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Your insurance accepted page and plan directory listings: keeping them accurate

What federal law asks of practices on provider directory accuracy, the new Medicare Advantage directory rules, and how to word an honest insurance page.

For many patients the insurance question comes before anything else. They look at your website, then at their health plan’s online directory, and if both say you are in network they book. When those two sources disagree with each other, or with what your front desk says on the phone, the result is a confused patient at best and an unexpected bill at worst.

This guide covers what federal law expects from practices on provider directory information, the new Medicare Advantage directory rules that start in 2028, and how to write an insurance page on your own website that stays accurate. It also gives a simple process for keeping everything in step when a contract starts, ends or changes. Advertising claims about same-day visits and whether you take new patients are covered in our guide to same-day and new patient availability claims. If your front desk also helps patients get coverage, see our guide to helping patients with marketplace and Medicaid enrollment. If you list TRICARE, our guide to marketing to veterans and military families explains the difference between authorized, participating and network status. For the other places your address and phone appear, from map apps to the NPI registry, see our guide to directory listings and local citations. If you are not in network with a patient’s plan, our guide to advertising an out-of-network practice covers superbill wording, self-pay estimates and state disclosure laws.

This is general information, not legal advice. Sources cited were checked on October 29, 2026: 42 U.S.C. 300gg-139 (Public Health Service Act section 2799B-9) and 42 U.S.C. 300gg-115; the CMS training The No Surprises Act’s Continuity of Care, Provider Directory, and Public Disclosure Requirements (December 2021); FAQs about Affordable Care Act and Consolidated Appropriations Act, 2021 Implementation Part 49 (August 20, 2021); the CMS proposed rule implementing the REAL Health Providers Act, 91 FR 66408 (October 20, 2026); 45 CFR 162.410; and 15 U.S.C. 45. Federal law here does not preempt state provider directory laws, so check your state’s rules as well, and ask counsel about your contracts.

Why insurance accuracy is more than customer service

A statement on your website such as “we are in network with this plan” is a factual claim. Section 5 of the FTC Act, 15 U.S.C. 45(a)(1), declares unfair or deceptive acts or practices in commerce unlawful, and that applies to what a practice says about the insurance it takes just as it applies to prices or results. An insurance page that was accurate when it was written and was never updated can become misleading on the day a contract ends.

There is also a specific federal law on provider directories. The No Surprises Act, part of the Consolidated Appropriations Act, 2021, added duties for health plans and for providers to keep directory information accurate, and a protection for patients who rely on a wrong listing.

What the No Surprises Act asks of practices

Under 42 U.S.C. 300gg-139 (section 2799B-9 of the Public Health Service Act), beginning no later than January 1, 2022, each health care provider and facility must have business processes in place to ensure the timely provision of provider directory information to the health plans and insurers it contracts with. At a minimum, the practice submits that information:

  1. When a network agreement begins with a plan or issuer.
  2. When a network agreement ends.
  3. When there are material changes to the directory information, such as a new address or a provider who leaves.
  4. At any other time the provider, facility or the Secretary of HHS determines appropriate, including when the plan or issuer asks.

The statute defines provider directory information as the names, addresses, specialty, telephone numbers and digital contact information of individual providers, and the names, addresses, telephone numbers and digital contact information of each medical group, clinic or facility in the network. That is the minimum the plan’s directory needs from you.

The same section has a refund rule. If a patient relied on a plan directory that wrongly listed the provider as in network, and the provider bills the patient more than the in-network cost-sharing amount and the patient pays, the provider must reimburse the excess, plus interest at a rate set by the Secretary. The statute also lets a provider require in its contract that the plan remove it from the directory when the contract ends, and that the plan bear financial responsibility for giving patients inaccurate network status information.

On the plan side, 42 U.S.C. 300gg-115 requires plans and issuers to verify and update their online directory at least once every 90 days, to update it within 2 business days of receiving information from a provider, and to answer an enrollee’s phone inquiry about network status within 1 business day, in writing. When an enrollee relied on the plan’s directory or response showing a provider as in network and the provider was not, the plan may not charge more than in-network cost sharing and must apply the in-network deductible and out-of-pocket maximum.

A note on rulemaking. In August 2021 the Departments said rulemaking on the plan directory requirements would not be issued until after January 1, 2022, and the CMS provider training from December 2021 said the same about the provider requirements, adding that in the meantime providers may have to work with plans and issuers to make good faith efforts. When we checked the Federal Register on October 29, 2026, we did not find a final rule implementing the provider side of these provisions. The statute itself still applies, so treat it as the baseline.

Medicare Advantage: the REAL Health Providers Act

Medicare Advantage directories are getting their own, stricter rules. On February 3, 2026, section 6220 of the Consolidated Appropriations Act, 2026 enacted the Requiring Enhanced and Accurate Lists of (REAL) Health Providers Act. According to the CMS proposed rule published October 20, 2026 (91 FR 66408), it sets new directory requirements for Medicare Advantage organizations starting with plan year 2028, including that each organization must:

  • Keep an accurate provider directory on a public website.
  • Verify each listed provider’s directory information at least once every 90 days, and update it if needed.
  • Show in the directory when a provider’s information could not be verified and may not be up to date.
  • Remove a provider within 5 business days of determining that the provider no longer participates in the plan’s network.
  • Run an annual accuracy analysis using a random sample of listed providers.

