LAW: Medicare Advantage Provider Compliance
Medicare Advantage Provider Compliance:
What Plans Are Legally Required to Do
What Plans Are Legally Required to Do
Medicare Advantage plans that contract with providers to deliver benefits to enrolled members operate under a detailed set of legal requirements governing how those provider relationships are established, maintained, and governed. These requirements span network adequacy under 42 CFR 422.112, provider selection and credentialing under 42 CFR 422.204, prompt payment under 42 CFR 422.520, participation procedures under 42 CFR 422.202, and anti-discrimination protections under 42 CFR 422.205. Failure to meet any of these obligations can result in CMS sanctions including marketing and enrollment freezes, civil money penalties, and contract termination. This article explains what the law requires, what CMS enforces, and where plans most commonly fail.
5
Network Adequacy Violation Letters in 10 Years
A KFF Health News FOIA investigation found that CMS sent only 5 network adequacy violation letters to insurers from 2016 to 2022, covering 7 plans that failed to meet provider network requirements. The Medicare Payment Advisory Commission confirmed in June 2024 that CMS has authority to impose civil money penalties for network adequacy violations but had never exercised it.
KFF Health News: CMS Network Adequacy Enforcement (2024)
30 / 60
Day Prompt Payment Deadlines (Non-Contracted)
Under 42 CFR 422.520(a), MA plans must pay 95% of clean claims from non-contracted providers or members of MA private fee-for-service plans within 30 calendar days of receipt. All other non-contracted provider claims must be paid or denied within 60 calendar days. Interest accrues on clean claims not paid within 30 days. Contracted provider payment timelines are set by the plan-provider contract.
42 CFR 422.520, Prompt Payment
CY2024
When CMS Moved Network Adequacy to Application Stage
Beginning with CY2024 applications, CMS restructured network adequacy assessment so that MA applicants must now demonstrate network adequacy during the application review process, not after approval. This significantly raised the risk of application denial for plans with inadequate networks, reversing the prior practice of allowing post-approval remediation.
Epstein Becker: MA Network Adequacy Changes for 2024
Law Summary: The Legal Framework for Medicare Advantage Provider Compliance
Provider compliance in Medicare Advantage is governed by 42 CFR Part 422, Subpart E (Quality Improvement Requirements) and Subpart H (Provider Relations), supplemented by the CMS Medicare Managed Care Manual and annual policy and technical changes. The obligations fall into five distinct areas: how plans build and maintain provider networks (network adequacy), how plans select and credential providers (provider selection), how plans pay providers (prompt payment), how plans govern the contractual relationship with providers (participation procedures), and what protections providers have against discrimination by plans (anti-discrimination).
These obligations run primarily from the plan to CMS, the plan is responsible for ensuring that its provider network meets all regulatory standards, that its credentialing processes meet 42 CFR 422.204, that its payment processes comply with 42 CFR 422.520, and that its participation procedures comply with 42 CFR 422.202. Providers who believe a plan is violating these obligations have several remedies, including filing grievances, challenging terminations, and in some cases seeking relief through state insurance commissioners or CMS directly.
