What is 90-Day Update Requirement

90-Day update Requirement Definition

The 90-Day Update Requirement is the cornerstone of the No Surprises Act’s transparency provisions. For C-Suite leaders, this mandate shifts the burden of data accuracy onto the payer; if a member relies on outdated information to see a doctor they believe is "In-Network," the plan may be forced to pay the claim at in-network rates even if the provider is actually OON. Operationally, this requirement demands a "Closed-Loop" data system. When a provider submits a change, the directory must be updated within 48 hours. The 90-day clock is a "hard deadline" for outreach; any provider who has not responded to an attestation request within that window represents a compliance deficiency. To manage this at scale, plans are integrating with "Clearinghouses" and "Provider Portals" to centralize the attestation process across multiple payers, reducing the administrative fatigue on provider offices.

FAQs

What happens if a provider fails to respond to a 90-day outreach?

The plan must follow a documented "outreach protocol." If the provider remains unresponsive, they must be suppressed from the online directory to prevent members from receiving inaccurate information.

Does the 90-day requirement apply to all providers?

Yes, it applies to all individual practitioners and facilities listed in the public-facing directory used by members to make care decisions.

How is "48-hour synchronization" achieved?

This requires a direct API connection between the Provider Data Management (PDM) system and the public web directory, eliminating manual batch uploads that often cause delays.