Your 2028 REAL Health Providers Act deadline is reallyOctober 15, 2027
Provider directory accuracy is becoming a reportable, and soon public, compliance metric. Download the infographic for the requirements, the key dates, and what to do now.
What's inside
The infographic is a 2027 compliance briefing on the Requiring Enhanced and Accurate Lists of (REAL) Health Providers Act. Its headline: your 2028 deadline is really October 15, 2027, because that is when the first compliant plan-year-2028 directory must be posted. Provider directory accuracy is becoming a reportable, and soon public, compliance metric, so the job changes from maintaining directories to actively verifying, measuring and reporting accuracy.
Why it matters. From plan year 2028, ghost networks carry a price tag: the plan absorbs the cost when a member relies on a wrong listing, so inaccuracy stops being a service problem and becomes a claim liability. CMS audits of Medicare Advantage directories have found error rates of roughly 50%, and the new window to pull a departed provider from every directory is five business days. A wrong directory costs delayed care, higher call centre volume, out-of-network cost exposure, regulatory penalties and damaged member trust.
The five requirements. Verify every provider record at least every 90 days, documented and timestamped. Remove providers within five business days of confirmed departure. Run an annual accuracy audit on a random sample, including specialties with high inaccuracy rates such as mental health and substance use disorder. Protect members from added cost-sharing when they rely on inaccurate in-network information, with notice before the annual election period, in the directory and in the EOB. Flag any record not verified within 90 days, and carry expanded fields for disability accommodations, cultural and linguistic capabilities and telehealth.
The timeline. The REAL Act was signed in February 2026. HHS implementation guidance is due in early 2027. The PY2028 directory posts on October 15, 2027. From January 1, 2028 the 90-day clock, 5-day removals and cost-sharing protection take effect, and accuracy scores go public in 2029. Nobody has yet decided how the score will be calculated.