What Can I Do if My Insurance Company Has a Ghost Network?

Perhaps you have struggled to find a doctor who accepts your insurance. A provider may appear in your health plan’s online directory as accepting new patients. Even better, the provider is relatively close to your home. But when you call to schedule an appointment, you find the doctor moved or retired – sometimes years ago – no longer accepts your insurance or has never participated in your health plan. Assuming this is a one-time “fluke,” you make several more calls, only to find the same thing happening again and again. Obviously, this is extremely frustrating, particularly when you really need to find a doctor for an existing medical condition.

Unfortunately, this phenomenon is so common that it even has a name – “insurance ghost networks.” When you are choosing your insurance plan, one of the things you likely look at is whether there is a broad network of doctors and specialists. You may even have chosen your insurance company specifically because of this issue, only to find that many of the listed providers are no longer available – or were never available. This results in delays in your medical care, stress and time spent looking for a provider, and even worsening health conditions. It is important to understand what ghost networks are, and what you can do if you encounter them with your insurer.

In May 2023, the Senate Committee on Finance studied ghost networks in Medicare Advantage plans. Twelve different plans were randomly selected, and ten providers from each plan were called. Of the 120 provider listings contacted, 33 percent had inaccurate or non-working numbers or returned calls. Staff were only able to make appointments 18 percent of the time, even when they found a working number. Ghost networks were most prevalent with mental health providers.

This is especially unfortunate in a country where one in five adults suffers from a diagnosable mental health illness. Further, in 2021, it was estimated that less than half of the 57.8 million adults living with a mental illness had received mental health services over the past year. It is highly likely that ghost networks are involved in this. Delayed access to mental health care and inadequate treatment can result in worsening of mental health conditions, and even death.

If you have encountered ghost networks with your current health insurance, it can be frustrating. You can benefit from having a strong legal advocate in your corner – one who has dealt with insurance companies that do not hold up their end of the bargain for over two decades. That advocate is Attorney Scott Glovsky, with the Law Offices of Scott Glovsky. Scott will fight for justice on your behalf, helping ensure your insurer is not allowed to ignore its obligations.

Contact us online or call 626-243-5598 today to discuss your issue and possibly get some much needed answers.

What is a Ghost Network in Health Insurance?

A ghost network in healthcare refers to a health insurance provider directory that lists medical providers who are not actually available to patients. The directories give consumers searching for the best insurer for themselves and their families the false impression that they will have easy access to care, even though the directory may be full of unreachable or retired providers, or those who do not accept the patient’s insurance. The term “ghost” is used because these networks are phantom, unavailable, or practically invisible to patients. Patients rely on the insurer’s provider directory, yet may repeatedly encounter:

• Retired physicians
• Wrong phone numbers
• Healthcare providers who no longer accept the insurance plan
• Providers who are not accepting new patients
• Duplicate listings
• Incorrect office locations

Ghost networks can occur for many reasons, including poor maintenance of provider directories, insurance company oversight, or changes to provider contracts. The fact remains that insurers benefit from ghost networks because their network coverage appears larger, making their plans more marketable. The result of ghost networks can be very serious, as patients may delay necessary treatments or seek expensive out-of-network care.

Has the Issue of Ghost Networks Been Addressed?

While ghost networks have been addressed by lawmakers, regulators, and courts, directories containing significant inaccuracies remain a concern. Medicare Advantage, Medicaid Managed Care, and mental health networks appear to be the most serious violators. Studies continue to show that many provider directories contain outdated or inaccurate information despite existing legal requirements. The federal No Surprises Act required health providers to maintain more accurate provider directories and establish protections for patients who rely on incorrect directory information.

The law also placed responsibility on healthcare providers to notify insurers when their network participation changed. While the No Surprises Act has improved accountability, inaccurate directories remain a common problem. In 2025, the Centers for Medicare and Medicaid Services (CMS) finalized new rules (CMS-4208-F2) requiring Medicare Advantage organizations to submit provider directory information directly to Medicare’s Plan Finder. This would allow patients to more easily compare networks.

