Section 1: Program Overview
Q: What is Medicare Plan Finder (MPF) Phase II?
A: As part of CMS-4208-F2, all payers offering Medicare Advantage (MA) plans must supply provider directory data for all individual (not employer-only) MA plans to CMS, for display on Medicare Plan Finder, beginning with Contract Year (CY) 2027. Data is submitted as either Machine-Readable JSON files or FHIR-based JSON files, made available via a URL entered in the payer's HPMS system. CMS crawls and validates this URL daily. Plans are responsible for the accuracy of the data and must attest to it annually.
Q: Which method is RevSpring using to support clients?
A: RevSpring is generating FHIR-based JSON files, packaged behind a per-contract-number/per-contract-year index file, hosted at a dedicated publicly accessible URL. RevSpring does not expose a live, queryable FHIR endpoint for this requirement — CMS crawls and downloads static, pre-built files only.
Q: Who must comply with this requirement?
A: Provider directory data must be supplied for all individual (not employer-only) MA plans, including: Local Coordinated Care Plans (CCP) — HMO, HMO-POS, and Local PPO; Regional PPO plans; Medical Savings Account (MSA) network-based plans; and Private Fee-for-Service (PFFS) network-based plans.
Q: What are the key CMS dates for Phase II?
| Date | Milestone |
|---|---|
| Feb 2, 2026 | API URL data entry fields become available in HPMS |
| Feb 18, 2026 | Publication of updated/final technical implementation guidance |
| May 1, 2026 | Updated Technical Implementation Guide, memo, and FAQs published |
| May 4 – Aug 31, 2026 | CMS plan testing period (machine-readable and FHIR-based JSON) |
| Jul 10, 2026 | Deadline to enter both the MPF Provider Directory URL and the FHIR Provider Directory API Endpoint in HPMS (per June 24, 2026 CMS memo) |
| Sept 1, 2026 | CY 2027 HPMS attestation deadline |
| Early Sept 2026 | CMS plan preview window |
| Sept 18, 2026 | CMS “target” date for production-ready CY 2027 data |
| Oct 1, 2026 | Production release of the CY 2027 Medicare Plan Finder |
Section 2: Data Requirements
Q: What data is being transferred to CMS?
A: CMS receives provider and facility data for all individual (not employer-only) MA plans: Local CCP (HMO, HMO-POS, Local PPO), Regional PPO, MSA network-based, and PFFS network-based plans.
Q: In Phase I there was a PCP ID requirement — is that still needed?
A: No. The concept of PCP ID used in Phase I is no longer relevant. NPI is the required identifier moving forward.
Q: Must supplemental benefit provider types (dental, vision, hearing) be included?
A: Yes. All contracted providers, including those administering supplemental benefits, must be included in the MPF MA provider directory data.
Q: Should Part D pharmacy data be included?
A: No. CMS collects Part D pharmacy network data for MPF through a separate, existing bi-weekly HPMS process.
Q: Should provider groups be included as a single entry?
A: No. Organizations should include the individual providers that comprise a group separately, rather than the group as a whole.
Q: What does the “Last Updated” field represent?
A: It represents the date a record was last updated on the MA organization's FHIR server.
Section 3: File Format & Data Transfer
Q: Is RevSpring exposing a live FHIR endpoint to CMS for MPF?
A: No. RevSpring exposes publicly accessible MPF Provider Directory URL(s) that lists flattened, FHIR-based JSON files, which CMS crawls on a schedule. A queryable FHIR endpoint is not used for this requirement.
Q: Will the MPF Provider Directory URL(s) provided by RevSpring change?
A: RevSpring does not currently expect the URL(s) to change. If a change becomes necessary, advance communication will be provided to clients.
Q: How frequently will CMS crawl the MPF Provider Directory URL(s)?
A: CMS crawls the URL(s) per contract ID daily, generally overnight Eastern Time, and posts validation results by mid-to-late morning the same day.
Q: How frequently are the underlying FHIR-based JSON files refreshed?
A: RevSpring refreshes the FHIR-based JSON files almost daily. At minimum, CMS requires the data be refreshed at least every 30 days to remain compliant.
Q: Are any third parties involved in the data transfer to CMS?
A: To RevSpring's knowledge, no third parties are involved in Phase II. Phase II is intended to be a direct data exchange between plans (via RevSpring) and CMS.
Q: Does CMS require the hosted files to be on a FHIR-compliant server?
A: No. CMS only requires that the index file and constituent JSON files be hosted at a dedicated, publicly accessible URL — not that the hosting server itself be FHIR-compliant.
Q: Can files be compressed (.zip/.gzip) or must they be plain JSON?
A: CMS does not support compressed file delivery. Hosted files must be plain JSON, and CMS recommends no single file exceed 300 MB.
Section 4: Testing & Validation
Q: What exactly is CMS validating? Is CMS checking data accuracy?
A: CMS is not validating the accuracy of the underlying data. CMS validates that: (1) the provider directory URLs in HPMS are functional and publicly accessible; (2) the JSON/FHIR files meet CMS's technical specifications; (3) the data meets CMS's field-level specifications; (4) records exist for all individual plan/segments offered; and (5) the directory has been updated within the last 30 days.
