‍The new regulation requires accurate, updated, and searchable provider directories.

‍

As part of the Consolidated Appropriations Act 2023, Section 5123, mandates accurate, updated, and searchable provider directories for Medicaid and CHIP managed care entities. These directories aim to enhance accessibility and transparency for patients seeking health care services. The new regulation becomes effective on July 1, 2025.

‍

Previously, Medicaid and CHIP provider directory requirements varied based on delivery systems such as fee-for-service (FFS), primary care case management (PCCM), and managed care. While FFS and PCCM systems were mandated to maintain provider directories, managed care entities had more lenient requirements.

‍

Medicaid managed care provider directory requirements.

The new regulation [Section 5123 of the CAA 2023] extends provider directory requirements to Medicaid managed care entities, including managed care organizations, prepaid health plans, and PCCM entities. This includes:

• Publishing searchable directories of network providers on a public website, ensuring up-to-date information on physicians, hospitals, pharmacies, providers of mental health services, providers of substance use disorder services, providers of LTSS, as appropriate, and such other providers as required by the HHS Secretary. 
• Details on cultural and linguistic capabilities, telehealth services, and accommodations for individuals with disabilities.

‍

Medicaid FFS and PCCM system provider directory requirements. 

For states providing Medicaid services through FFS or PCCM systems, the regulation requires the publication of provider directories on the state's Medicaid website. 

• These directories must be updated quarterly, containing information on provider specialties, locations, contact details, cultural and linguistic capabilities, telehealth services, and accommodations for individuals with disabilities.

‍

CHIP provider directory requirements.

The regulation also extends Medicaid provider directory requirements to CHIP providers operating under FFS or PCCM systems. This ensures consistency across Medicaid and CHIP programs, enhancing transparency and accessibility for beneficiaries.

‍

Violet’s role in provider directory requirements. 

‍

Violet aims to streamline the ways that Medicaid managed care entities can add cultural and linguistic capabilities to their public searchable directories of network providers. These capabilities include languages offered by the provider or by a skilled medical interpreter who provides interpretation services at the provider’s office.

‍

Violet engages providers across networks, benchmarking cultural competence and collecting provider SOGI (Sexual Orientation and Gender Identity), and REaL (Race, Ethnicity, and Language) data on behalf of payers. This enables us to create a unified, dynamic provider record that seamlessly integrates into public plan directories through our API. Violet’s data goes beyond regulatory requirements, making it easy to ensure identity-centered care for BIPOC, LGBQ, and TGNC communities.

‍

The two most common approaches we’ve seen for assessing cultural abilities are self-attestation and lived experience. 

• Self-attestation, usually from a single tick box, is both a subjective and quite limited way of assessing competence, and leads to culturally diverse patients routing themselves to unverified providers who may or may not specialize in their communities. 
• Using lived experience as a proxy for cultural ability leads to a short supply of providers for routing and also leads to a disproportionate burden on providers with lived experience.

‍

At Violet, we believe that inclusivity is a skill that can be measured and improved. Violet Benchmarks are the industry’s first integrated assessment of cultural competence that can be used to assess providers across all specialties on their competence across communities most impacted by health disparities. This data, along with linguistic skills, can be used to seamlessly integrate with Medicaid managed care entity directories and help meet the growing health equity compliance and regulation measures.

‍