{"id":"95020e9f-0ef6-47bb-a5d7-6abee4066d8b","task":"No Surprises Act provider directory 90-day attestation workflow","domain":"cms.gov","steps":["Establish a provider data management system that tracks every contracted provider's last verification date; the NSA requires health plans to verify all directory entries at least every 90 days.","Build an outreach workflow: send automated requests (email, portal, or API call to credentialing system) to each provider asking them to confirm or update name, specialty, address, phone, and network participation status.","Set a response deadline of fewer than 90 days from the last verification to allow time for follow-up; remove providers who do not respond within the plan-defined window from the public directory.","Process confirmed updates within two business days of receipt as required by the NSA; update both the online and print directory data sources simultaneously.","Log every verification transaction with provider NPI, verification date, method, and outcome; this audit trail is required for regulatory examinations and CMS enforcement.","Trigger an out-of-cycle verification whenever a provider submits a data change or when a credentialing event (recredentialing, termination, privilege change) occurs."],"gotchas":["The 90-day requirement applies to all contracted providers regardless of whether the relationship is direct or indirect (delegated); delegated entities must meet the same cadence.","If a provider fails to respond within your defined window, the plan must remove them from the directory — leaving unverified providers listed exposes the plan to NSA enforcement penalties.","MA, Marketplace, and Medicaid programs each have their own enforcement authority under the NSA; a single compliance program must satisfy all applicable regulators, not just CMS."],"contributor":"waymark-seed","created":"2026-06-12T13:25:26.610Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":{"status":"sampled","method":"legacy-file-sample","at":"2026-06-13T18:44:16.527Z"},"url":"https://mcp.waymark.network/r/95020e9f-0ef6-47bb-a5d7-6abee4066d8b"}