Provider Directory Verification: Insurers Must Audit Every 90 Days, But Providers Bear the Risk

A new Illinois law, Public Act 103-0650, requires health insurance issuers—including PPOs and third-party payers—to review and verify the accuracy of their provider directories at least once every 90 days. While the legal obligation to maintain directory accuracy falls on the insurers, chiropractic physicians must take note: failure to respond to verification requests can result in being marked as not accepting new patients or even being removed from the network directory entirely. Although the statute does not place a direct compliance burden on providers, insurers are shifting operational enforcement to the providers by requiring regular responses and updates.

Unfortunately, the ICS has received several calls from members indicating that BCBSIL is terminating their “provider record” from the network, which demonstrates the importance of complying with the directory requirements.

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Although the information below is specific to BCBSIL, the ICS reminds our members that the directory audit requirement applies to all insurers and networks. As a result, most insurers are using similar practices as outlined below. We strongly recommend that members review the requirements of all networks with which they participate/contract.

BCBSIL-Specific Process for Chiropractic Physicians

Blue Cross and Blue Shield of Illinois (BCBSIL) has implemented a roster-based system for verifying directory information and enforcing the 90-day standard. This process is mandatory for commercial provider groups and solo providers. You will find the process below here under “Verify by Roster: Commercial Groups and Solo Professional Providers.”

To remain visible and compliant in BCBSIL’s directory, providers must complete one of two verification processes every 90 days:

1. Request and Submit BCBSIL’s Pre-Formatted Roster
   • Email the Provider Roster Requests team once per quarter to request your practice’s roster. Include your Tax ID Number.
   • Expect a response within approximately four weeks, including a roster file and case number.
   • Review and update information (e.g., names, locations, phone numbers, websites), ensuring the format remains unchanged.
   • Return the updated file in a new email to BCBSIL.
2. Submit the Universal Illinois Association of Medicaid Health Plans Roster
   • Practices may submit this alternate roster format instead, also on a quarterly basis.

For solo providers, BCBSIL “encourages” participation to reduce administrative burdens and ensure continued visibility in the directory. However, the ICS  recommends that ALL providers and practices make this a mandatory requirement in their offices every 90 days.

These quarterly verification processes apply only to commercial plans. Providers in Medicare Advantage or Medicaid networks are not subject to the 90-day verification cycle but must still report demographic changes as required by contract.

Full instructions and contact details are available on BCBSIL’s Provider Demographic Update page.

Key Takeaways for Chiropractic Physicians

• While the law mandates insurer responsibility, providers face real consequences if they do not respond to verification outreach.
• Providers should monitor insurer communications closely and ensure processes are in place to respond every 90 days.
• Proactive compliance with directory verification protects your network status and ensures patients can find your practice.