Why Regulators Are Suddenly Focused on a Problem Health Plans Have Faced for Years

Regulators have started paying closer attention to a term gaining traction in healthcare oversight: ghost providers. It refers to providers listed in a directory who are not actually available to see plan members, because they left the practice, stopped accepting the plan, or never really joined the network the way the directory suggests.  

An HHS OIG review published in October 2025 looked specifically at behavioral health networks in Medicare Advantage and Medicaid managed care. It found that many plans had limited behavioral health networks and that inactive providers further limited those networks. OIG noted that these inactive providers are sometimes referred to as “ghost” providers and can make networks appear larger than they actually are.  

Why this keeps happening without anyone intending it

A ghost listing rarely comes from bad intent. It comes from directory maintenance depending on someone remembering to remove a name. A provider retires, or a group dissolves a contract, and unless a specific person catches that change and acts on it, the listing simply persists. Multiply that across thousands of providers and dozens of delegated entities, and the gap between who is listed and who is actually seeing patients grows quietly, with no single event that forces anyone to notice.  

Why this is becoming a legislative priority

Regulators care about two things right now, and ghost providers touch both: member access to care, and the accuracy of the data that represents the providers available within their networks. A directory containing with inactive listings can make a network appear broader and more accessible on paper than it is in practice.  

That is one of the gaps the REAL Health Providers Act is designed to address. By requiring an annual, statistically sampled accuracy analysis, with specific attention to specialties like behavioral health, the law requires plans to systematically assess the accuracy of their directories rather than relying solely on a member complaint or an audit to surface problems.  

Where a ghost listing actually comes from

A psychiatrist leaves a group practice to join a hospital system. The group’s office manager updates internal scheduling but never sends formal notice to every plan the group contracted with, assuming, incorrectly, that credentialing handles it centrally. Eight months later, the directory still lists the psychiatrist at the group’s old address and phone number. A member in crisis calls it, reaches a disconnected line, and gives up rather than calling a second name from the same list.  

Nobody at the health plan made an obvious error. The listing simply never received the one signal that would have triggered its removal, because removal depended entirely on someone outside the plan remembering to send it.  

Why manual cleanup does not solve it

The instinct, when a ghost-provider problem surfaces, is to run a cleanup project: pull the directory, call every listed provider, remove the ones who do not respond or do not confirm. That works, once. It does not stay solved, because the underlying process that created the gap, provider changes depending on someone noticing, communicating, and acting on them, has not changed. Six months later, the same pattern starts rebuilding itself.  

The more durable fix is structural: verification that happens on a fixed cycle rather than only when someone remembers to run it, and a process that treats a provider’s failure to confirm status within a set number of days as a flag to resolve rather than a fact to ignore quietly. That is a process design question as much as a staffing question, and it is usually the first thing worth examining before adding headcount to the cleanup effort.  

The question worth asking internally

How would a health plan’s own provider operations team know, today, if a meaningful number of ghost providers were sitting in the directory right now? If the honest answer involves waiting for the next audit or a member complaint, that is worth changing before the REAL Health Providers Act’s reporting requirements make the answer more visible outside the organization.  

Authors profile

Katrina Huynh

Chief of Staff

Katrina Huynh is a healthcare strategy and operations leader with more than 15 years of experience, including over a decade working within Blue plans. Her experience spans health plan operations, enterprise strategy, client relationships, transformation, and strategic partnerships. As Director, Strategic Partnerships and Growth at MDI NetworX, she drives strategic partnerships, identifies growth opportunities, and translates organizational priorities into execution. With firsthand health plan experience, Katrina brings a broad perspective on how people, technology, data, and operations come together to create meaningful results. Known for bringing clarity to complexity and connecting people and capabilities, she is focused on advancing practical, high-impact solutions across healthcare operations.