A patient searches their insurer’s directory, finds a therapist listed as in-network, books an appointment, and later gets a bill that looks nothing like what they expected. New federal regulations exist specifically to stop that scenario. Insurers are now required to keep provider directories current, verified, and accurate, and therapists carry real responsibility for making sure their own credentialing data, specialty, location, and network status, is correct everywhere their name appears. When that data drifts out of date, the fallout lands on patients first and on practices soon after.
What the No Surprises Act Actually Requires
The No Surprises Act, part of the Consolidated Appropriations Act of 2021, added specific provider directory refund requirements that CMS outlines for providers, facilities, and health plans. Under these rules, providers must submit directory information to a plan whenever they begin or terminate a network agreement, whenever there’s a material change to their directory listing, or whenever the plan or HHS requests it. That information must include name, address, specialty, phone number, and digital contact details. If a patient relies on inaccurate directory information and ends up billed above in-network cost-sharing, the provider is required to refund the difference, with interest, and the health plan must apply in-network cost-sharing terms retroactively. In other words, an outdated listing isn’t just a data problem; it creates a financial obligation.
Why “Ghost Networks” Became a National Story
The scale of the underlying problem is what pushed regulators to act. A ghost network study conducted by Senate Finance Committee staff called 120 in-network mental health providers listed across 12 Medicare Advantage plans and could secure an appointment only 18% of the time. More than 80% of listings were “ghosts,” unreachable, not accepting new patients, or not actually in-network. Mental health listings were singled out precisely because behavioral health directories tend to have some of the highest error rates of any specialty, which is part of why therapists face outsized scrutiny under these new rules.
The 90-Day Rule That Changes the Timeline
Directories can no longer sit unverified indefinitely. Health plans must actively confirm the accuracy of every provider listing on a recurring cycle, a 90-day directory verification requirement established under the No Surprises Act, and update confirmed changes within a short window after a provider reports them. In practice, this means insurers are now reaching out to therapists more frequently to confirm specialty, location, and whether they’re still accepting new patients under a given plan. A therapist who doesn’t respond to that outreach risks being dropped from the directory altogether, even if they’re still actively in-network.
What This Means for Therapists Specifically
Therapists frequently work across multiple settings: private practice, group practices, telehealth platforms, and sometimes hospital-affiliated clinics. Each setting can mean a different address, phone number, or even network status depending on which entity holds the contract. Every one of those variations has to be reflected accurately in every payer’s directory. A therapist who changes offices, drops an insurance panel, or stops accepting new patients needs that update to reach every plan they’re contracted with, not just the one where the change originated.
The financial exposure is not hypothetical. Because the refund-with-interest requirement attaches to the treating provider regardless of who caused the original error, a therapist whose directory listing lags behind reality can end up absorbing costs tied to a plan’s outdated record. Regulators have also signaled that oversight is tightening: congressional staff have specifically called on CMS to audit directories more regularly and consider financial penalties for plans that fail to maintain accuracy, which raises the compliance stakes for everyone whose data feeds those directories.
Practical Steps to Keep Directory Data Accurate
Respond promptly to every payer verification request, even when it feels redundant. Audit your own listings across major payer directories at least quarterly, checking specialty, address, phone number, and network status against reality. Report changes in writing and keep a record of when and how you reported them, since that documentation matters if a billing dispute arises. Treat directory accuracy as an ongoing credentialing task, not a one-time setup step during enrollment.
Why Choose Prime Credential
Keeping directory data accurate across every payer a therapist works with is exactly the kind of ongoing, detail-heavy task that falls through the cracks without dedicated attention. Prime Credential monitors your credentialing data across payer directories, submits updates the moment your specialty, location, or network status changes, and tracks every payer’s verification cycle so nothing lapses into a ghost listing. We handle the recurring outreach insurers now send under the No Surprises Act so you’re never the reason a patient can’t find or reach you. Whether you’re a solo therapist or part of a growing group practice, Prime Credential keeps your directory presence accurate, current, and compliant.
Frequently Asked Questions (FAQs)
1. Does the No Surprises Act apply to therapists who only accept Medicaid or Medicare patients?
No. The No Surprises Act’s directory and billing protections apply to private and commercial group health plans and issuers, including employer-sponsored and marketplace coverage. Medicare, Medicaid, and similar government programs are covered by their own separate directory and access rules.
2. Can a therapist be held responsible if an insurer’s directory shows outdated information despite timely updates from the practice?
The rules place the ongoing verification and correction duty on the health plan once a therapist has submitted accurate information. A therapist’s documented, timely submission of changes is generally the key factor in demonstrating compliance if a dispute arises.
3. How does directory inaccuracy affect a therapist’s own liability for surprise billing situations?
If a patient is billed above in-network cost-sharing because they relied on inaccurate directory information, the treating provider is required to refund the excess amount with interest, regardless of whether the inaccuracy originated with the therapist or the plan.
4. Are telehealth-only therapists subject to the same directory accuracy requirements as in-person providers?
Yes. The directory submission requirements apply to any provider with a network agreement, regardless of whether care is delivered in person or via telehealth, though the location and contact information reported may differ.
5. What should a therapist do if a payer directory still shows them after they’ve left a network?
Notify the plan in writing immediately, request written confirmation of removal, and keep records of both communications. Providers can also request that a plan contractually agree to remove them from the directory at the time a contract terminates.
