Implement a 90-day provider directory verification workflow to comply with No Surprises Act health plan directory requirements

Steps

1. Confirm the obligation: the No Surprises Act requires health plans/issuers to verify and update online provider directory data (name, specialty, address, phone, network status) at least every 90 days, with no exemption by provider or facility category.
2. Build an outreach/attestation cycle that contacts each in-network provider or facility at least once every 90 days to confirm or correct directory data.
3. When a provider submits updated information, publish the correction to the public directory within 2 business days of receipt.
4. Define a documented non-response policy specifying how long an unverified listing may remain published before it is flagged as unverified or removed.
5. Log every verification attempt, response, and directory change for audit purposes, since both providers (up to $10,000 per violation) and plans (up to $100 per day per affected individual) face separate penalty exposure.
6. Reconcile the directory against claims and prior-authorization systems so members relying on published network status have a defensible basis if the directory was inaccurate.