Key Insight
The enhanced MA Plan Finder marks a new era in healthcare transparency. For payers, it’s a challenge and an opportunity: to clean up provider data, align APIs and submissions, and prepare for a future where network data supports compliance and competition. Ultimately, it is an opportunity for providers, payers, and the government to play a role in aggregating accurate, complete, and usable directory data to empower patient choice.
On September 19, 2025, CMS issued a Final Rule requiring Medicare Advantage (MA) plans to submit provider directory data to CMS in a standard format, regularly update it, and attest to its accuracy. The data is to be loaded into MA Plan Finder, giving beneficiaries the ability to compare plans based on their provider networks.
Until now, MA Plan Finder helped beneficiaries compare plans using saved drug and pharmacy information, but the tool lacked a key ingredient that Healthcare.gov and state-based exchanges have: the ability to search for plans by preferred provider. This new feature, supported by the Final Rule and payer data submissions, fills that gap.
Beneficiaries Need Provider Network Data
Beneficiaries have ample reason to shop during open enrollment this year:
- 1.8 million enrollees will see their current MA plans exit the market.
- Remaining plans are adjusting with higher deductibles, co-pays, and out-of-pocket maximums.
- Provider networks are shifting, meaning beneficiaries may need to find new doctors.
For millions making difficult plan decisions this year, richer provider directory data in MA Plan Finder could make the difference between keeping their provider and having to find a new one.
Short-Term: Adding Third-Party Data into Plan Finder
To meet the immediate need, CMS is sourcing provider network data from a third-party vendor, SunFire, as described in its August 25, 2025 memo, “Updates to the Contract Year 2026 Medicare Plan Finder and Medicare.gov.” CMS has been transparent that this is a “short-term solution”, not a viable long-term one, since MA Organizations are not required to provide directory data to SunFire or attest to the accuracy of the submitted data.
That short-term solution went live this week. Unsurprisingly, it’s imperfect. Reports from The Washington Post describe duplicate provider listings, mismatched network statuses, and inconsistent addresses. Washington Post was not specific about error details, so we were unable to reproduce them, but it is easy to imagine a provider associated with duplicate addresses with the same carrier, and listed as participating with a plan at one and not at another. In addition, there are prominent MA carriers that are not currently submitting data to SunFire, leaving the results incomplete (i.e., ‘Contact the Plan for Provider Information’ is prevalent throughout results). These are classic early-launch issues, likely the result of differing payer data and incomplete address normalization. On the surface, these issues seem to be solvable with better normalization across payer data sets and more complete submissions.
CMS is offering a three-month grace period for beneficiaries who enrolled in a plan based on inaccurate Plan Finder data, an acknowledgment that these issues have real-world impact.
Long-Term: Data Submissions into National Directory
The Final Rule sets January 1, 2026 as the effective date for MA carriers to begin submitting directory data directly to CMS, in a standardized format. This format has not yet been published, so it will be a scramble for carriers to produce the format between now and the end of the year. Whether government delays (due to the shutdown) shift that timeline remains to be seen. At some point CMS will begin regularly receiving these submissions from payers.
CMS has a longer vision: a unified National Directory that links provider–plan participation, allows providers to update data in a single place, and serves as the definitive source for payer and provider digital endpoints. That infrastructure will eventually underpin tools like MA Plan Finder, making provider data more accurate, timely, and interoperable across the healthcare system. The MA plan-network data would be syndicated well beyond MA Plan Finder, supporting third-party plan shopping workflows, provider search, and AI care navigation agents.
Payers, Do Not Retire Your Provider Directory API
Some payers may wonder: does this mean CMS no longer needs them to publish Provider Directory APIs? No. The Final Rule maintains Provider Directory API requirements alongside new data submission formats. In fact, the introduction of Plan Finder’s directory data makes API accuracy and alignment more important than ever. CMS now has two data sources to compare, submitted files and published APIs, to verify consistency and compliance. If your API isn’t fully functional or is missing data elements (e.g., provider-plan associations or NPIs) that CMS expects for MA Plan Finder, the time to address those issues is now.
Network Adequacy: A Pragmatic Exception
Interestingly, CMS has clarified that it will not require harmonization between network adequacy (HSD) submissions and directory data. This reflects a pragmatic understanding: not every in-network provider should appear in a consumer-facing directory (for example, those who cannot be directly scheduled). This flexibility lets payers improve directory accuracy without fear of triggering adequacy issues, at least at the moment. But long-term, CMS will need to modernize how adequacy is measured — perhaps incorporating availability metrics, such as appointment wait times, when technology and cost structures make that feasible.
Payers and Providers Need to Do Their Part to Address Provider Directory Data Issues
Many directory data issues persist in Plan Finder that have long plagued payer APIs:
- Incorrect or missing provider addresses
- Providers listed at locations they don’t serve
- Outdated or incorrect phone numbers
- Disagreements between providers and payers on in-network status
Each of these reflects weak points across the data lifecycle. Payers control in-network status, but providers and payers do not have a ‘network ID’ to help them align on answers. Providers control address and contact information, but share incorrect information with the payers (because they share the data to minimize claims denials, not to support directory accuracy). Accuracy depends on every party serving as the authoritative source for the data they own and validating it before it moves downstream. As Epic said in its response to the CMS Ecosystem RFI: ‘a unified national directory should have federated inputs with an unambiguous source of truth for each data element’ and ‘directory should have strong governance to manage data quality’. CMS’s long-term National Directory vision would reduce the number of “hops,” could more regularly measure and provide feedback on accuracy, isolate errors closer to the source, and make systemic fixes more achievable.
Sharing Provider Network Data Is Becoming a Competitive Imperative
The MA Plan Finder rollout, though imperfect, is accelerating a shift in how plan and network data are used. Data about in-network providers will increasingly drive consumer behavior around plan selection. The MA Plan Finder itself, third-party AI-enabled plan comparison tools, and new broker workflows are all beginning to embed directory data as it becomes more available. Every HR benefits meeting includes the same line: “Make sure your providers are in-network.” This is the information beneficiaries actually shop on. Now that provider data is feeding directly into a federal consumer-facing tool, directory data availability and data accuracy are no longer just a compliance checkbox, they are key factors in driving member enrollment and retention.
What Payers Should Do
- Verify your submissions. Ensure directory data submitted to CMS (or SunFire between now and January) is accurate and complete. Normalize your addresses and other information upstream, prior to submission, to prevent conflicting or inconsistent data downstream.
- Check your Provider Directory APIs. Make sure your Provider Directory API functions correctly and mirrors your submitted data in MA Plan Finder. This needs to include NPIs associated with every provider and explicit Provider-Plan relationships. Make sure your Insurance Plan names match those published on MA Plan Finder.
- Isolate issues where they need to be resolved. Work with CMS to identify and correct any data discrepancies that they may be responsible for (through incorrect data ingestion or loading). Identify issues payers should resolve in their own loading or production of data files submitted to CMS. For those issues that can be isolated within provider-submitted data, it is important to provide the feedback to the providers, and encourage them to resolve that upstream within their own databases.
- Prepare for the National Directory. Treat the roll-out of the MA Plan Finder as a dress rehearsal for bi-directional data exchange in a National Provider Directory. Addressing issues during MA Plan Finder could make a payer’s transition to using a National Provider Directory more seamless when it comes around. Encouraging providers to fix their data as upstream as possible will ensure they are ready to submit accurate and complete data into a National Provider Directory when it becomes available.