Ghost networks list unavailable providers in over 50% of health plan directories, causing patients to discover they have no accessible in-network care only after enrollment
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Health insurance provider directories contain listings for physicians who have retired, moved, died, left the network, or are not accepting new patients. Studies show that more than half of all directory entries contain errors. Medicare Advantage plans include just 48% of doctors who accept traditional Medicare. Patients select health plans based on these directories during open enrollment, then discover months later that listed providers are unavailable, leaving them unable to access care without paying out-of-network rates.
Why it matters: Patients who chose their plan specifically for a listed specialist discover that specialist is unavailable, so they must either pay out-of-network rates (often 3 to 5 times higher) or wait weeks to find an alternative in-network provider, so continuity of care is disrupted for patients with chronic conditions who need consistent specialist relationships, so patients delay or forgo necessary care entirely, so health outcomes deteriorate for the most medically complex patients who are most dependent on specialist access.
The structural root cause is that CMS had not imposed any sanctions on health plans for network adequacy failures as of 2024, according to ProPublica's investigation. Maintaining accurate directories requires continuous verification with thousands of providers, which costs insurers money. Inaccurate directories that inflate apparent network size help insurers attract enrollees during open enrollment, and the cost of directory inaccuracy is borne entirely by patients who only discover the problem after they are locked into their plan for the year.
Evidence
KFF report found Medicare Advantage plans include just 48% of doctors who accept traditional Medicare. ProPublica investigation (2024) found CMS had imposed zero sanctions on health plans for network adequacy failures. In 2024, EmblemHealth agreed to a $2.5 million settlement with the New York Attorney General for failing to fix mental health provider directory errors, the largest such fine secured by the AG's office. Multiple class action lawsuits have been filed reframing ghost networks as ERISA fiduciary duty breaches (American Bar Association, 2025). Source: KFF, ProPublica, NY AG Office, ABA.