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The Medicare Annual Coordinated Election Period (ACEP) is the most crucial time of year for Medicare beneficiaries to make decisions about how they wish to receive their Medicare coverage.  This year the Administration seems to be actively promoting Medicare Advantage plans. However, at the same time that this steering toward private plans is occurring, the Centers for Medicare & Medicaid Services (CMS) reported that Medicare Advantage  provider directories contain extremely inaccurate information, which could lead beneficiaries to sign up for plans that might not actually include their doctors.

This is CMS’ third round of provider directory review since initially being alerted by a beneficiary complaint. CMS Examined 5602 providers and their listed locations from 52 different Medicare Advantage organizations between November 2017 and July 2018.  Reviewers in the study called provider offices to verify the accuracy of the information in the provider directory. Information to be verified included names, address and phone numbers; whether the provider accepted the MA-PD in question at that location, and whether they accepted new patients with the MA-PD in question. CMS assigned each error a score, with incorrect locations, numbers and statements regarding accepting patients weighted highest.[1]

The CMS review found that:

  • Almost half (48.74%) had at least one inaccuracy.
  • Percentage of inaccuracies by MA organization ranged from 4.63% for the best network listing to 93.02% for the worst.
  • The majority of MA organizations had between 30% and 60% inaccuracies.
  • “Providers should not have been listed at 33.14% (3,481) of the locations…either because the provider did not work at the location or because the provider did not accept the plan at the location.”[2]
  • “85.64% of locations with deficiencies…had deficiencies of the highest weighted, most egregious errors.”[3]
  • 41.75% of all locations listed had inaccuracies “with the highest likelihood of preventing access to care.”[4]

Beneficiaries and caregivers rely on provider directories to make important choices about their care. In this era of overt steering toward Medicare Advantage by the Administration[5], accurate information has never been more crucial. Errors in provider listings “create a barrier to care and raise questions regarding the adequacy and validity of the MAO’s network as a whole.”[6] 

Despite these inaccuracies, according to the Washington Post, “[t]he Trump administration is holding off on punishing Medicare Advantage plans for error-ridden doctor directories — further evidence” that CMS “is showing special favor to the alternative program over traditional Medicare offerings.”[7]  The Post continues: “Last year, the agency threatened to impose fines on the plans if they didn’t clean up their act. While this year’s report shows no substantial improvement over last year (or the year before that), CMS isn’t following through on the threat [emphasis in original].”


[1] Online Provider Directory Review Report (Centers for Medicare & Medicaid Services) (November 2018), available at:, p. 5, table 3.
[2] Id, p. 6
[3] Id, p. 8
[4] Id, p. 1
[5] In addition to previous Center Alerts, see, e.g. “Trump Administration Peppers Inboxes With Plugs for Private Medicare Plans” by Robert Pear, New York Times, (Dec. 1, 2018), available at:, and “The Health 202: Trump administration lets Medicare plans off the hook” by Paige Cunningham, (Dec. 4, 2018), Washington Post, available at:
[6]Online Provider Directory Review Report , p. 1
[7] “The Health 202: Trump administration lets Medicare plans off the hook” by Paige Cunningham, (Dec. 4, 2018), Washington Post, available at:  


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