June 29, 2026

The Honorable Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

RE: Section 6220 Provider Directory Meeting – Written Comment

Submitted electronically via partnership@cms.hhs.gov

Dear Administrator Oz:

The Workgroup for Electronic Data Interchange (WEDI) is pleased to provide comments on the implementation of the Requiring Enhanced and Accurate Lists (REAL) Health Providers Act, Section 6220 of the Consolidated Appropriations Act, 2026, and its provisions addressing provider directory accuracy in Medicare Advantage Organizations while reducing administrative burden.

WEDI was formed in 1991 by then Department of Health and Human Services (HHS) Secretary Dr. Louis Sullivan to identify opportunities to improve the efficiency of health data exchange. Named in the Health Insurance Portability and Accountability Act (HIPAA) legislation as an advisor to the Secretary of HHS, WEDI is the leading multi-stakeholder authority on the use of health information technology (IT) to efficiently improve health information exchange, enhance care quality, and reduce costs. With a focus on advancing standards for electronic administrative transactions, and promoting data privacy and security, WEDI is recognized and trusted as a formal advisor to the Secretary. Our diverse membership includes health plans, providers, standards development organizations (SDOs), health IT vendors, clearinghouses, federal and state government agencies, and patient advocacy organizations.

WEDI supports efforts to improve provider directory accuracy and reduce the administrative and financial burden experienced by patients when inaccurate information limits access to care. Accurate provider information is essential to ensure that patients can identify participating providers, make informed health care decisions, and access services without unnecessary delays or confusion. At the same time, we urge the Centers for Medicare & Medicaid Services (CMS) to ensure that implementation of Section 6220 balances directory accuracy goals with the operational realities faced by providers, health plans, and other stakeholders. Any national approach should reduce administrative burden and avoid additional reporting requirements that duplicate existing processes.

General Principles

WEDI has been actively engaged in the needs and functionalities of provider directories through our Provider Information Subworkgroup, which focuses on identifying and addressing business issues that impact the transmission and receipt of provider directory data. The subworkgroup focuses on understanding the complexities and nuances of provider data, while examining industry successes, challenges, and best practices for obtaining and maintaining accurate, timely information. Through our diverse, multi-stakeholder membership, we are well-positioned to collaborate with CMS and other industry partners in ongoing efforts to improve provider directory data collection, exchange, and accuracy across the health care ecosystem.

Our work on provider directory issues has identified the following general principles:

1. Improve provider directory accuracy
2. Minimize administrative burden on impacted stakeholders
3. Leverage existing authoritative data sources
4. Promote standards-based data exchange
5. Support thorough testing prior to rollout
6. Encourage public and private sector collaboration

WEDI believes a strong national strategy incorporating these general principles will result in a higher quality provider directory that will better support the needs of impacted stakeholders, most of all, patients.

1. Improve provider directory accuracy

The accuracy of provider directory information is critical to ensuring patients can locate and access appropriate care when they need it. Patients rely on provider directories to identify participating providers, verify practice locations and contact information, determine whether providers are accepting new patients, and understand network participation. When directory information is inaccurate, patients may experience delays in care, unnecessary administrative burdens, unexpected out-of-network costs, and frustration navigating the health care system.

As CMS advances a provider directory, ensuring the accuracy, completeness, and timeliness of provider information should remain a central objective. Achieving this goal will require an efficient reporting framework, strong validation process, robust data verification process, and ongoing collaboration with stakeholders to promote timely data maintenance.

WEDI urges CMS to consider the following actions:

• Adopt a multi-source verification framework to improve data accuracy by leveraging third-party verification services, existing administrative data sources, and trusted public and private sector datasets to validate provider information, identify discrepancies, and enhance the overall quality of data.
• Prioritize targeted outreach for verification efforts based on identified discrepancies, data anomalies, inactivity indicators, or other risk-based triggers rather than routine outreach to all providers.
• Offer multiple methods for reporting and accessing provider data to accommodate the diverse needs of provider types and varying levels of technical abilities.
• Leverage public and private sector data verification resources by using available sources, such as IRS tax identification databases and other trusted datasets, to validate information and notify providers when discrepancies, errors, or data gaps are identified.
• Establish a predictable and regular update cadence that allows providers and other stakeholders to incorporate directory maintenance activities into workflows.

2. Minimize administrative burden on impacted stakeholders

Reducing administrative burden should be foundational in the development of the provider directory. Today, providers are often required to submit and maintain similar information across multiple federal programs, health plans, and other entities, creating duplicative reporting requirements. These burdens can be particularly challenging for small, rural, and under-resourced providers that have limited administrative capacity. CMS can reduce unnecessary duplication by creating a more coordinated and efficient approach to provider information management. CMS should also focus any new provider directory reporting or verification process on replacing existing duplicative outreach activities rather than creating an additional layer of provider obligations.

