plan choices.
The final rule seeks to simplify and streamline the Medicare beneficiary shopping experience. It does so by requiring MA plans to submit this data directly to CMS for display on MPF.
What’s the regulatory history of the final rule?
The Biden administration originally proposed the policy in the December 2024 proposed rule (89 FR 99340). This rule proposed changes to leverage technological methods to streamline the beneficiary experience and make the MA provider directory data viewable on MPF.
CMS finalized some December 2024 proposed provisions in April 2025, but noted that remaining items, including provider directory requirements, may be addressed in future rulemaking. The Trump administration finalized the provider directory requirement in a separate rule (CMS 4208-F2). CMS issued the provider directory requirement through a separate final rule to give MA plans “maximum lead time” to integrate their directories into Medicare Plan Finder (MPF) ahead of the 2027 open enrollment.
This rule is separate from CMS’s interim plan that leverages third-party vendor data for the 2026 MPF. MA plan-sourced data will replace the interim solution for 2027.
The goal of the finalized requirement is to advance informed beneficiary choice and transparency by empowering people with Medicare to make informed choices about their coverage.
The regulations take effect on November 17, 2025, and are applicable to MA organizations for plan years beginning on or after January 1, 2026. The data collected under this rule will enhance the 2027 shopping and plan comparison experience on the MPF.
The final rule established several new requirements for Medicare Advantage organizations at 42 CFR 422.111(m):
What requirements did the rule finalize?
For plan years beginning on or after January 1, 2026, MA organizations must:
- Make Provider Information Available to CMS. MA organizations must make the required provider directory information (described in § 422.111(b)(3)(i)) available to CMS for publication online, following guidance from CMS.
- Submit in a Specific Format. Organizations must submit or otherwise make available their plan provider directory data to CMS. That data will be in a format, manner and at times determined by CMS.
- Update Data Regularly. Organizations must update the provider directory information submitted to CMS within 30 days of the date they become aware of a change.
- Attest to Accuracy. Organizations must attest at least annually (in a format and manner determined by CMS) that all information submitted or made available is accurate.
Provisions Not Finalized
CMS modified the proposed attestation requirement. The final rule did not finalize the portion that would have required MA organizations to attest that their provider directory data is consistent with data submitted to comply with CMS’s MA network adequacy requirements. CMS determined it was more appropriate to distinguish provider directory accuracy and network adequacy. It noted that MA organizations already attest to an adequate network for specific provider or facility types.
Implementation and Timing
CMS clarified that the final rule is independent of CMS’s interim plan to populate the 2026 Medicare Plan Finder with provider directory information supplied by third-party vendors. The MA plan-sourced provider directory data required by this regulation will replace that interim third-party solution for the Contract Year 2027 MPF.
Although MA organizations must make the directory data available to CMS by January 1, 2026, the data will not be immediately populated in the MPF for public use. CMS intends to conduct a testing period, During that testing period, CMS will ensure the directory data accurately reflects the data provided by MA organizations. Then, CMS will release the data for 2027 Medicare Plan Finder. CMS also plans to issue an operational guide for the final rule. The guide will deliver technical specifications and timing milestones. CMS will design it so plans can prepare data and comply with the new requirements.
What is the financial impact of the rule?
The rule is expected to result in a financial benefit for MPF users. That manifests as time saved by not having to visit multiple MA organization websites to compare provider directories. CMS estimated that amount at over $49 million annually.
The regulatory changes are associated with implementation costs for MA organizations, including:
- A one-time burden of $558,096 for programming. This programming provides CMS access to the provider directory data (estimated at 8 hours per plan for 700 plans).
- An annual burden of $176,974 for the attestation requirement (estimated at 1 hour per plan for 700 plans).
- The overall estimated annual paperwork burden is $500,000.
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