Ghost networks: why provider directories lie — and how to fix yours

What a ghost network actually is

A ghost network — sometimes called a phantom network — is the portion of your published provider directory that does not correspond to real, reachable, in-network care. The provider might be listed but no longer contracted. The address might route to a location the physician left. The phone number might reach a practice that stopped accepting your plan. The listing might say "accepting new patients" when the panel closed months ago. Each of these is a ghost: a name on paper with no care behind it.

The distinction that matters is between network adequacy and directory accuracy. Adequacy asks whether enough providers of each type exist within reach on paper. Accuracy asks whether the specific listings a member relies on are true today. A plan can pass its adequacy review — enough cardiologists inside the time-and-distance standard — while its directory is riddled with ghosts. Members do not experience your adequacy model. They experience your directory. When the directory lies, the network is functionally smaller than it looks, and the difference is invisible until someone tries to get care.

Why directories drift out of accuracy

Directory inaccuracy is not usually the result of negligence. It is the natural entropy of provider data colliding with fragmented ownership. A single physician's participation status depends on the group's contract, the individual's credentialing, the location roster, the panel status, and the billing configuration — and those facts live in different systems maintained by different parties. Providers move, merge, retire, add and drop locations, and change which plans they take, often without telling the plan promptly. The plan learns late, if at all.

The scale of the problem is well documented by the regulator itself. CMS reviews of Medicare Advantage online directories have repeatedly found that roughly half of provider locations contained at least one inaccuracy — a wrong phone number, an incorrect address, or an outdated new-patient status. A 2025 Office of Inspector General review found that a large majority of inactive providers listed in MA and Medicaid managed care directories should not have been listed at all. These are not outlier plans. This is the baseline condition of an unmanaged directory.

• Contract churn: groups join and leave, and downstream roster updates lag the contract event.
• Roster fragmentation: a provider's locations, panel status, and specialty are maintained in separate feeds that fall out of sync.
• One-way information flow: providers rarely notify the plan proactively when something changes.
• Duplicate and phantom locations: administrative addresses and no-longer-active sites get published as if members can be seen there.
• Stale attestations: annual sign-offs certify data that was already out of date when it was certified.

What CMS requires for Medicare Advantage directories

For Medicare Advantage organizations, the core directory obligations live in 42 CFR 422.111 and related communication requirements. The plan must make provider directory information available for online publication in the format CMS specifies, update the directory within 30 days of becoming aware of a change, and attest at least annually that the submitted information is accurate and complete. "Becoming aware" is doing a lot of work in that sentence: the whole point of a directory-accuracy program is to become aware faster, because the clock and the accountability run from your knowledge, not from the provider's courtesy.

CMS has been auditing these directories since 2016 and has not stopped. Findings of inaccuracy support compliance actions, and beginning with plan year 2027, CMS is moving MA directory data directly onto Medicare Plan Finder under the rule finalized in 2025 — meaning your data quality becomes visible to CMS and to shoppers on a federal platform, not just on your own site. The trajectory is unmistakable: less tolerance for ghosts, more centralization, and more direct exposure of bad data.

The No Surprises Act 90-day rule and its consumer protection

The No Surprises Act added a federal directory-accuracy standard that applies broadly across commercial and Marketplace coverage, and it is the rule most plans underestimate. Under the NSA, a plan must verify and update its provider directory information at least once every 90 days, and must update the directory within two business days of receiving new or corrected information from a provider. The plan is also expected to have a process to remove providers who fail to verify their data. The 90-day cadence is a floor, not a target — it is the slowest you are permitted to be, not the speed to aim for.

The NSA pairs that operational duty with a consumer protection that changes the financial stakes of a ghost. If a member relied on inaccurate directory information and reasonably believed a provider was in network, the member's cost-sharing is capped at the in-network amount, and the balance-billing protections apply. In plain terms: when your directory lies and a member gets hurt by it, the statute shifts the cost of that lie back onto the plan. A ghost is no longer just a bad listing — it is a potential balance-billing liability every time a member acts on it.

The downstream harm — for members and for the plan

For members, a ghost network produces the exact experience a directory is supposed to prevent: wasted calls, delayed care, surprise bills, and the sense that the plan's promise of access was not real. For members in D-SNP and other high-need populations, a phantom specialist is not an inconvenience — it can be a missed diagnosis or a lapse in a chronic-care relationship.

For the plan, the harm compounds across every axis you care about. Directory inaccuracy drives grievances and appeals, which feed member-experience measures inside Star Ratings and QHP quality frameworks. It creates NSA balance-billing exposure. It invites CMS and state audits, corrective action plans, and enrollment or marketing sanctions in severe cases. And it quietly undermines the sales story: the network you sold on breadth is not the network your members can use. A ghost network is expensive precisely because its costs are distributed and delayed until they arrive all at once.

A practical program to keep your directory honest

Fixing a ghost network is not a project with an end date; it is a standing capability. The plans that keep directories clean treat accuracy the way they treat claims — as a continuous operation with owners, cadences, and metrics. We help plans stand up that capability, and it rests on a few concrete disciplines rather than a single vendor or portal.

• Set a verification cadence tighter than the floor. The NSA requires every 90 days; run high-volume and high-risk specialties on a faster loop so drift never approaches the legal limit.
• Use outbound verification, not passive attestation. Confirm phone, address, specialty, and new-patient status through active outreach and secret-shopper-style checks — not a once-a-year signature.
• Enforce a remove-if-unverified rule. Providers who do not confirm their data come off the directory. A smaller true directory beats a larger false one, and the NSA expects the removal process to exist.
• Close the loop within two business days. When a provider reports a change, the correction must reach the public directory inside the NSA window; build the workflow so that is automatic, not heroic.
• Deduplicate locations and reconcile against credentialing and claims. Cross-check the directory against your credentialing roster and actual claim activity to surface listed providers with no real presence.
• Instrument accuracy as a metric. Track measured inaccuracy rate, time-to-correction, and grievance volume tied to directory errors — and report them to leadership like any other operational KPI.
• Align the directory with the adequacy model. The providers you count for adequacy and the providers you publish should be the same reachable providers; when they diverge, one of them is fiction.

Where to start

If you are entering a new market or line of business, build the directory-accuracy program before launch, not after the first audit. The cost of standing it up early is a fraction of the cost of a corrective action plan, a balance-billing dispute, or a lost member who could not find care. Start by measuring your true inaccuracy rate against a live sample of your own listings — most plans are surprised, and the surprise is the beginning of the fix.

A directory is a promise. When it is accurate, it is the most powerful proof point you have that your network is real. When it is not, it is a liability that grows quietly until it does not. We help plans turn the directory from a compliance chore into a standing asset — one that members trust, regulators respect, and your sales team can stand behind.