DataSpring powered by CAQH
Maryland Insurance Administration
Attn: Jessica Blackmon, Government Relations and Regulatory Affairs Specialist 200 St. Paul Place,
Suite 2700
Baltimore, Maryland 21202
August 10, 2026
Re: Draft Proposed Regulation 31.10.52 – Provider Directory Requirements
Dear Ms. Blackmon,
DataSpring, powered by CAQH, appreciates the opportunity to submit comments to the Maryland
Insurance Administration (MIA) regarding draft proposed regulation 31.10.52-Provider Directory
Requirements.
Provider directory accuracy is a significant challenge across the health care industry impacting
access to care and perpetuating provider burden. A recent U.S. Department of Health and Human
Services Office of Inspector General report highlights these challenges particularly related to
maternal care access [1]. Additionally, our own research indicates provider organizations continue to
face significant administrative burden from current manual provider directory information
verification methods, with many practices fielding frequent, lengthy phone-based requests that
disrupt workflows, reduce time for patient care, and contribute to longer patient wait times.
Passage of Maryland HB 1093/SB 808 and federal enactment of the REAL Health Providers Act and the
No Suprises Act all seek to improve provider directories. We applaud MIA for proposing regulations
that support patients’ access to care and minimize burden through provisions that support
streamlined provider directory activities and concurrently heighten the accuracy of directory data.
We appreciate the Commissioner’s recent designation of DataSpring in Bulletin 26-20 [2] to serve as
“the system … designated by the Commissioner for use by providers to submit new and updated
directory information to carriers.” We recognize MIA intends to establish minimum standards for the
review of provider directories through these proposed regulations. DataSpring shares the goals
reflected in the proposed regulations to improve provider directory accuracy for consumers, clarify
carrier obligations, reduce administrative burden among providers and carriers alike, and ensure
that consumers, carriers, providers, and regulators have access to reliable provider information.
¹ U.S. Department of Health and Human Services, Office of the Inspector General. “Inaccurate
Medicaid Managed Care Provider Directories May Limit Enrollees’ Access to Maternal Health Care.”
June 2026. https://oig.hhs.gov/documents/evaluation/11709/OEI-05-24-00090.pdf
² Maryland Insurance Administration. Bulletin 26-20: “Provisional Designation of Uniform
Credentialing Form and Multi-Carrier Common Online Provider Directory Information System. July 24,
2026.
https://insurance.maryland.gov/Pages/Bulletins/Bulletin-26-20.aspx
For more than 25 years, DataSpring has united providers, carriers, and other healthcare
organizations to improve the efficiency of data collection and improve the accuracy of essential
information to help the healthcare system operate effectively. Today, DataSpring maintains the
largest and most complete healthcare data foundation in the country, including more than 4.8
million full provider data records sourced directly from providers across all 50 states and the
District of Columbia and augmented by third-party data sources.
DataSpring’s nationally scaled Provider Data Portal (PDP) supports the efficient and streamlined
collection, maintenance, validation and sharing of provider information for credentialing,
directory management and related administrative functions. Providers and authorized practice
administrators enter, update, and attest to professional and practice information once, then
authorize that information to be shared with participating carriers and other approved
organizations. We augment and validate provider-supplied data against additional third-party
sources and produce a single reliable provider data record. This one-to-many model reduces
payer-by-payer outreach to providers, limits duplicative attestation requests, and helps minimize
conflicting records across carrier systems through a single source of truth.
We offer the following recommendations for proposed COMAR 31.10.52-Provider Directory Requirements:
- Update the definition of CAQH to reflect DataSpring.
- Incorporate the statutory requirement for carriers to use the online credentialing system as the primary source for creating and updating provider directories beginning January 1, 2027.
- Align directory refresh standards with federal cadences.
- Clarify whether penalty assessments account for good-faith use of DataSpring data.
- Support education to providers about new regulatory requirements.
Update the “CAQH” Definition to Reflect DataSpring
In June 2026, CAQH rebranded as DataSpring, powered by CAQH. Our legal entity remains CAQH, but to
better reflect our new brand, we respectfully request the following definitional change of “CAQH”:
“CAQH” means the Council for Affordable Quality Healthcare d/b/a DataSpring or its successor, which
offers an electronic system that simplifies data collection to support carriers’ credentialing and
provider data needs including the creation and updating of provider directories.
Incorporate the Statutory Requirement Regarding the Use of Online Credentialing System
HB 1093/SB 808 added new subsection (p)(3) into Insurance Article, §15-112 stating, “A carrier
shall use the online credentialing system as the primary source of information to create and update
the carrier’s provider directory in accordance with regulations adopted by the Commissioner”
beginning January 1, 2027. However, the proposed regulations omit this requirement despite its
critical relevance to the creation and maintenance of provider directories. To ensure clarity and statutory
alignment, we respectfully recommend two amendments:
1. Add the following definition of “online credentialing system” into Section .01:
“Online credentialing system” has the meaning stated in Insurance Article §15–
112(a), Annotated Code of Maryland.
