REAL Act MA Plan Compliance Leaderboard — Q2 2026
Per-Medicare-Advantage-plan directory accuracy compliance scores under the REAL Act (ACA §1002 / 42 CFR §422.111). Completeness, currency, accuracy, and ghost-network risk scored from NPPES, CMS Care Compare, and PECOS cross-source data. Q2 2026 issuance.
Contents · 5 sections
Executive Summary
- The REAL Act requires Medicare Advantage plans to maintain accurate provider directories. CMS enforces compliance via quarterly audits with civil monetary penalty exposure.
- Fonteum scores each MA contract on four dimensions: directory completeness (NPIs present in cross-source data), currency (NPIs updated within 90 days), accuracy (field-level agreement from the PDAI engine), and ghost-network risk (NPIs absent from CMS Care Compare).
- Scores are computed from the same cross-source engine that powers the Provider Directory Accuracy Index (PDAI), applied at the plan level. All data is federal public record.
- The composite score (equal-weight average of four sub-scores) drives the A–F compliance grade displayed on the leaderboard. Plans with fewer than 50 matched NPIs are flagged as insufficient-sample.
- Publishes quarterly — Q1 in March, Q2 in June, Q3 in September, Q4 in December. Four earned-media cycles per year targeting MA compliance officers and state AG offices.
At a glance — for journalists, researchers, and AI agents
What this dataset covers
- Per-Medicare-Advantage-plan directory accuracy compliance scores under the REAL Act (ACA §1002 / 42 CFR §422.111). Completeness, currency, accuracy, and ghost-network risk scored from NPPES, CMS Care Compare, and PECOS cross-source data. Q2 2026 issuance.
What this dataset does NOT cover
- Fonteum analysis is not a quality measurement of any individual provider.
- Counts and rankings describe the Fonteum-indexed or source-published dataset, not the entire U.S. market.
Sources
- CMS NPPES
- CMS Care Compare
- CMS PECOS
- CMS MA Plan Landscape
Snapshot date: Q2 2026
Dataset scope · Snapshot June 15, 2026
Includes: the healthcare-provider records this study covers, each tracing to a dated public-record source named in the citation footer. Does not include: providers outside the source named for this study, or records not present in that source at the snapshot date. Counts describe this Fonteum healthcare-provider dataset — not a representative census of the U.S. healthcare workforce.
Key findings
Overview
The REAL Act MA Plan Compliance Leaderboard ranks Medicare Advantage plans by their directory accuracy compliance posture under 42 CFR §422.111.
Each plan is scored quarterly on four dimensions derived from Fonteum's cross-source NPI agreement data (NPPES, CMS Care Compare, PECOS):
- Completeness: Are the plan's listed NPIs findable in federal public records?
- Currency: Have those NPIs been updated in NPPES within the past 90 days?
- Accuracy: Do the plan-listed provider attributes (address, specialty, phone) match across federal sources?
- Ghost-network risk: Are the plan's listed providers actually present in CMS Care Compare — or are they "ghost" listings with no CMS-curated record?
The composite score (equal-weight average) drives the A–F compliance grade.
Methodology
Scoring methodology: real-act/v1. Full details at /research/real-act-compliance/methodology.
Data sources: NPPES NPI Registry (CMS), CMS Care Compare, PECOS (Medicare enrollment), CMS MA Plan Landscape File. All Tier-2 federal public records under US-Government-Works license.
Statutory cite: ACA §1002 / 42 CFR §422.111 (directory accuracy requirements for MA organizations).
Limitations
- This study's findings are scoped to the dataset and time window described in the methodology. They do not constitute medical, legal, or financial advice.
- Fonteum does not independently rate, inspect, verify, endorse, or guarantee any provider referenced in this study.
Methodology
Read the full methodology
Each Medicare Advantage contract is scored on four equal-weight sub-scores (0–1) computed by the same cross-source engine that powers the Provider Directory Accuracy Index (PDAI): completeness (share of plan NPIs found in Fonteum's combined NPPES + CMS Care Compare + CMS PECOS data), currency (share of NPIs with an NPPES update within the trailing 90 days), accuracy (field-level agreement rate drawn from the PDAI comparison vectors), and ghost-network risk (the inverse fraction of plan NPIs absent from CMS Care Compare). The composite score is the equal-weight average of the four sub-scores and drives the A–F compliance grade shown on the leaderboard; contracts with fewer than 50 matched NPIs are flagged insufficient-sample and excluded from ranking. All inputs are federal public records — NPPES, CMS Care Compare, CMS PECOS, and the annual CMS MA plan landscape file. Methodology version: real-act/v1.
Each Medicare Advantage contract is scored on four equal-weight sub-scores (0–1) computed by the same cross-source engine that powers the Provider Directory Accuracy Index (PDAI): completeness (share of plan NPIs found in Fonteum's combined NPPES + CMS Care Compare + CMS PECOS data), currency (share of NPIs with an NPPES update within the trailing 90 days), accuracy (field-level agreement rate drawn from the PDAI comparison vectors), and ghost-network risk (the inverse fraction of plan NPIs absent from CMS Care Compare). The composite score is the equal-weight average of the four sub-scores and drives the A–F compliance grade shown on the leaderboard; contracts with fewer than 50 matched NPIs are flagged insufficient-sample and excluded from ranking. All inputs are federal public records — NPPES, CMS Care Compare, CMS PECOS, and the annual CMS MA plan landscape file. Methodology version: real-act/v1.