These duties fall on the plans, not on practices. They still matter to you, because verification often depends on the provider answering. The proposed rule notes that some verification methods depend on a response from the provider, and that a provider may not respond. A practice that ignores verification requests risks being flagged as possibly out of date, which can turn patients away. Comments on the proposed rule close December 15, 2026, so the details may change before the final rule. What a practice may say and display about plans in its own office is covered in our guide to Medicare Advantage and Part D plans in your practice.

Your NPI record counts too

Plans, directories and data services draw on the national NPI registry. Under 45 CFR 162.410(a)(4), a covered health care provider must communicate changes in its required data elements to the National Provider System within 30 days of the change. A move, a new practice location or a change in mailing address is a reason to update the NPI record as well as the plan directories.

Practices that see veterans through VA community care have a separate set of rules on eligibility, authorization and what veterans pay. Our guide to VA community care provider marketing covers them.

Writing an insurance page patients can rely on

Your own website is the one directory you control completely. A few wording choices make a large difference:

  • Say “in network” only where you have a current contract. “We accept” is often read as “in network”. If you will file a claim with a plan you are not contracted with, say that plainly and explain that out-of-network costs may apply.
  • Name the plans, not only the insurer. A contract may cover some of an insurer’s plans and not others. List what your contracts actually cover, in the words patients see on their insurance card.
  • Avoid blanket statements. “We take all major insurance” is almost never accurate and hard to keep accurate.
  • Show a last updated date. It tells patients how fresh the list is and reminds your team to review it.
  • Tell patients how to confirm. Suggest that patients check with their plan before a visit, the same advice federal law requires plans to print in paper directories.
  • Keep it consistent everywhere. The insurance page, your Google Business Profile, your booking system, your phone script and the plan directories should all say the same thing.

Patients who will pay out of pocket need different information. Our guides to good faith estimates for self-pay patients and advertising cash prices cover that side, and our guide to the No Surprises Act website disclosure covers the balance billing notice many practices must post.

When a contract changes: a checklist

Illustration: a two-location physical therapy practice leaves one insurer’s network at the end of the quarter and adds a new provider at its second location the same month. A checklist like this, owned by one named person, keeps every source in step.

  1. Tell the plan in writing. Send the termination date and confirm the removal date for the directory, and send the new provider’s directory information to every plan the practice contracts with.
  2. Update the website. Change the insurance page and the provider and location pages, and update the last updated date.
  3. Update your listings. Google Business Profile and other online listings should match the website.
  4. Update the NPI record. Within 30 days of any change to the required data elements.
  5. Brief the front desk. Give staff the exact wording for affected patients and for new callers.
  6. Tell affected patients. Patients with upcoming visits under the ended contract should hear about it before they arrive, not at checkout.
  7. Check refund cases. If a patient relied on a plan directory that still listed you as in network and paid more than in-network cost sharing, review whether a refund is owed under 42 U.S.C. 300gg-139(b).
  8. Diarize a review. Check the plan directories again a few weeks later, and review the whole insurance page at least quarterly.

How we handle this

When we build or rebuild a practice website, we give the insurance page a named owner, a last updated date and wording that matches the practice’s actual contracts, and we keep provider and location pages consistent with the listings patients see elsewhere. See our medical website design service for how we approach the build.

Does federal law require practices to keep plan directories accurate?

Federal law requires providers to have business processes to send directory information to the plans they contract with when a contract begins or ends, when the information materially changes, and at other appropriate times, under 42 U.S.C. 300gg-139. The plans maintain the directories and must verify them at least every 90 days.

What happens if a patient relied on a wrong directory listing?

If the plan’s directory or response showed you as in network and you were not, the plan may charge the patient only in-network cost sharing. If you billed the patient more than that and they paid, the statute requires you to refund the excess with interest.

Is there a final regulation on the provider directory rules?

CMS said in 2021 that rulemaking would come after January 1, 2022. When we checked the Federal Register on October 29, 2026, we did not find a final rule on the provider side. The statute applies on its own terms.

What is the REAL Health Providers Act?

It is section 6220 of the Consolidated Appropriations Act, 2026. It sets stricter directory accuracy rules for Medicare Advantage organizations starting with plan year 2028, including verification at least every 90 days and removal of non-participating providers within 5 business days. CMS proposed implementing rules on October 20, 2026.

Can we say we accept an insurer we are not contracted with?

Patients often read “we accept” as “in network”. If you are out of network but will file claims, say exactly that and explain that out-of-network costs may apply.

Do state laws also apply?

They can. The federal provisions say they do not preempt state laws on provider directories. This guide does not cover state rules, so check yours.

Sources

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