How to Prepare for a CMS Online Directory Audit

How to Prepare for a CMS Online Directory Audit

Dec 21, 2018
  • Author:
    Cheryl Cisneros, BSN, RN, CPCS, CPMSM
    Consultant Advisor
    Cheryl provides management consulting services and is an experienced health care management professional with over 25 year's experience including credentialing, privileging, managed care, and provider enrollment.

The Centers for Medicare and Medicaid Services (CMS) recently released the results of the Medicare Advantage Organization (MAO) online provider directory reviews. This is the third round of annual audits reviewing 5,602 providers at 10,504 locations.


The results of the audit found that overall, 48.74% of provider locations had at least one deficiency. The importance of accurate provider directories is crucial to ensure a patient’s access to care.

Round One 45.10% Overall Inaccuracy

Round Two 55.07& Overall Inaccuracy

Round Three 48.74% Overall Inaccuracy

CMS’s goal is to drive industry improvement to provide accurate provider directories

Common provider types were selected as a focus for the three consecutive annual reviews. The provider types are Primary Care Physicians, Cardiologists, Oncologists, and Ophthalmologists. 50.14% of providers had at least one deficiency.

The top five Deficiency Types by Occurrence were reported:

    #1 Provider should not be listed in the directory at this location

    #2 Provider should not be listed at any of the directory-indicated locations

    #3 Phone Number needs to be updated (incorrect or disconnected)

    #4 Address needs to be updated

    #5 Address (suite number) needs to be updated

The findings suggest that Medicare Advantage Organizations are not adequately maintaining accurate directories.

CMS noted the following observations driving inaccurate provider directories:

  • Group practices continue to provide data at the group level than at the provider level.
  • A lack of internal review of directory by the MAOs.
  • Directory had been out of date for a long time – provider retired or deceased.

CMS issued compliance actions.

18 Non-Compliance Notices

15 Warning Letters

7 Warning Letters with a Request for Business Plan

What can you do to ensure successful outcomes and eliminate risk for CMS compliance actions?

Implement an internal audit process. CMS has provided the questions which they survey.

  1. Does the provider see patients at the location?
  2. Does the provider accept Medicare Advantage plan(s) at the location?
  3. Does the provider accept or not accept new patients who have a Medicare Advantage plan?
  4. Is the provider a PCP, cardiologist, oncologist, or ophthalmologist?
  5. Is the address correct?
  6. Is the telephone number correct?
  7. Is the provider name correct?
  8. Is the practice name correct?

Use this list in your internal reviews so you can answer “yes” when asked if your organization is ready for the next CMS Audit.