Most of the regulatory pressure on Medicare Advantage directories right now comes from two rules finalized close together, plus the interoperability rule that preceded them. Read individually they each sound manageable. Stacked on a calendar, they describe a three-year shift in what a plan is expected to do with its directory data. Here is the sequence, and what each milestone actually requires.
Now in effect: submit, update within 30 days, attest annually
The baseline has not changed and is easy to lose track of under the newer rules. MA organizations submit directory data to CMS, update it within 30 days of learning about a change, and attest at least once a year that it is accurate and complete (42 CFR §422.111). If the newer requirements are the roof, this is the foundation they sit on.
January 2026: verify every record every 90 days
The REAL Health Providers Act requirement, finalized in CMS-4208-F2, took effect at the start of 2026. Plans must verify each provider's directory information at least once every 90 days. The word that matters is verify — not 'update if someone tells you,' but actively confirm. A plan that cannot show its verification cadence when asked has a gap regardless of how accurate the data happens to be.
Plan year 2027: your directory shows on Medicare Plan Finder
CMS begins publishing MA directory data on Medicare Plan Finder for plan year 2027, with a validation window before it goes live. Accuracy stops being purely an audit concern and becomes something a shopper sees during open enrollment.
January 2027: the interoperability APIs come due
CMS-0057-F sets a general compliance date of January 1, 2027 for the Provider Access, Payer-to-Payer, and Prior Authorization APIs. The public FHIR Provider Directory API — the machine-readable directory, built to the DaVinci PDex Plan-Net guide — is the piece most directly tied to the directory itself, and it was already required under the earlier interoperability rule. If your plan does not have one, 2027 is the year that becomes visible.
Plan year 2029: the accuracy score is published
From plan year 2029, MA organizations must prominently display their directory-accuracy score, and CMS publishes those scores publicly. This is the endpoint the whole stack has been building toward: accuracy that is measured, scored, and shown.
Reading the stack as one thing
- The verification cadence (2026) produces the accuracy that gets scored (2029).
- The FHIR API (2027) and the member-facing directory should run off the same data, or they will disagree in public.
- Plan Finder publication (2027) turns a private compliance number into a competitive one.
- Each milestone is easier if the directory is one continuously-verified dataset rather than several reconciled near a deadline.
Dates and scope can shift as CMS issues further guidance, so treat this as an orientation rather than legal advice and confirm the specifics for your contract type. If you want a scored picture of where you stand against all four, the readiness check takes about two minutes.