2. Incorporate the requirement to use the online credentialing system as a new section in the
regulations:
.0X Use of Online Credentialing System
Beginning January 1, 2027 a carrier shall use the online credentialing system as the primary source
of information to create and update the carrier’s provider directory in accordance with
§15-112(p)(3)(i), Annotated Code of Maryland.
Align Directory Data Refresh Standards
Proposed Section .05 (F) allows carriers to rely on a provider’s attestations made through
DataSpring’s system within the past 120 days, a cycle dictated by the National Committee for
Quality Assurance for provider credentialing standards. Conversely, federal policy framework under
the No Surprises Act and the REAL Health Providers Act established directory-specific refresh
cadences at least once every 90 days. The DataSpring PDP allows for this refresh cadence and
therefore we respectfully request this update, which supports current directory data while
preserving the administrative efficiency of a centralized, one-to-many provider workflow.
Consider Good-Faith Use of DataSpring Data
Bulletin 26-20 designated DataSpring as “the system … for use by providers to submit new and
updated directory information to carriers” and requires carriers to “accept new and updated network
directory information for a provider submitted through DataSpring or directly to the carrier.” In
addition, current Insurance Article §15-112(p)(6) and §15-112(p)(7) effective January 1, 2027,
identifies factors the Commissioner must consider before imposing penalties for inaccurate provider
directory information. However, neither the statute nor the proposed regulations specify whether a
carrier’s good-faith use of the designated online credentialing system and multi-carrier common
online provider directory information system must be considered when assessing penalties. We
recommend that MIA clarify in Section .06 that a carrier has exercised reasonable diligence when it
uses DataSpring as its primary source for provider directory information, relies on recent provider
verification and attestations, and promptly incorporates provider-submitted updates through the
platform into its provider directory. We ask MIA to consider whether a carrier should be subject to
penalties solely because a directory entry is later determined to be inaccurate. This clarification
would encourage use of the centralized, provider-attested data source designated by the State while
helping ensure that carriers are not penalized for inaccuracies beyond their reasonable control.
Support Education to Providers on New Regulatory Requirements
Provider directory accuracy is a shared responsibility between carriers and providers. Providers
and authorized practice administrators are best positioned to confirm practice locations, contact
information, availability, and whether they are accepting new patients. While HB 1093/SB 808
contemplates carriers “inform[ing] providers that the online credentialing system is the primary
source of information to create and update the carrier’s provider directory,” more can be done to
raise awareness among providers and staff about the importance of provider directory accuracy for
ensuring access to care. We encourage MIA to work with providers, staff and their surrogates to
educate them on the new requirements and the importance of their active participation to help
patients find and receive care.
DataSpring appreciates MIA’s leadership in advancing provider directory requirements to better
serve consumers, carriers, providers, and regulators. We look forward to continued engagement with
MIA as these regulations are refined and implemented, and we would welcome the opportunity to serve
as a resource on additional provider directory matters.
Sincerely,
Melissa Speck
Senior Director, Government & Public Affairs
The League of Life and Health Insurers of Maryland / National Association of Dental Plans
August 10, 2026
Commissioner Grant & Director of Regulatory Affairs
Maryland Insurance Administration
200 St. Paul Place, Suite 2700
Baltimore, Maryland 21202
Re: Proposed Regulation 31.10.52 Provider Directory Requirements
Commissioner Grant:
On behalf of the League of Life and Health Insurers of Maryland, Inc. (League) and the National Association of Dental Plans (NADP) [1], thank you for the opportunity to provide comments regarding the Maryland Insurance Administration's (MIA) draft regulations under COMAR 31.10.52, Provider Directory Requirements, published in the July 10th edition of the Maryland Register. We appreciate the MIA's efforts to strengthen accuracy and transparency in carrier provider directories and offer the following targeted recommendations for the MIA's consideration.
Section .02(B) – Required Means for Reporting Directory Inaccuracies
We appreciate the MIA's addition of a definition of “other electronic means." Section .02(B) requires three reporting channels: a customer service telephone number, an e-mail address link, and another electronic method. Because the two electronic options serve the same purpose, requiring both may not materially improve consumers' ability to report directory inaccuracies.
We recommend requiring a customer service telephone number and either an e-mail address link or another electronic reporting method. This would preserve telephone and electronic access while allowing carriers to use the electronic method best suited to their systems. The approach would maintain an accessible and effective reporting process without prescribing multiple, potentially duplicative electronic options.
