Ensure accuracy of MA provider directories
Recommendation
Congress should codify existing regulatory requirements that Medicare Advantage plans maintain accurate provider directories, including provider contact information and whether a provider accepts new patients.[1] Congress should require independent audits of all network directories for accuracy, should impose delisting requirements for not billing any plan for more than 12 months, and should impose out-of-network reconciliation requirements.[2][3]
Background/summary
Medicare Advantage Plans (MA or Part C) are plans offered by private insurance companies and will pay enrollees Medicare Part A (Hospital Insurance) and Medicare Part B (Medical Insurance) on their behalf.[4] Existing federal regulations governing the MA program mandates that all Medicare Advantage organizations must maintain a publicly accessible standard-based interface which, among other things must include a “complete and accurate” provider directory.[5] This directory must include provider name, address, and phone number; and must be updated within 30 days of MA networks being made aware of changes to provider contact information, and must update in/out of network statuses within two days.[1][5] However, the Senate Finance Committee has investigated and found significant lapses in accurate provider information, making the process of finding an appointment more challenging.[6] No person experiencing a mental health of substance use disorder crisis should be expected to navigate an inaccurate provider list, or the resulting delay to care.
Congress should codify these administrative requirements, while also providing regulators with resources to ensure enforcement capacity. The Better Mental Health Care for Americans Act, for instance, would provide $10,000,000 of otherwise unallocated funding to be directed at implementing independent audits.[7] The Department of Health and Human Services (HHS) should also be empowered to automatically remove providers who have not billed Medicare or Medicaid for more than 12 months and to impose out-of-network reconciliation when a provider has been found to be incorrectly listed as in-network.[3]
citations
1. U.S. Senate Committee on Finance. “Bipartisan Mental Health Care Provisions.” Last Accessed December 1, 2022.
2. Senator Michael Bennet and Senator Ron Wyden “Introduce Bill to Increase Access to Mental and Behavioral Health Care for Kids, Seniors, and Low-Income Americans.” 2023. Senator Michael Bennett. Last Updated March 22, 2023.
3. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services. “No Surprises: Understand your rights against surprise medical bills.” Last Updated January 3, 2022.
4. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services. “Medicare & Your Mental Health Benefits.” Last Updated September 2022.
5. National Archives and Records Administration, Code of Federal Regulations. “PART 422—MEDICARE ADVANTAGE PROGRAM.” Last Updated July 24, 2023.
6. U.S. Senate Committee on Finance. “Barriers to Mental Health Care: Improving Provider Directory Accuracy to Reduce the Prevalence of Ghost Networks.” Last Updated May 3, 2023.
7. Better Mental Health Care for Americans Act S.923 (Bennett-Wyden), 118th Congress (2023-2024). Last Accessed July 24, 2023.