2024 to 2025 regulatory shifts affecting provider compliance
The CY2024 application changes moved network adequacy assessment to the application stage. The 2024 Final Rule added the Utilization Management Committee requirement and annual internal coverage criteria review, which affects how plans may manage provider-requested services. The 2025 Final Rule added a health equity expert requirement to the UM Committee and required plans to conduct plan-level health equity reviews of prior authorisation policies, affecting which providers’ patients may face disproportionate access barriers. These changes layer additional provider relations obligations on top of the base compliance framework. Source: LeadingAge: 2025 MA Final Policy Rule Analysis
Compliance Table: Medicare Advantage Provider Compliance Obligations
| Obligation | Regulation | Core Requirement | Enforcement Risk |
|---|---|---|---|
| Network Adequacy | 42 CFR 422.112; CMS Network Adequacy Standards | Maintain sufficient network of contracted providers in each county and service area to meet time and distance standards and access-to-care requirements; demonstrate adequacy at application stage from CY2024 | Application denial; marketing and enrollment freeze; notice of non-compliance; civil money penalties (rarely imposed historically) |
| Provider Selection and Credentialing | 42 CFR 422.204 | Conduct credentialing and recredentialing of contracted providers; base provider selection on provider performance; not deny participation solely on the basis of a provider’s licence or certification scope; not exclude providers on discriminatory grounds | CMS programme audit finding; civil rights complaints; provider grievance; state licensing board involvement |
| Prompt Payment | 42 CFR 422.520 | Pay 95% of clean claims from non-contracted providers within 30 days; pay all other non-contracted claims within 60 days; pay interest on clean claims not paid within 30 days; contracted provider timelines set by contract | Interest liability; provider disputes; CMS audit finding; potential state prompt pay law exposure |
| Participation Procedures | 42 CFR 422.202 | Establish procedures for physicians and other practitioners to participate; consult with contracted providers on medical policy, quality, and administrative procedures; procedures must be consistent with applicable law | CMS audit finding; provider complaints to CMS; state insurance department involvement |
| Provider Anti-Discrimination | 42 CFR 422.205 | Not discriminate against any provider acting within the scope of their licence or certification; not exclude providers from the network for advocating on behalf of patients; comply with applicable federal and state anti-discrimination requirements | Federal civil rights complaints; provider termination challenges; CMS enforcement referral |
Medicare Advantage Provider Compliance: What the Law Requires in Each Area
1. Network Adequacy: Building and Maintaining a Legally Sufficient Provider Network
Under 42 CFR 422.112, MA plans must maintain a provider network sufficient to offer access to covered services to all enrolled members. CMS evaluates network adequacy through time and distance standards, provider-to-member ratios, and specialty availability requirements that vary by county and service area. Plans must meet these standards for primary care, specialists, hospitals, mental health providers, and other covered service categories.
What the network adequacy standard measures
CMS measures network adequacy through three dimensions: provider-to-member ratios (sufficient number of providers per enrolled member population), time and distance standards (maximum travel time and distance to reach covered services in urban, suburban, and rural areas), and specialty availability (presence of required specialty types within the service area). Plans must meet all three dimensions across all counties in their service area.
The CY2024 shift: adequacy must be demonstrated before approval
Beginning with CY2024, MA applicants must demonstrate network adequacy during the application review, not after. Previously, CMS assessed adequacy post-approval and gave plans time to cure deficiencies. The change means that a plan applying to enter a new county or expand its service area must have a sufficient provider network contracted before it can receive approval to offer coverage, a fundamental shift in how new plans and expansions are validated. Source: Epstein Becker: MA Network Adequacy Changes for 2024
The enforcement gap: paper compliance versus operational access
CMS network adequacy standards assess network structure, provider counts, geographic coverage, specialty distribution, but do not assess whether a patient can actually schedule an appointment with a listed provider. A plan can meet every CMS adequacy benchmark while enrolled patients encounter closed panels or providers who are not accepting new Medicare Advantage patients. CMS noted in its 2025 Contract Year updates that it maintained a distinction between network adequacy attestations and provider directory accuracy requirements, without finalising a requirement to verify operational availability. Plans that are structurally compliant but operationally inaccessible face reputational and competitive risk even when they satisfy CMS standards. Source: Neolytix: CMS Network Adequacy vs. Operational Access (2025)
2. Provider Selection and Credentialing: Who Plans Must Accept and How They Must Evaluate Them
Under 42 CFR 422.204, MA plans must establish and implement a provider selection policy that defines how providers are selected for participation in the network and how they are credentialed. The regulation requires that selection criteria be established and applied consistently, and that the plan not discriminate in provider selection against providers acting within the scope of their licence or certification. Plans must also conduct credentialing, verification of licensure, training, experience, and competence, and recredentialing at regular intervals.