WEDI urges CMS to consider the following actions:

• Design provider directory reporting and review processes for ease of use by streamlining and simplifying the reporting, review, and update processes to minimize administrative burden and encourage timely provider participation.
• Leverage provider directory data collection to eliminate duplicate reporting requirements across federal programs by enabling providers to submit information once and allowing applicable federal plans and programs to access and use that data.
• Consider a federated data collection approach in which the provider directory serves as a centralized repository that receives data feeds from trusted public and private sector sources, reducing provider reporting burden while improving scalability and data quality.
• Work with state and local governments to harmonize reporting requirements by aligning provider directory data requirements across jurisdictions to reduce variation and minimize administrative burden.

3. Leverage existing authoritative data sources

Maintaining accurate provider directory information remains a significant challenge, with providers often required to submit the same information to multiple entities. By leveraging existing authoritative data sources, such as the National Plan and Provider Enumeration System (NPPES) and the Provider Enrollment, Chain, and Ownership System (PECOS), CMS can address these challenges and create a more efficient data collection and validation process while alleviating duplicative reporting requirements.

WEDI urges CMS to consider the following actions:

• Explore leveraging existing authoritative federal data sources, including NPPES and PECOS, as primary sources for provider demographic, practice location, and enrollment information whenever possible.

• Identify and align with existing sources of provider information by inventorying federal, state, and private-sector data sources and leveraging validated information to populate the provider directory where appropriate.

• Establish a "collect once, use many" approach that allows provider data submitted through NPPES, PECOS, or other approved sources to populate the provider directory.
• Develop a multi-source verification framework that combines authoritative federal data sources, existing administrative data, and third-party validation resources.
• Establish privacy and data governance controls to ensure that provider directory data sharing and publication do not result in unintended disclosure of personally identifiable information or other non-public data elements.

4. Promote standards-based data exchange

A standards-based approach will improve scalability, reduce costs, and support real-time or near-real-time updates across participating organizations. Adoption of industry-recognized, national standards promotes consistency in data elements, formats, and exchange processes, enabling all stakeholders to more efficiently collect, maintain, and disseminate directory information. CMS should consider mature, widely implemented standards, while also supporting other options that meet the technology capabilities of the provider, including APIs, online portals, spreadsheet uploads, and document-based submissions. At the same time, CMS should provide education, tutorials, and technical assistance to help organizations transition from manual reporting processes to more automated, standards-based approaches over time.

WEDI urges CMS to consider the following actions:

• Establish a common core provider data set across federal programs to provide consistency in data requirements, reduce duplicative reporting efforts, and enable the efficient exchange of accurate provider data establishing the source of truth for all government programs and allowing private and public payers to connect, including through Medicare and Medicaid.
• Offer multiple options for reporting and accessing provider data by supporting a range of data exchange methods to accommodate the diverse technical capabilities of participating providers and reporting entities.
• Support ongoing standards development efforts by collaborating with industry stakeholders and SDOs to promote interoperability, advance consistent data exchange, and ensure the provider directory can evolve with industry needs.
• Align implementation of the REAL Health Providers Act with broader HHS provider directory initiatives to promote consistent data standards, governance structures, privacy protections, and provider data exchange processes across federal programs.

5. Support thorough testing prior to rollout

Thorough testing prior to rollout is critical for smooth implementation and successful user experience. CMS should pilot the provider directory and data collection and dissemination processes with a diverse group of stakeholders, including patients, prior to the final rollout. This approach will help identify usability challenges, validate reporting workflows, assess data quality, and ensure the system supports the needs of all participants. CMS should use feedback gathered during pilot testing to refine and improve the provider directory before its required use.

WEDI urges CMS to consider the following actions:

• Pilot test the provider directory with a diverse range of stakeholders prior to deployment.
• Engage a broad range of provider types and organizations during testing to ensure the provider directory can accommodate varying operational processes, technical capabilities, and data reporting needs.
• Incorporate end-user and stakeholder feedback into ongoing improvements by testing, refining, and updating the provider directory as needed.

6. Encourage public and private sector collaboration

The success of the provider directory will depend on broad stakeholder participation and adoption. CMS should consider establishing a framework that allows for impacted stakeholders to collaborate on its development and provide detailed needs for the technical capabilities. In addition to collaboration, CMS should provide education to ensure that stakeholders are well-prepared to use the provider directory. Smaller and less technically capable organizations will need education, technical assistance, and support to understand the provider directory requirements and transition to automated reporting approaches.

• Engage stakeholders in ongoing provider directory improvement efforts by collaborating with impacted stakeholders to identify best practices, address operational challenges, and continuously improve the quality and usability of provider directory data.
• Provide education and technical assistance to stakeholders to support the transition to automated reporting approaches.

Conclusion

WEDI supports the goals of the REAL Health Providers Act and believes that meaningful improvements in provider directory accuracy can be achieved through collaboration, standardization, and thoughtful implementation. Success will depend on balancing accountability with administrative simplification, leveraging existing data assets, and ensuring that impacted stakeholders, including patients, all benefit from a coordinated national strategy.

We appreciate the opportunity to provide these comments and look forward to continued collaboration with CMS as this important work moves forward. Please contact Robert Tennant, WEDI Executive Director, at rtennant@WEDI.org with any questions on these comments.

Sincerely,

/s/

Merri-Lee Stine
Chair, WEDI

cc: WEDI Board of Directors