Q: Who validates the data before it's sent to CMS?
A: RevSpring validates that: the MPF Provider Directory URLs are functional and accessible; the FHIR-based JSON files meet CMS's technical and field-level specifications; and the directory has been updated at least every 30 days. The client is responsible for ensuring RevSpring receives accurate underlying data — CMS does not validate accuracy, and neither does RevSpring's technical check.
Q: What are the three levels of CMS validation findings?
| Level | Meaning | Impact on MPF |
|---|---|---|
| 1 – Fatal Error | Structural failure (e.g., malformed JSON, hosting issue) that prevents CMS from reading the file. | Entire dataset rejected; nothing shown on MPF until resolved. |
| 2 – Record-Level Error | A specific record has invalid or incomplete data. | That record is withheld from MPF; rest of the dataset still processes. |
| 3 – Informational Warning | A potential issue is flagged for review. | Data still appears on MPF; plan should remediate promptly. |
Q: When will validation results be available, and how?
A: In May 2026, CMS performed a modified review and shared results with the plan's HPMS-listed Medicare Compliance Officer, Medicare Coordinator, System, and Interoperability contacts. Beginning in early June 2026, CMS moved to a fully automated process, with results available directly via the HPMS MPF Provider Directory module or API.
Q: Which contract-year reference data does CMS use during testing?
| Phase | Timeframe | Reference Data Used |
|---|---|---|
| Testing Period 1 | Until early July 2026 | Approved CY 2026 contract and plan data from HPMS |
| Testing Period 2 | Early July – mid-Sept 2026 | “As submitted” CY 2027 contract and plan data from HPMS |
| Production | Starting mid-Sept 2026 | Approved CY 2027 contract and plan data from HPMS |
Q: Can clients test using their CY 2026 directory instead of CY 2027?
A: Yes. Plans may use their CY 2026 directory for testing purposes, since CY 2027 data is still fluid. CMS used CY 2026 approved data for validation purposes early in the testing window, then transitioned to CY 2027 as that data stabilized.
Section 5: Attestation & Contract Years
Q: Who is responsible for completing the annual attestation?
A: A designated signatory at the MA organization — specifically the CEO, CFO, and/or COO — must complete the attestation electronically in HPMS, confirming the provider directory data is accurate, complete, and truthful.
Q: When is the CY 2027 attestation due?
A: No later than September 1, 2026.
Q: Will CMS be collecting practitioner-level attestation dates?
A: No. CMS is not collecting attestations from individual practitioners or providers as part of this effort — only the organizational, annual attestation described above.
Q: How will CMS handle the transition between contract years (e.g., removing old years, adding new ones)?
A: CMS has indicated it will address the contract year switchover process in future guidance.
Section 6: Process, Workflow & Support
Q: Will CMS continue sending error reports after MPF goes live, or only during testing?
A: Error reports will be delivered by CMS directly into the plan's HPMS system, both during testing and during ongoing production crawls.
Q: If a client's data changes, how quickly must that be reflected?
A: At minimum, provider directory data must be updated within 30 days of when a change is identified, per existing MA provider directory guidance that MPF follows.
Q: How long after a new data set is generated will the URL reflect it?
A: The MPF Provider Directory URL is defined at the contract ID / contract year level and does not change as new files are generated — the underlying file(s) behind that URL are simply refreshed in place.
Q: Is there a requirement to notify beneficiaries about Medicare Plan Finder?
A: Medicare Plan Finder is a CMS-provided tool available to all beneficiaries. RevSpring is not aware of any requirement for health plans to proactively notify members about this specific feature.
Q: What is the difference between the “MPF Provider Directory URL” and the “FHIR Provider Directory API Endpoint” that CMS asked for by July 10, 2026?
A: These are two distinct CMS requirements that were communicated together in the June 24, 2026 memo, but originate from different rules:
- MPF Provider Directory URL — required under CMS-4208-F2 for the MPF initiative itself. This is the index file URL that RevSpring generates and provides as part of standard Provider Directory support.
- FHIR Provider Directory API Endpoint — required under the separate, pre-existing Interoperability and Patient Access final rule (CMS-9115-F, effective July 1, 2021). This is a live, public, no-authentication FHIR base URL. It is only available through RevSpring's separate FHIR Provider Directory API add-on service; clients who already maintain their own compliant endpoint under CMS-9115-F should enter that URL directly.
Q: Where can clients get technical support?
| Topic | Contact |
|---|---|
| HPMS access, URLs, attestation, plan preview | HPMS Help Desk — 1-800-220-2028 / hpms@cms.hhs.gov |
| Machine-readable / FHIR-based JSON files & validation results | support@cms-mapnet.zendesk.com |
| HPMS provider directory validation API | hpmstechsupport@triafed.com |
| General MPF questions | MPF@cms.hhs.gov |
| RevSpring-specific questions | Your assigned Customer Success Partner |