The plan may not deny participation to a provider solely on the basis of what type of services the provider offers within their scope of practice, so long as those services are covered under the plan. For example, an MA plan cannot categorically exclude nurse practitioners from participation when nurse practitioners are licensed in the state to provide the same services the plan covers. The plan’s credentialing criteria must be documented, applied consistently, and available for CMS review. Source: 42 CFR 422.204, Provider Selection and Credentialing
3. Prompt Payment: When and How Plans Must Pay Providers
Non-contracted providers: 30-day and 60-day deadlines under 42 CFR 422.520(a)
For clean claims submitted by non-contracted providers on behalf of MA enrollees (or clean claims from members of MA private fee-for-service plans), the plan must pay 95% within 30 calendar days of receipt. All other claims from non-contracted providers, those that are not clean claims or require additional information, must be paid or denied within 60 calendar days. The plan must pay interest on clean claims that are not paid within the 30-day window, accruing in accordance with the applicable interest rate provisions of the Social Security Act. Source: 42 CFR 422.520(a)
Contracted providers: timelines set by the plan-provider contract under 42 CFR 422.520(b)
For claims from contracted providers, 42 CFR 422.520(b) specifies that the contract between the MA organisation and the provider sets the payment timeline. CMS does not prescribe a specific prompt payment deadline for contracted providers in the same way it does for non-contracted providers. However, the plan’s prompt payment practices with contracted providers are a provider relations compliance issue, plans that routinely delay payment to contracted providers generate provider complaints, contract termination risk, and potential network adequacy failures if providers leave the network as a result. A bipartisan bill introduced in 2024 proposed aligning in-network and out-of-network prompt payment standards (14 days for clean in-network claims, 30 days for out-of-network), which would significantly tighten contracted provider payment obligations if enacted. Source: Healthcare Finance News: Bipartisan MA Prompt Payment Bill (2024)
4. Participation Procedures: Due Process for Providers
Under 42 CFR 422.202, MA plans must establish procedures for physicians and other health care professionals to participate in the plan’s network. These procedures must include a process for initial application, criteria for selection and rejection, and a process for reviewing adverse decisions. The regulation also requires that plans consult with contracted providers on medical policy, quality, and administrative procedures, meaning that provider input must be a genuine part of the plan’s policy development process, not a formality.
When a plan terminates a provider from its network for reasons other than imminent patient safety risk, the provider is entitled to a hearing and a review process before termination takes effect. The plan must give the provider at least 60 days advance notice of the proposed termination, state the reasons for termination, and provide an opportunity to appeal. Plans that terminate providers without following these procedures face regulatory exposure and potential legal challenge. Source: 42 CFR 422.202, Participation Procedures
5. Provider Anti-Discrimination: What Plans Cannot Do
Under 42 CFR 422.205, MA plans may not discriminate against any provider acting within the scope of their licence or certification solely on the basis of provider type. This means a plan cannot exclude all chiropractors, all psychologists, all nurse practitioners, or all certified nurse midwives from participation if those providers are licensed to provide services that the plan covers and Medicare approves. The anti-discrimination rule also prohibits plans from excluding providers from the network because they advocated for a patient’s access to care, a provision designed to protect providers who challenge prior authorisation denials on behalf of their patients. Plans that violate 42 CFR 422.205 face federal civil rights complaints, CMS enforcement referrals, and significant legal exposure. Source: 42 CFR 422.205, Provider Anti-Discrimination Rules
Penalties: Sanctions and Enforcement for Provider Compliance Failures
| Violation Type | Authority | Potential Consequence | Enforcement Likelihood |
|---|---|---|---|
| Network adequacy failure in application or during operations | 42 CFR 422.112; 422.752(c) | Application denial; marketing and enrollment freeze; notice of non-compliance; civil money penalty up to $100,000 per violation per day | Application denial risk HIGH (from CY2024); CMP imposition historically LOW but authority confirmed by MedPAC 2024 |
| Prompt payment failure, non-contracted providers | 42 CFR 422.520(a)(2) | Mandatory interest on unpaid clean claims; CMS programme audit finding; provider disputes | Interest liability AUTOMATIC; audit finding risk MODERATE; assessed during programme audits |
| Provider termination without required due process | 42 CFR 422.202; 422.205 | Provider legal challenge; CMS enforcement referral; state insurance department complaint; potential civil rights action under 422.205 | Legal challenge risk HIGH if process was not followed; state insurance department involvement MODERATE |
| Provider discrimination based on scope of practice or patient advocacy | 42 CFR 422.205 | Federal civil rights complaint; CMS enforcement referral; litigation; state licensing board involvement | Federal complaint risk HIGH; CMS enforcement referral MODERATE for systemic patterns |
Common Failures: What Triggers Provider Compliance Findings
Provider directories listing providers who are not accepting new MA patients
CMS requires MA plans to maintain accurate provider directories showing which providers are accepting new patients, their locations, and their contact information. Plans that list providers as accepting new patients when those providers have closed their panels, left the network, or are not operationally available generate member access failures and CMS programme audit findings. The 2025 CMS updates maintained provider directory accuracy as a separate and distinct compliance requirement from network adequacy attestation. Inaccurate provider directories directly harm members who attempt to make appointments and cannot, and generate grievances and complaints that surface in CMS programme audits.