Section .03(A)(2) – Clarify Compliance Pathways Under Insurance Article §15-112(p)(3)
Section .03(A)(2) should be clarified to ensure consistency with Insurance Article §15-112(p)(3), which sets out two compliance approaches: (i) conducting a periodic review of a reasonable sample of the network directory and retaining documentation, or (ii) contacting providers who have not submitted a claim in the preceding six months to confirm continued network participation. As drafted, Section .03(A) establishes the periodic review and then introduces documentation or provider outreach in a manner that could be read to incorporate both elements within a single compliance framework.
This structure may create ambiguity as to whether provider outreach is intended as part of the periodic review process or as a separate compliance option. We therefore request clarification as to whether the MIA intends for carriers to satisfy the requirement through either approach independently or through a combined process, and that Section .03(A) be revised accordingly to clearly reflect the intended structure.
Section .03(A)(3) – Extend the Claims-Inactivity Period from Six to Twelve Months
Section .03(A)(3) requires carriers to contact directory-listed providers who have not submitted a claim within the preceding six months to confirm whether they intend to remain in network. We recommend extending this period to twelve months because claims inactivity alone is not a reliable indicator of network departure.
Providers may remain contracted, credentialed, and available to patients despite limited claims activity due to specialty practice patterns, seasonal utilization, claim timing, or low enrollment. This is particularly relevant for specialists and providers in rural or underserved areas.
A six-month threshold could therefore prompt outreach to providers whose participation has not changed, increasing work for carriers and providers without a corresponding improvement in directory accuracy. A twelve-month period would better distinguish temporary inactivity from a potential network departure and focus compliance resources on changes more likely to impact consumers.
Section .03(B) – Clarify the Periodic Review Frequency Requirement
The revised proposal changes the review frequency from every three months to “no less frequently than every 6 months." We appreciate this adjustment, but the wording could be interpreted to require reviews at intervals of no more than six months, limiting carriers' ability to coordinate directory reviews with other required audits.
We recommend revising the requirement to state: “A periodic review shall occur at least twice during each 12-month period."
This language would preserve two reviews each year while providing reasonable scheduling flexibility. For example, reviews conducted in May and December would satisfy the annual frequency without requiring carriers to reschedule other mandated audits solely because the interval exceeds six months.
Section .03(C) – Replace the Fixed 25 Percent Sampling Requirement with a Statistically Valid Methodology
We appreciate the MIA's removal of the requirement that periodic reviews cover 100 percent of directory listings within 15 months. We recommend defining a “reasonable sample size" through a statistically valid and reliable methodology rather than a fixed minimum of 25 percent of provider listings.
The proposal does not identify the basis for the 25 percent threshold or establish that it would produce more reliable results than a representative sample selected under accepted auditing principles. Reliability depends on the sample's methodology and representativeness, not a predetermined percentage of the population.
A methodology-based standard would also align with section .07(B), which requires Commissioner-directed surveys to use a “statistically reliable and valid methodology." Applying the same standard to carrier reviews would promote consistency and focus the requirement on reliable results.
A fixed 25 percent threshold could also substantially increase audit volume. For example, if a statistically valid 5 percent sample included 175 provider listings, a 25 percent sample of a comparable directory would require review of 875 listings – five times as many. The proposal does not establish that the larger sample would produce materially more accurate results, and the additional work may not yield a corresponding benefit.
We therefore respectfully request that the regulation require a statistically valid and reliable sampling methodology rather than a fixed percentage. This approach would preserve meaningful oversight and representative results while allowing the sample to reflect each directory's size and characteristics.
Section .05 (B) and (D) – Inaccuracies: Entry or Listing Changes Based on Prospective Enrollees
As currently drafted in Section .5, removing an entry or listing or marking it “unverified" can be triggered by either an enrollee or a prospective enrollee. The League and NADP continue to suggest that the regulation be edited to have these actions be required triggered only upon receipt of notification from enrollees, and not prospective enrollees. While carrier members make their provider directories available to prospective enrollees pursuant to §15-112(n)(1), prospective enrollees must choose a network to see the providers included in that network. If a prospective enrollee erroneously selects an incorrect network, and notifies of an inaccuracy, carriers will be subject to specific timelines to label providers as “unverified" or even removed from the directory possibly in error, which could result in both consumer confusion and provider abrasion. When an enrollee searches a directory, they are prompted to enter their membership information, which points them to the specific network applicable to their plan, which is more credible.
We appreciate the MIA's continued collaboration and consideration of these recommendations. We welcome the opportunity to discuss them further or answer any questions. Thank you for the opportunity to comment.
