CMS targets Medicare Advantage ghost networks. Fix your provider data now

A new CMS proposal would force Medicare Advantage plans to keep provider directories accurate, and hospitals will feel it in their contracts, their data teams and possibly their collections.

What CMS proposed

On Oct. 16, CMS released a proposed rule that carries out Medicare Advantage and Part D provisions of the Consolidated Appropriations Act, 2026. The headline item for providers is a crackdown on inaccurate MA provider directories, often called ghost networks.

Under the proposal, MA plans would have to verify and update directory listings at least every 90 days for most providers. Acute inpatient hospitals, critical care and surgical services would be checked every 12 months. Plans would report accuracy scores to CMS, and starting in 2029 those scores would be posted publicly and displayed in plan directories. Most requirements would begin in contract year 2028. Comments are due Dec. 15.

The cost-sharing shift

The provision with the most financial weight is a new enrollee protection. If a member books care with a provider the plan listed as in-network, and that listing turns out to be wrong, the member would pay no more than in-network cost sharing. According to HFMA’s review, the proposal does not spell out how the plan and the provider would settle payment in that situation.

That gap matters. Out-of-network hospitals and physician groups that see these patients could face disputes over who absorbs the difference. Health systems should expect plans to look for ways to push that risk back onto providers through contract terms.

New contract language is coming

The proposal would also require MA plans to write into provider contracts an obligation to document the earliest appointment date a patient was offered, even if the visit is later rescheduled. HFMA reports that this obligation would have to survive at least 10 years after a contract ends. Plans would also keep daily directory archives for a decade.

For hospitals and employed medical groups, this means more data requests, more record-keeping and a longer audit tail. Systems that already struggle to keep physician rosters, locations and accepting-new-patient status current across dozens of payers will need cleaner processes.

What leaders should do now

• Assign an owner for provider data accuracy across all payer directories, with a defined update cadence.
• Review MA contracts coming up for renewal in 2027 for directory, appointment-date and liability clauses.
• Model exposure from patients sent to your facilities through incorrect listings, especially if you are out of network with major MA plans.
• Comment by Dec. 15, directly or through your state hospital association, on how payment should be settled when directories are wrong.

Sources

• CMS Proposes Reforms to Strengthen Transparency and Affordability in Medicare Advantage and Part D (CMS, Oct 16, 2026)
• CMS proposes Medicare Advantage provider directory requirements for 2028 (HFMA, Oct 19, 2026)
• Health Care Week in Review (Alston & Bird, Oct 16, 2026)
• CMS Issues Proposed Transparency and Affordability Reforms in Medicare Advantage and Part D (Missouri Hospital Association, Oct 19, 2026)