Prior authorisation policies that apply more restrictive criteria than Medicare coverage allows
The 2024 Final Rule’s internal coverage criteria (ICC) requirements prohibit MA plans from applying more restrictive coverage criteria than national or local Medicare coverage determinations in their prior authorisation policies, except in specific circumstances where CMS guidance is silent. When plans apply internal criteria that are more restrictive than Medicare’s, they are denying coverage that Medicare would cover, which is both a provider compliance issue (the provider’s recommended service is denied) and a member rights issue (the member’s covered benefit is withheld). The 2025 requirement for a health equity review of prior authorisation policies adds another layer: plans must assess whether their PA policies disproportionately affect dual-eligible or LIS members.
Credentialing delays that block providers from billing for services already rendered
When a provider is in the credentialing process but has not yet been credentialed, claims for services rendered during the credentialing period may be denied or held. Plans must have a credentialing timeline policy that allows for provisional credentialing so that providers can begin seeing patients and submitting claims during the credentialing process without financial risk to either the provider or the patient. Plans that routinely leave providers in credentialing limbo for months generate provider dissatisfaction, network retention problems, and member access issues, all of which surface as provider compliance failures.
Terminating providers who challenged prior authorisation decisions on patient behalf
42 CFR 422.206 specifically prohibits MA plans from penalising any provider who advocates on behalf of a patient, including requesting an expedited determination or filing an appeal of a prior authorisation denial. Plans that terminate providers who are perceived as high-cost, high-utilisation, or “difficult” due to their appeals activity may be in violation of both 42 CFR 422.205 (anti-discrimination) and 422.206 (interference with professional advice). This is a high-risk compliance area because the motivation for termination is rarely documented explicitly, but patterns of terminating providers with high appeals rates relative to peers can constitute discrimination evidence. Source: 42 CFR 422.206, Prohibition of Interference with Provider Advice
Plan Obligations: What Provider Relations Must Maintain
Keep the provider directory accurate and updated continuously
CMS requires MA plans to update their provider directories within specified timeframes when provider information changes. For online directories, updates must be made within 30 business days of a change notification. For print directories, the plan must note that the online version is the most current. Plans must have a process for providers to request corrections to their directory listing and must respond within required timeframes. Provider directory accuracy is audited as part of CMS programme audits and is directly tied to network adequacy attestation accuracy.
Document all credentialing decisions and make criteria available for review
42 CFR 422.204 requires that the plan’s provider selection criteria be documented and consistently applied. Adverse credentialing decisions must be documented with the basis for the decision. Plans must also have a recredentialing cycle, typically every two to three years, with the same documentation requirements. CMS auditors examine credentialing files during programme audits to verify that selection criteria are applied consistently and that no discriminatory criteria are embedded in the credentialing process.
Follow provider termination due process requirements in every termination case
Except for terminations for imminent patient safety risk, the plan must give the provider at least 60 days advance notice, state the reasons for the proposed termination, and provide an opportunity for the provider to respond before the termination takes effect. The plan must have a hearing process that is independent of the initial termination decision. Document every step of the termination process, including the date notice was sent, the reasons stated, and the outcome of any appeal. Plans that skip or shortcut this process face provider legal challenges and CMS enforcement exposure.
Track and report prompt payment performance for non-contracted providers
Plans must be able to demonstrate that 95% of clean claims from non-contracted providers are paid within 30 days and that all other non-contracted claims are paid or denied within 60 days. Track clean claim receipt dates, payment dates, and interest calculations for non-contracted claims. Include prompt payment performance in the compliance monitoring programme and report outliers to the compliance committee. A plan that cannot produce prompt payment performance data during a CMS audit faces a systemic compliance finding in this area.
Legal Disclaimer
This article provides educational information about regulatory requirements. It does not constitute legal advice. Requirements vary by plan type, contract year, and specific operational circumstances. Consult a qualified healthcare compliance attorney for guidance specific to your organisation’s Medicare Advantage contract obligations.