Some state insurance departments now require insurers to update provider directories within specified timeframes. Consumer complaints regarding inaccurate listings may be investigated by the state. Several states even impose fines for insurers who fail to comply. Unfortunately, inaccurate provider directories remain a significant barrier to healthcare access.

It is worth noting that in June 2026, the Office of Inspector General warned consumers about inaccurate Medicaid managed care provider directories, especially those that could negatively affect overall maternal health outcomes if not properly addressed. Although OIG authorities stopped just short of accusing the insurers of a crime, there were a significant number of inaccuracies in provider directories related to maternal health.

In fact, from 22 to 41 percent of the directories lacked proper provider contacts. The OIG was especially concerned with instances where providers were incorrectly listed as in-network, causing new and expecting mothers to have necessary services denied due to lack of coverage eligibility.

Are California Ghost Networks Illegal?

While ghost networks are not inherently illegal, they can violate California laws. The state of California requires health plans and insurers to maintain accurate provider directories and adequate provider networks. When an insurer fails to meet these obligations, it could violate state insurance laws, consumer protection laws, and its contractual obligations to consumers. California law requires many health plans to regularly verify provider information and update online directories at least weekly when changes occur.

In some situations, if you receive care after relying on an incorrectly identified in-network provider, your financial responsibility may be limited to the amount you would have paid to an in-network provider. Although a single clerical error may not result in legal liability for the insurer, widespread or repeated inaccuracies, maintaining directories that significantly overstate network availability, or repeated failure to update provider information can violate California’s provider directory requirements. In fact, California’s Department of Managed Healthcare has fined Kaiser Permanente, Health Net and Centene Corporation and also penalized Anthem Blue Cross and Blue Shield of California for having inaccurate provider directories, AKA ghost networks. Mental and behavioral health inaccuracies in provider network directories are especially pervasive, and California lawmakers continue to consider additional legislation to strengthen enforcement and improve directory accuracy.

What is a Network Gap Exception?

A network gap exception can be one of the most important remedies available to consumers. Network gap exceptions allow you to receive care from an out-of-network provider at the in-network benefit level when no appropriate in-network provider is available.

A network gap exception asks a health insurance company to treat an out-of-network provider as in-network when the healthcare plan does not offer reasonable access to necessary medical care. Situations that can result in a network gap exception include:

• Your healthcare plan offers no qualified in-network specialist.
• The only listed in-network providers are not accepting new patients.
• The available providers have unreasonably long wait times.
• The nearest participating provider is an unreasonable distance away from your home.
• Your provider directory contains inaccurate information.
• You require specialized treatment that is unavailable within your insurer’s network.

When a network gap exception is approved, the insurer may agree to cover treatment from an out-of-network provider, significantly reducing out-of-pocket expenses and helping you obtain necessary medical care in a timely fashion. While the process for obtaining a network gap exception varies by insurer, it generally involves:

• Contacting your insurer’s member services department
• Explaining why an appropriate in-network provider is unavailable.
• Providing documentation, including records of unsuccessful attempts to schedule appointments, screenshots of inaccurate provider directory listings, or letters from a physician explaining why specialized care is medically necessary.
• Requesting written approval before receiving out-of-network treatment when possible.

It is important that you keep copies of all correspondence, provider directory listings, notes from telephone calls, and denial letters. A network gap exception is especially relevant if a large provider network exists only on paper. In many cases, documenting unsuccessful attempts to obtain in-network care can significantly strengthen your request.

If your insurer denies a network gap exception, you may have the right to appeal the decision, depending on your health plan. If the denial prevents you from receiving medically necessary care or results in substantial financial harm, an attorney like Scott Glovsky who is experienced in health insurance disputes can evaluate your legal options.

How Do Ghost Networks Delay Medical Care?