Sincerely,![]()
Matthew Celentano
Executive Director
The League of Life and Health Insurers of Maryland
Bianca Balale
Director of Government Relations
National Association of Dental Plans (NADP)
[1] NADP is the largest non-profit trade association focused exclusively on the dental benefits industry. NADP's members provide dental HMO, dental PPO, dental indemnity and discount dental products to more than 200 million Americans with dental benefits. Our members include the entire spectrum of dental carriers: companies that provide both medical and dental coverage, companies that provide only dental coverage, major national carriers, regional, and single state companies, as well as companies organized as non-profit plans.
Office of the Attorney General Consumer Protection Division
To: J. Van Lear Dorsey, Principle Counsel, Maryland Insurance Administration
Subject: Provider Directory Requirements Proposed Regulations, 31.10.52
Van,
As discussed, we wanted to share HEAU's views on the Provider Directory Requirements Proposed Regulations, 31.10.52.
Our primary concerns with the Proposed Regulations are:
1. The periodic review period is every 6 months, which is inconsistent with the (a) No Surprises Act, requiring a periodic review every 90 days, and (b) COMAR 31.10.44.03(8)(2), which requires carriers to continuously verify and update information consistent with Insurance§ 15-112 and the No Surprises Act.
2. The definition of•reasonable sample size" as 25% is too low, and we believe it should be higher to ensure consumers have accurate information.
If carriers are allowed to sample just 25% of their directory every six months, that means individual provider listings could remain unverified for up to two years, potentially leading to outdated or misleading information. Because provider network data changes frequently-due to staffing shifts, credentialing updates, practice relocations, and changing acceptance of new patients-limited sampling fails to capture the full scope of inaccuracies, allowing outdated entries to persist undetected for long periods. This review structure is harmful to consumers and at odds with recent federal protections, including No Surprises Act protections.
As the MIA is aware, inaccuracies undermine timely access to care. Consumers rely on accurate provider data to schedule appointments and access in-network services. Yet past audits have revealed nearly 50% inaccuracy rates in Medicare Advantage and Maryland MCO directories, including wrong phone numbers, addresses, or acceptance status. If reviews are sparse, patients may face repeated misdirection, appointment cancellations, or even be unable to find local providers. Repeated failures in directory accuracy compound harm: a consumer encountering multiple incorrect listings may abandon attempts to secure in-network care altogether, exacerbating delays in treatment and worsening health outcomes. Moreover, inaccuracies expose patients to financial risk. When inaccurate listings persist, consumers may unknowingly visit out-of-network providers and incur unexpected costs.
Federal policies recognize these risks. Under the No Surprises Act, plans must update directories within 2 business days of change notification and verify listings not less frequently than once every 90 days, to protect consumers and hold plans and providers accountable for inaccuracies. 42 USC § 30099-115. Allowing less frequent sampling contradicts these safeguards. Section 5123 of the Consolidated Appropriations Act (CAA 2023) requires at least quarterly updates to Medicaid/CHIP directories.
Maryland should match or exceed, not fall below, those protections. Allowing carriers to rely on limited sampling undermines these consumer protections standards. We offer the following additional specific comments:
.02A Carrier Contract - the proposed rule requires carriers to provide a mechanism for enrollees and prospective enrollees to notify carriers of inaccurate directory information. We recommend broadening the provision to require carriers to accept notification from others. It is not uncommon for consumer advocates, providers, social workers or others to identify inaccuracies in provider directories. Those individuals should have a mechanism for reporting those inaccuracies. Notification of a potential inaccuracy in a network directory by others is expressly contemplated by Md. Code Ann., Ins.§ 15-112(0)(2), which requires carriers to investigate the reported inaccuracy and take corrective action, if necessary, to update the network directory. Accordingly, we recommend adding "others• to .02(A).
.05 Inaccuracies -for the reasons stated above, we recommend ensuring carriers take appropriate corrective action when "others• report inaccuracies.
.058- appears to contain an error and should be corrected by replacing "A carrier shall.. .' to "A provider shall..."
In conclusion, we believe the Administration should strengthen the provider directory requirements to align with federal standards and better protect Maryland consumers. Ensuring timely, comprehensive verification of provider information is essential to safeguarding access to care, preventing avoidable financial harm, and maintaining public trust. The proposed sampling approach falls short of these goals and risks perpetuating the very inaccuracies that federal and state law seeks to eliminate. By adopting stronger, more frequent verification standards and broadening reporting mechanisms, Maryland can advance meaningful consumer protections and promote a more reliable and transparent healthcare system for all enrollees.
Thanks,
Kimberly S. Cammarata
Assistant Attorney General
Director, Health Education and Advocacy Unit
Office of the Attorney General
Consumer Protection Division
