Network adequacy loopholes let insurers sell plans with zero nearby specialists

Insurers in ACA marketplace plans list specialists in their provider directory who are not accepting new patients, have retired, or are located 90+ miles away, technically satisfying network adequacy requirements while leaving enrollees with no practical access to care. A patient in rural Texas who buys a Silver plan expecting dermatology coverage discovers the only listed dermatologist is 3 hours away and booked 8 months out, effectively making the coverage useless. State regulators require insurers to submit provider directories annually, but directories are stale within weeks because there is no real-time verification system and no penalty for inaccuracy. Insurers benefit from "ghost networks" because narrow networks reduce claim volume, and enforcement requires individual patient complaints that most people never file.