When you are unable to locate an in-network healthcare provider, you may experience delays in necessary medical treatment. Perhaps your insurance company’s provider directory appeared to offer numerous options, yet once you begin calling for an appointment, many of the listed physicians no longer participate in your network, may not be accepting new patients, or could have retired or relocated. You may spend countless hours calling providers, only to conclude that the directory does not accurately reflect the actual network.

Delays due to ghost networks can have serious consequences. You may need to see a cardiologist, neurologist, oncologist, or other type of specialist yet cannot find an in-network provider. If you have a chronic illness, you may experience harmful interruptions in care, or if you are awaiting surgery or diagnostic testing, your medical condition may worsen as a result of ghost networks. Once you discover that no in-network providers are available, you could be forced to seek a network gap exception, appeal a coverage decision, or obtain prior authorization for an out-of-network provider. All of these solutions take time – time that you may not realistically have.

Delayed diagnosis or treatment often allows a disease to progress, significantly increasing the risk of complications, prolonged pain, or disability. Emotional stress is also a real side effect of ghost networks as you struggle to locate care while worrying about your health and the financial costs. Ghost networks are particularly harmful for those seeking treatment for depression, anxiety, PTSD, eating disorders, or substance use disorders. Limited provider availability may already exist, and ghost networks can cause patients to abandon their search for care altogether or experience lengthy delays.

Some patients may seek care from an out-of-network provider out of desperation. While this decision can provide quicker access to treatment, it also exposes patients to substantially higher medical expenses unless a network gap exception is granted. If you or a loved one has a serious medical condition, ghost networks can be even more problematic.

How Do Ghost Networks Affect Patients with Serious Medical Conditions?

While ghost networks can delay medical care for anyone, they can have particularly serious consequences for those with complex, chronic, or life-threatening medical conditions. In these situations, timely treatment is even more essential, and an inaccurate provider directory can create barriers that delay diagnosis, interrupt ongoing care, or postpone medically necessary treatments.

As an example, if you have been diagnosed with cancer, it is important that you see an oncologist quickly to begin treatment, whether that treatment includes chemotherapy, radiation therapy, a newer cancer drug, or surgery. If your provider directory lists oncologists who have retired, no longer participate in your network, or are not accepting new patients, you can lose valuable time searching for an available specialist.

If you are awaiting an organ transplant, receiving kidney dialysis, or undergoing treatment for serious neurological or heart conditions, the result of a ghost network can be devastating. If you are living with a rare disease or complex autoimmune disorder, you are likely to require highly specialized physicians with expertise treating uncommon conditions. A ghost network can create significant obstacles in any of these situations, causing you to potentially spend weeks searching for a specialist covered by your insurer while your condition continues to progress.

Perhaps you receive infusions, biologic medications, immunotherapy, physical rehabilitation, or specialized healthcare. A ghost network can disrupt your care, reduce the effectiveness of your treatment, worsen your symptoms, and even force you to repeat diagnostic testing or establish care with a new physician unfamiliar with your medical history.

What Should I Do If My Insurance Company Has a Ghost Network?

If you have found your insurance company’s provider directory is less than accurate, it is important to take the following steps:

• Carefully document your search for an in-network provider, including writing down the name of every physician or specialist you contact (including date, time, and who you spoke with), as well as the reason given for the appointment not being scheduled.
• Print the relevant pages of your directory, or take a screenshot with your phone.
• Contact your insurer and ask it to provide an updated list of in-network providers.
• If there are no qualified in-network providers, ask about a network gap exception.
• Submit any necessary requests for prior authorization as quickly as possible.
• Continue to seek medical care, even while working with your insurer.
• If your insurer denies your request for a network gap exception and refuses to authorize appropriate care, file an internal appeal.
• Consider an external review to evaluate whether your insurer properly applied the terms of your policy.
• Speak with an experienced health insurance attorney.

Can I See an Out-of-Network Doctor if There Are No In-Network Doctors Available?

