As we close out 2025, the first year of mandatory secret shopper surveys under the CMS Final Rule is behind us. With the 2026 cycle starting on January 1, now is the time to apply the hard-won lessons from the inaugural reporting year.
Reviewing the 2025 Access Reality: ATTAC’s Findings
The first year of mandatory reporting revealed significant operational hurdles for many issuers. Based on ATTAC’s analysis of survey data across the plans we supported, we identified these critical challenges:
High Friction Data Collection: Our data shows that organizations faced an average of 47% non-responsive and ineligible surveys. This volume of “dead ends” creates a massive drag on resources.
Resource Strain: The time required to complete necessary reserves and validate directory data proved higher than anticipated for most teams we worked with.
Meeting the Standard: Achieving the 90% Compliance Rate for appointment wait times remains the critical benchmark—and the hardest to hit without clean data.
What to Expect in 2026
The requirements are ongoing. CMS expects issuers to continue annual surveys beginning shortly after January 1. Additionally, be prepared for scope expansion. Specialty care providers are expected to be required in future plan years, potentially adding complexity to your future strategy.
Preparing for the New Year
Before the new survey window opens, ask your team:
- Did your 2025 data reveal gaps in your provider directory accuracy?
- Do you have a strategy to reduce the high non-response rates we observed across the industry?
- Do you have a vendor partner capable of meeting strict CMS requirements while delivering meaningful, actionable data?
Start 2026 Strong with ATTAC Consulting Group
Don’t let the same challenges from 2025 slow you down in 2026. Leveraging our proprietary insights and hands-on experience from the inaugural cycle, ATTAC’s Provider Network Management Team offers flexible, ongoing support to manage survey administration, provider education, and data validation.
Contact us today to discuss your 2026 Network Access strategy.