Key Takeaways
Network adequacy compliance is now a pre-market obligation, not a post-approval cure
The CY2024 change requiring network adequacy demonstration at the application stage means that plans cannot enter a new service area or expand to a new county without first establishing a compliant provider network. This is a fundamentally different compliance posture from the prior environment where adequacy was assessed after approval. Plans must build provider networks before they can offer coverage, not after. Application denial is now a real and operative enforcement consequence of inadequate network planning.
Provider anti-discrimination and due process are active legal risks, not just CMS audit risks
Violations of 42 CFR 422.205 (anti-discrimination) and 422.202 (participation procedures) do not only generate CMS audit findings, they generate legal claims from providers. A provider terminated without due process can challenge the termination in court. A provider discriminated against based on scope of practice or patient advocacy can file a federal civil rights complaint. These are private legal risks that exist independently of CMS enforcement, and they are not limited by the historically low frequency of CMS enforcement action in the network adequacy space.
Provider compliance failures compound into member access failures, and member access failures become CMS audit findings
An inaccurate provider directory causes a member to attempt an appointment with a provider who is not available. That generates a member grievance. The grievance generates a ODAG record. The ODAG record is sampled in a CMS programme audit. The audit finds a pattern of access-related grievances. The access grievance pattern triggers a network adequacy review. Every provider compliance failure at the operational level, an outdated directory entry, a credentialing delay, a closed panel not removed from the directory, traces forward into the member experience and backward into the CMS audit record. Provider compliance is not a back-office function. It is a direct determinant of audit outcomes.
Frequently Asked Questions
What is network adequacy in Medicare Advantage and how does CMS measure it?
Network adequacy is the requirement under 42 CFR 422.112 that MA plans maintain a sufficient network of contracted providers to serve enrolled members. CMS measures adequacy through three dimensions: provider-to-member ratios (sufficient provider count per enrolled population), time and distance standards (maximum travel time and distance to access services in urban, suburban, and rural areas), and specialty availability (presence of required specialty types within the service area). Starting with CY2024, CMS assesses adequacy at the application stage rather than post-approval, requiring plans to demonstrate network adequacy before receiving approval to offer or expand coverage. Source: Epstein Becker: MA Network Adequacy Changes for 2024
What prompt payment obligations apply to Medicare Advantage plans under 42 CFR 422.520?
Under 42 CFR 422.520(a), MA plans must pay 95% of clean claims from non-contracted providers (or from enrollees of MA private fee-for-service plans) within 30 calendar days of receipt. All other non-contracted provider claims must be paid or denied within 60 calendar days. The plan must pay interest on clean claims not paid within the 30-day window. For contracted providers, 42 CFR 422.520(b) provides that payment timelines are set by the plan-provider contract, CMS does not prescribe specific deadlines for in-network claims, though legislative proposals have sought to set a 14-day in-network clean claim standard. Source: 42 CFR 422.520
Can a Medicare Advantage plan exclude certain types of providers from its network?
Not categorically. Under 42 CFR 422.205, MA plans may not discriminate in provider selection against any provider acting within the scope of their state licence or certification. A plan cannot categorically exclude nurse practitioners, clinical psychologists, chiropractors, or any other provider type if those providers are licensed to provide services that the plan covers. The plan may apply credentialing criteria and select among providers who meet those criteria, but the criteria must be applied consistently and must not result in blanket exclusion of a provider type covered by Medicare. Credentialing standards that disproportionately or systematically exclude a provider type may constitute discrimination under 42 CFR 422.205. Source: 42 CFR 422.205, Provider Anti-Discrimination Rules
What process must a Medicare Advantage plan follow before terminating a contracted provider?
Under 42 CFR 422.202, except for terminations due to imminent patient safety risk, the plan must give the provider at least 60 days advance notice of the proposed termination, provide written reasons for the termination, and offer the provider an opportunity to appeal through a fair hearing process before the termination takes effect. The hearing must be independent of the initial termination decision. Plans that terminate providers without following this process are exposed to provider legal challenge and CMS enforcement referral. Imminent patient safety risk terminations may proceed immediately but must be followed by a post-termination hearing process. Source: 42 CFR 422.202, Participation Procedures
Can a Medicare Advantage plan terminate a provider who frequently appeals prior authorisation decisions?