If your healthcare plan does not have an available in-network provider who can deliver the medical care you need within a reasonable time or distance, you may be able to receive treatment from an out-of-network provider while paying the same cost-sharing that would apply to in-network care. This could be accomplished through a network gap exception, a network adequacy exception, or another out-of-network authorization process, which will be determined by your specific insurance company and plan.

When possible, before you schedule treatment with an out-of-network provider, contact your insurance company and explain that you are unable to locate an appropriate in-network provider. If your insurer refuses to provide reasonable access to covered care, your next step might be to consult an attorney experienced in health insurance disputes to evaluate your legal options.

How Do I Prove a Ghost Network?

Proving your insurer has a ghost network may come down to careful documentation. Although a single inaccurate provider listing could be nothing more than a clerical error, multiple incorrect listings or an inability to locate an available in-network provider despite your best efforts likely indicates a larger problem with the provider directory or network adequacy. Carefully document every attempt you make to obtain in-network care.

If you are told the physician retired or moved, ask when that change occurred. If you are told your insurance is not accepted, or the provider is not accepting new patients, again, the same holds true. Medical records are also valuable evidence; if your physician documents that your treatment was delayed because an in-network provider could not be located, this can help establish how the ghost network affected your care.

Financial records may also support your claim of a ghost network. Keep every receipt, bill, and insurance statement that shows additional costs you incurred because you were forced to seek care outside your insurer’s network or postpone treatment while searching for an available provider.

What Are California’s Network Adequacy Laws?

California has some of the nation’s strongest network adequacy laws, requiring many health plans to maintain provider networks that allow members reasonable and timely access to covered healthcare services. Most HMOs and certain other managed care plans are regulated by the California Department of Managed Health Care (DMHC). Many PPO insurance policies are regulated by the California Department of Insurance (DOI). While the specific rules vary by plan type, regulators enforce standards to ensure that insured patients can obtain medically necessary care from qualified providers in a timely manner. Learn more from the DOI and the DMHC.

California law generally requires health plans to maintain sufficient numbers of physicians, specialists, hospitals, mental health professionals, and other healthcare providers to adequately meet members’ needs. Networks must be large enough and geographically accessible enough that patients can obtain covered services within reasonable travel distances and without significant delays.

California also has “timely access” standards that limit how long patients must wait for an appointment. Depending on the type of care requested and whether prior authorization is required, health plans generally must provide access to urgent care, primary care, specialist care, and mental health services within specified timeframes. These timeframes are established by state law and regulations. Insurers must monitor compliance and submit annual reports to the DMHC to demonstrate they are meeting these standards.

Can I Sue My California Insurance Company Over a Ghost Network?

Whether you can sue your California health insurance company over a ghost network will depend on the specifics of your case, the type of health plan you have, and the harm you suffered as a result of your insurer’s actions. While the mere existence of a ghost network does not automatically result in a lawsuit, insurers who fail to comply with California law, improperly deny or delay access to medically necessary care, or breach contractual obligations could face legal liability.

If your insurer’s provider directory consistently lists providers who no longer accept your insurance, have retired, or are not accepting new patients, you may have reason to consider a lawsuit. In short, when a ghost network deprives you of the healthcare benefits you purchased, or unreasonably delays medically necessary treatment, California law may provide avenues to challenge your insurer’s conduct.

How the Law Offices of Scott Glovsky Can Help You Deal with a Ghost Network

Attorney Scott Glovsky and his legal team fight for justice against big corporations every single day. Often, these big insurance companies believe they are untouchable, yet Scott never backs away from a fight when he is fighting for his clients’ rights. Scott will be fully committed to your insurance issue; he takes the responsibility to obtain justice on your behalf to heart and will work tirelessly to achieve that goal. If you are the victim of a ghost network, and your health has been adversely affected as a result, we are ready to help you get what your insurer promised. Contact the Law Offices of Scott Glovsky online or call 626-243-5598 to discuss your issue.