The Future of MA Provider Directories: CMS Drops the Draft MPF Technical Guide!

Spoiler alert: Medicare Plan Finder (MPF) is getting an upgrade… and your provider directories are about to go real-time, structured, and API-powered.

CMS has released the Draft Technical Implementation Guide for Supplying Medicare Advantage (MA) Provider Directory Data for Use in Medicare Plan Finder (MPF) — and the industry has until December 19, 2025 to weigh in.

Grab your JSON, your FHIR endpoints, and maybe a cup of coffee. This is a fun one.

Why This Memo Matters

For years, beneficiaries have struggled with outdated or inconsistent provider directories.
CMS is fixing that — with technology.

Under CMS-4208-F2, MA Organizations must:

  • Make provider directory data available to CMS/HHS

  • Submit data in the formats/timelines CMS defines

  • Update within 30 days of any change

  • Attest annually (CEO, CFO, or COO) that the info is accurate

This memo introduces how MA plans are expected to technically deliver this data for MPF.

The Roadmap: CMS’s Three-Phase Rollout

CMS is easing the industry in with a phased approach — think of it like moving from flip phones → smartphones → AI assistants.

Phase 1: CY 2026 (Interim Fix)

CMS partners with SunFire Matrix to supply in-network provider and facility data for MPF.

  • Plans can opt out — but then MPF will show a directory link pulled from their HPMS “Organization Marketing Data” page.

  • Goal: Buy plans time to prepare for API-based submissions.

Phase 2: CY 2027 (Dual Option – Pick Your Tech Path)

This is where the big shift happens. Plans must supply their directory data using one of two formats:

Option 1 – Machine-Readable JSON Files

  • Modeled after ACA Marketplace requirements

  • Publicly accessible

  • CMS crawls them daily

Option 2 – FHIR-Based JSON APIs

  • Based on HL7 FHIR R4

  • Using Da Vinci PDex Plan-Net v1.2.0

  • No login/authentication allowed

  • CMS crawls these daily too

⚠ XML FHIR is not supported — JSON only.

What CMS will validate (daily):

  • URLs work

  • JSON/FHIR structure matches CMS specs

  • Required fields are present

  • Records cover all plan/segments

  • Data updated within last 30 days

But CMS does not validate accuracy. That’s on the MA plan.

Phase 3: National Provider Directory (Future State)

Announced at the White House Make Health Tech Great Again event on July 30, 2025.

CMS is building a FHIR-based national directory to connect:

  • Providers

  • Payers

  • Networks

  • Interoperability frameworks

Eventually → MPF will pull from this national directory, using plans’ FHIR APIs as its backbone.

What MA Plans Must Prepare (CY 2027 Workflow)

CMS outlines a very clear process:

1. Enter & maintain provider directory API URLs in HPMS

Available beginning Feb 2, 2026

2. Generate & publish:

  • Machine-readable JSON or

  • FHIR-based JSON APIs

3. CMS crawls your endpoints daily

Extract → ingest → validate.

4. Review validation results in HPMS

Plans must promptly fix issues.

5. Complete annual attestation

Due September 1, 2026 for CY 2027.

6. Join the plan testing period

May–August 2026

7. Preview MPF data

Early September 2026.

8. CMS suppressions may occur if:

  • API URLs don’t work

  • JSON/FHIR fails validation

  • Attestation is missing

  • Data quality crosses CMS “thresholds”

What Data Must Plans Send?

The guide includes full JSON & FHIR specs; highlights include:

For Individuals (Practitioners):

  • NPI

  • Full name

  • Specialty (NUCC)

  • Locations (address, phone)

  • Languages

  • Accepting new patients (optional)

  • Contract-Plan-Segment ID (e.g., H9999-001-000)

  • Last updated date

For Facilities:

  • NPI

  • Facility name

  • Facility type (NUCC)

  • Address

  • Plan participation

  • Updated timestamp

Technical expectations:

  • Support HTTP metadata (ETag, Last-Modified, Content-Length)

  • Support HEAD & conditional GET requests

Key Dates to Know

  • Nov 7, 2025 – Draft guide released

  • Nov 7 – Dec 19, 2025 – Public feedback window

  • Jan 16, 2026 – Final guide published

  • Feb 2, 2026 – HPMS URL entry opens

  • May–Aug 2026 – Testing period

  • Sept 1, 2026 – Attestation due

  • Oct 1, 2026 – CY 2027 data goes live on MPF

CMS Wants Your Feedback (Seriously)

Submit comments here: https://surveys.CMS.gov/jfe/form/SV_aeYUdIQZz96oBOm

Questions?
1-800-220-2028 | hpms@cms.hhs.gov

Final Takeaway

CMS is modernizing how provider directories flow into Medicare Plan Finder — moving toward a real-time, API-driven, standardized national ecosystem.

MA plans that prepare now (especially with FHIR) will have smoother testing, fewer suppressions, and a stronger compliance posture headed into CY 2027 and beyond.

Think of this as the warm-up lap for the National Provider Directory.
And the race has already started.