Section 6220 of the Consolidated Appropriations Act, 2026, also known as the REAL Health Providers Act, is already signed into law. CMS and ONC held a public stakeholder meeting on it this month and are now collecting written comments directly by email, with new Medicare Advantage provider directory accuracy requirements set to begin in plan year 2028.
Key Dates
- May 19, 2026: CMS and ONC issue the public stakeholder meeting notice for Section 6220 implementation
- June 15, 2026: Public stakeholder meeting held virtually, recorded with a transcript
- June 29, 2026: Written comments due to Partnership@cms.hhs.gov
- Plan Year 2028: New Medicare Advantage provider directory accuracy requirements take effect
Directory Accuracy Touches More Than the Directory
Provider data problems don’t stay contained to the directory. Access issues touch clinical outcomes, member experience, grievances, and compliance exposure, the things a plan is actually measured and scored on.
What CMS Is Asking For
CMS is asking for input on data standards and source of truth, meaning what counts as authoritative provider data and where it should originate. This determines what plans will eventually be required to treat as the baseline for directory accuracy.
CMS also wants input on verification approaches and update cadence, including how often directories should be checked and how quickly non-participating or terminated providers should be removed once a plan knows they’re no longer in network.
A third area covers accuracy score methodology and sampling, how CMS should calculate and report a directory accuracy score, what sampling approach should be used to test directories at scale, and how transparent that methodology should be to plans and the public.
CMS is also seeking input on beneficiary cost-sharing protections, what should happen when a member relies on inaccurate directory information, and what notices plans should be required to send when an error is found or corrected.
The fifth area is burden reduction, how these new requirements can be built to work alongside the reporting and verification obligations plans already have, rather than adding a parallel set of compliance work.
Key
How to Submit a Comment
Written comments are due June 29 by email to Partnership@cms.hhs.gov, subject line “Section 6220 Provider Directory Meeting – Written Comment.”
If you work with provider data, network adequacy, network operations, or provider data management, this is the window to weigh in before the framework is set.
How ATTAC Can Help
ATTAC has worked alongside payers and providers on provider data management, network adequacy and access surveys, and network strategy for years across Medicare Advantage, Medicaid, and ACA lines of business. We’re putting together our own comments now, and we’re glad to talk through what we’re seeing if it’s useful as you build yours.
