The network adequacy window is closing. Here is why we are launching Radius this year.
For two decades, network adequacy was the quietest corner of healthcare compliance. Plans submitted HSD tables once a year. CMS reviewed in batch. State regulators reviewed less often than that. The tools that grew up around the work were built to match: overnight runs, complex reports, six-figure annual licenses.
That world is ending in 2027. Three regulatory forces are converging inside an eighteen-month window, and existing network adequacy tools are never going to make the transition. This post is our attempt to explain what we are seeing, why we think the timing is the entire story, and why a small team of technologists decided to build a new platform rather than wait for the incumbents to modernize theirs.
The payer side stops being a deadline and starts being an enforcement era
The payer side is being reshaped on two parallel tracks. The ACA timeline runs through state DOIs and SBM exchanges. The MA timeline runs through CMS Medicare Plan Finder and the ACC review. Both arrive in 2027. Both raise the cadence requirement from quarterly to continuous. Both expose the legacy stack at the seams.
On the ACA side, the 2027 NBPP revision devolves federal network adequacy authority to the states. State Departments of Insurance and SBM exchanges become the primary reviewers for QHP filings. The first wave of SBM states moved to quantitative T&D standards in January 2026, with another ~18 SBM states finalizing 2027 implementation. Multi-state QHP issuers face dozens of different state review regimes instead of one federal one, with no consistent methodology across them.
On the MA side, the 2027 directory mandate requires MA plans to submit provider directory data to CMS Medicare Plan Finder, refresh it on a 30-day cadence, and attest to its accuracy annually. What was a back-office data-quality concern becomes a continuously auditable obligation tied to member-facing search results.
Cutting across both: OIG audits and ghost-network litigation are escalating now, not in 2027. The Cigna $5.7M settlement is the highest-profile recent example, but it is not the last. Class actions alleging directory inaccuracy are multiplying across MA and ACA marketplaces alike. CMS has created a Special Election Period for MA members who join a plan based on inaccurate directory information, turning every directory error into a potential retention problem on top of the compliance and legal exposure.
The consequence is the same on both sides: directory accuracy and adequacy compliance, which historically were quarterly snapshot exercises, now need to run continuously. The existing tooling was not built for that cadence.
The incumbents cannot move at the speed the new era requires
We have a lot of respect for what the incumbents built. Quest, in particular, holds the CMS ACC contract, owns the methodology relationship, and serves nearly every major MA plan. The company, in many ways, defined this category.
But the architecture is showing its age. On engagements where we watched health plans use Quest for their network adequacy work, three patterns kept repeating.
Performance. A full-state, multi-specialty adequacy run takes long enough on the legacy system that running multiple "what if" scenarios in a planning session is impractical. The infrastructure assumes the question gets asked occasionally, not interactively. In an era where 30-day update cycles are the rule, that assumption no longer fits.
Pricing. The license model is six-figure annual procurement, structured for one buyer per organization. That is economically rational for a compliance team that runs the tool once a quarter. It is economically irrational for a network ops team that needs to run it daily, for a consulting firm serving fifteen clients in twelve states, or for a state DOI standing up a continuous review program over thirty carriers.
Integration surface. The output is a deliverable: a CSV, an XLSX, a dashboard. It is not an API contract. Network ops teams that want adequacy answers wired into provider data management systems, claim platforms, or recruitment dashboards generally cannot get there from here.
These are not bugs in the product. They are consequences of the era it was built for. The era is changing.
The provider blind spot is the part of the story no one talks about
Here is the asymmetry that does not get enough attention.
Every payer running an MA, ACA, or Medicaid managed care book has access to network adequacy intelligence. Internal teams, contracting consultants, the incumbent platforms — they all show up at the renewal call knowing which counties the plan can lose, which specialties are at risk, and exactly how much regulatory leverage each provider organization carries.
Provider organizations almost never have that data. An independent physician group walking into a managed care renewal typically has a rate sheet, a roster, and a consultant who ran the same playbook for two systems in a different state. They have no way to answer the most consequential question in the negotiation: what happens to this payer's adequacy if we walk away?
That asymmetry is worth real money every renewal cycle, especially for groups in sole-provider counties, regional health systems whose footprints cover entire MSAs, and clinically integrated networks negotiating on behalf of their members.
But the same data points the other direction too, toward opportunity, not just leverage. A provider organization that can model adequacy from the payer side can answer questions that are otherwise opaque. Which counties are payers actually struggling to maintain coverage in? Where is a new clinic location most defensible from a market-need perspective? Which payers have the most to gain from a network development conversation, rather than the most to lose from a termination one?
The platform that gives both sides of the negotiation access to the same regulatory math does not have to be a leverage tool. It can be the foundation for better partnerships, better expansion decisions, and better conversations between health plans and the providers who serve their members.
The state regulatory devolution rewrites who is on the hook
The third force is the Notice of Benefit and Payment Parameters revision, which devolves federal ACA network adequacy authority to the states starting in 2027.
In practical terms: the federal pre-emption that historically gave CMS primary authority over ACA marketplace adequacy is being scaled back. State Departments of Insurance, State-Based Marketplaces, and Medicaid agencies will be expected to operate Effective Review Programs of their own, applying quantitative time-and-distance standards to every QHP filing in their markets.
Most states are not staffed for this. Most states do not have budget for a six-figure license per carrier review. Most states have never operated this kind of program independently, and the few that have are doing it with spreadsheets.
The result is a procurement category that did not exist five years ago and has to be in production within eighteen months. The vendor landscape that defines that category will be set in the next few procurement cycles. The product surface required, including independent verification, gaming-pattern detection, comparative dashboards across every carrier in a market, and public-facing scorecards, does not match what any incumbent currently sells.
Why we are launching now
Network adequacy is going to look very different in 2027 than it does today. The cadence has to change from quarterly to continuous. The pricing has to change from enterprise license to per-engagement. The integration surface has to change from spreadsheet deliverable to API contract. And the addressable audience has to expand from twenty payer compliance teams to thousands of provider organizations, dozens of state regulators, and the consulting practices that serve all of them.
The incumbent platforms can probably modernize parts of their stacks given enough time. What they probably cannot do, on this timeline, is rewrite their commercial model, their architectural assumptions, and their target customer profile all at once.
We can. We came at this as technologists. Distributed systems, geospatial infrastructure, large-scale data pipelines, low-latency APIs. We treated network adequacy as the engineering problem it always was, and we built the platform with the next era as the design target, not the current one.
If you are inside a payer, a provider organization, a state regulator's office, or an advisory firm reading this and thinking about the same shift, we would like to know.