synodic-ai HIPAA

Health Data & HIPAA Desk

2026-10-19

Today's briefing covers proposed rule CMS-4214-P, issued by CMS on 2026-10-16 to implement sections 6219, 6220 and 6224 of the Consolidated Appropriations Act, 2026. It would require Medicare Advantage plans to verify provider directory data at least every 90 days and publish accuracy scores, and would put reporting, disclosure and compensation requirements on pharmacy benefit managers in Part D, with comments open for 60 days after Federal Register publication.

CMS Press Release

Medicare Advantage plans would verify directories every 90 days, report an accuracy score, and cap enrollee costs caused by wrong listings

CMS issued a proposed rule that would improve the accuracy of provider directories for Medicare Advantage plans, establish transparency and compensation requirements for pharmacy benefit managers (PBMs), and deliver enhanced cost-saving protections for low-income Medicare beneficiaries. Plans would be required to verify and update their provider directory information at least every 90 days and report an accuracy score to CMS, and the scores would be prominently displayed on the plans' public-facing directories. Enrollees who rely on an inaccurate directory listing that leads them to receive care from an out-of-network provider would pay no more than their in-network cost-sharing amount. PBMs would have to report their compensation and cost performance to plan sponsors and CMS annually, and PBM payments would have to reflect fair market value for the services provided rather than drug costs. CMS Administrator Mehmet Oz said CMS has been working to improve data connectivity and accuracy in provider directories across the healthcare system. The changes are proposed for contract year 2028 and are open for public comment for 60 days after Federal Register publication; CMS expects to release another proposed rule with policy and technical changes for Parts C and D later this fall.

Why it matters

Directory accuracy becomes a measured, published data-quality obligation with a direct consequence for enrollees: someone misled by a wrong listing would owe no more than in-network cost sharing. Medicare Advantage organizations should map where their provider directory data comes from, how it is verified today, and whether a 90-day verification cycle and a reportable accuracy score can be produced from current systems before contract year 2028.

Source: CMS Newsroom · Press release · 2026-10-16
CMS Fact Sheet

CMS-4214-P in detail: machine-readable directory accuracy scores from contract year 2029, PBM data reporting and disclosure, and disgorgement for remuneration violations

The fact sheet ties the proposal to the Consolidated Appropriations Act, 2026, signed into law on 2026-02-03. For section 6220, the Requiring Enhanced and Accurate Lists of (REAL) Health Providers Act, CMS proposes provider directory verification and maintenance standards, annual accuracy analysis and reporting, public reporting of accuracy scores, and cost-sharing protections for enrollees who rely on inaccurate directory information, beginning in contract year 2028. It also proposes to codify the statutory requirements for contract year 2029: CMS must publicly display provider directory accuracy scores in a machine-readable format, and MA organizations must prominently display those scores in their provider directories.

For section 6224, Modernizing and Ensuring Pharmacy Benefit Manager Accountability, the proposals govern the remuneration PBMs and their affiliates may receive for services connected with the utilization of Part D drugs; data reporting by PBMs to Part D prescription drug plan sponsors and CMS; transparency in PBM price guarantee arrangements; and disclosure by PBMs to plan sponsors of the terms of certain agreements between PBMs or their affiliates and pharmaceutical manufacturers. CMS also proposes definitions of key terms and compliance and enforcement mechanisms, including disgorgement of funds to CMS for violations of the remuneration requirements. A conforming change required by section 6219 would reduce the generic drug copayment from $1 to $0 for full-benefit dual eligible individuals at or below 100 percent of the Federal Poverty Level, effective for plan years starting 2028-01-01.

Why it matters

Both halves of the rule are data obligations. Medicare Advantage organizations would produce accuracy analyses that CMS must publish in machine-readable form from contract year 2029, which makes directory data quality comparable across plans. PBMs would take on recurring data reporting to plan sponsors and CMS plus disclosure of manufacturer agreement terms, backed by disgorgement for remuneration violations. Part D sponsors should prepare to receive and validate new PBM reporting, and both MA organizations and PBMs should use the 60-day comment period to test whether the proposed definitions and reporting requirements fit their systems.

Source: CMS Newsroom · Fact sheet · CMS-4214-P · 2026-10-16