No, if the termination is motivated by the provider’s appeals activity. Under 42 CFR 422.206, MA plans may not penalise any provider who advocates on behalf of a patient, including by requesting expedited determinations or appealing prior authorisation denials. A provider who is terminated because they frequently challenge plan coverage decisions has grounds for a federal complaint under 422.205 and 422.206. Plans that terminate high-appeals providers without a clearly documented, non-retaliatory basis for the termination (such as documented quality concerns or contractual violations) are at risk of civil rights complaints and CMS enforcement referrals. Source: 42 CFR 422.206, Prohibition of Interference with Provider Advice
How often must Medicare Advantage plans recredential providers?
42 CFR 422.204 requires MA plans to conduct credentialing and recredentialing of contracted providers. The regulation does not specify a fixed recredentialing interval, but CMS guidance and accreditation standards typically require recredentialing every two to three years. Recredentialing must verify that the provider’s licensure, training, experience, and competence remain current and that no new adverse actions (licensure discipline, malpractice settlements, OIG exclusions) have occurred since the last credentialing cycle. Plans must also continuously monitor for OIG exclusion status and remove excluded providers from the network immediately upon identification. Source: 42 CFR 422.204, Provider Selection and Credentialing
What enforcement actions can CMS take for Medicare Advantage provider compliance failures?
Under 42 CFR 422.750 through 422.760, CMS has a range of intermediate sanctions and civil money penalties available for MA plan non-compliance. For provider compliance violations, CMS may impose intermediate sanctions including a suspension of enrolment of Medicare beneficiaries, a suspension of payment, or a suspension of marketing activities. For systemic violations adversely affecting enrollees, CMS may impose civil money penalties up to $100,000 per violation per day under 42 CFR 422.760(b). In practice, network adequacy sanctions have been rare historically, but CMS’s move to assess network adequacy at the application stage signals an intent to use application denial more aggressively as a front-end enforcement mechanism. Source: 42 CFR 422.752, Intermediate Sanctions and Civil Money Penalties
Sources
Government and Regulatory Sources
- 42 CFR 422.112, Access to Services (Network Adequacy): the primary network adequacy regulation for MA plans, requiring sufficient contracted provider networks by service area to meet time, distance, and provider-to-member standards.
- 42 CFR 422.204, Provider Selection and Credentialing: requires MA plans to establish and apply provider selection criteria, conduct credentialing and recredentialing, and not exclude providers discriminatorily based on scope of practice.
- 42 CFR 422.520, Prompt Payment by MA Organisation: establishes the 30-day clean claim payment standard for non-contracted providers, the 60-day deadline for all other non-contracted claims, and the interest obligation for late payment of clean claims.
- 42 CFR 422.202, Participation Procedures: requires MA plans to establish provider participation procedures including fair hearing rights before provider termination except in imminent patient safety situations.
- 42 CFR 422.205, Provider Anti-Discrimination Rules: prohibits discrimination in provider selection against providers acting within their licence scope; prohibits exclusion of provider types covered by Medicare.
- 42 CFR 422.206, Prohibition of Interference with Provider Advice: prohibits MA plans from penalising providers who advocate on behalf of patients, including by filing prior authorisation appeals or requesting expedited determinations.
Industry and Analysis Sources
- KFF Health News: Medicare Advantage Network Adequacy Standards and Federal Enforcement (2024): FOIA-based investigation confirming only 5 network adequacy violation letters were sent by CMS to insurers from 2016 to 2022, and the MedPAC June 2024 finding that CMS has authority for CMPs for network adequacy violations but had never imposed them.
- Epstein Becker Green: Medicare Advantage Provider Network Adequacy Regulatory Changes for 2024: analysis of the CY2024 application-stage network adequacy assessment requirement under the 2023 MA and Part D final rule, including the shift from post-approval to pre-approval adequacy determination.
- Healthcare Finance News: Bipartisan Bill Would Accelerate Medicare Advantage Payments to Providers (2024): coverage of the 2024 bipartisan legislative proposal to set minimum in-network prompt payment standards (14 days for clean claims) aligned with out-of-network standards, reflecting the current absence of a federal in-network prompt payment floor for contracted MA providers.
- Neolytix: Your Practice Meets CMS Network Adequacy Rules, But Patients Still Cannot Get Appointments (2025): analysis of the structural gap between CMS network adequacy attestations (which measure network structure) and operational access (which measures whether patients can actually schedule appointments), and CMS’s decision not to finalize a requirement for plans to verify operational availability of listed providers.
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