ACS CAN Comments on National Provider Directory RFI

December 1, 2022

The American Cancer Society Cancer Action Network (ACS CAN) appreciates the opportunity to comment on the Request for Information (RFI) regarding a national directory of health care providers and services. ACS CAN is making cancer a top priority for public officials and candidates at the federal, state, and local levels. ACS CAN empowers advocates across the country to make their voices heard and influence evidence-based public policy change, as well as legislative and regulatory solutions that will reduce the cancer burden. As the American Cancer Society’s nonprofit, nonpartisan advocacy affiliate, ACS CAN is more determined than ever to end cancer as we know it, for everyone.

We are pleased the Department is considering the creation of a National Directory of Healthcare Providers and Services (NDH). Consumers often find it challenging to find providers within their plan networks and, despite federal and state rules, provider directories are not always updated in a timely manner which can result in consumers inadvertently seeking care from an out-of-network provider. Having a well-maintained single repository of providers and the health plans to which they have contracted can help consumers make more informed choices.

An NDH can also aid researchers in a variety of health care service delivery research, particularly with regard to changes in the breadth of plan networks. Also, as noted in the preamble, it can reduce provider burden if the ultimate goal is to require providers to report any changes to the NDH system rather than multiple other systems.[1] Current provider directories require redundant reporting from providers, rarely support interoperable date exchange, and often contain inaccurate information that requires staff time to address. In addition, utilizing a single NDH could potentially save physician practices collectively over $1 billion annually.[2]


[1] The Department estimates that providers must update their directory information for an average of 20 different payers per practice. 87 Fed. Reg. at 61019 (citing CAQH. 2019. The Hidden Causes of Inaccurate Provider Directories. Retrieved from

[2] Id.