CMS enforcement is accelerating, specialty shortages are deepening, and too many plans are still running their network builds on spreadsheets — here's what that combination means for 2026.
Prediction 1: CMS Will Issue More Deficiency Notices Than Any Prior Year
This is the most confident prediction we'll make. CMS has been systematically expanding its network adequacy enforcement infrastructure — more staff, more sophisticated data tools, more frequent cross-referencing of submitted provider directories against credentialing records and claims data. The agency has publicly signaled that plan accountability is a priority. The enforcement numbers will follow.
What this means practically: plans that have historically passed adequacy reviews with thin margins — close enough, year after year — are going to find that margin insufficient in 2026. CMS's tolerance for time-and-distance exceptions that lack strong good faith documentation has narrowed. Plans in rural states and growing D-SNP markets are at the highest risk.
The response from most plans will be reactive. The response from plans that will outperform in 2026 is to run their own network adequacy analysis now, using CMS's methodology, and close gaps before the submission window opens — not in response to a notice.
Prediction 2: Specialty Shortages Will Worsen in Three Critical Areas
The provider shortage is not evenly distributed, and the three specialties where adequacy risk is highest in 2026 are the same three that have been under pressure for years: behavioral health, nephrology, and oncology.
Behavioral health is the most acute. The demand surge driven by post-pandemic mental health needs has not been matched by supply growth. Medicare Advantage plans are now required to include adequate behavioral health provider access, and the rural and suburban markets where plans are expanding are precisely the markets with the fewest available providers. Telehealth has partially bridged this gap, but CMS's rules on how telehealth providers count toward time-and-distance standards are inconsistent across markets.
Nephrology is under pressure from the combination of an aging population with high ESRD rates and a specialist workforce that is not growing fast enough to meet demand. Oncology faces a similar dynamic in non-major-metro markets, where cancer center capacity is constrained and independent oncologists are increasingly being absorbed by large health systems that may not be willing to contract with your plan at rates you can afford.
Plans that wait until the submission window to address specialty gaps will not close them in time. The contracting and credentialing timelines for these specialties routinely run 6 to 12 months. Start the recruitment cycle now.
Prediction 3: D-SNP Growth Will Create New Adequacy Pressure in Dual-Eligible Markets
D-SNP enrollment is growing at a rate that most plans did not fully anticipate when they built their 2025 networks. The dual-eligible population has distinct access needs — higher utilization of behavioral health services, long-term services and supports, and care coordination — that standard MA networks are not optimized to serve.
CMS has signaled increasing scrutiny of whether D-SNP plans are building networks that actually meet the access needs of their enrolled population, not just the minimum adequacy standards designed for the broader MA market. Expect more guidance in 2026 on D-SNP-specific network requirements, and expect that guidance to have teeth.
Plans entering or growing D-SNP markets need to be building networks specifically for that population: FQHC and RHC relationships, behavioral health integration at scale, LTSS coordination capacity. A network that passes for a general MA population may not pass for a D-SNP population under closer scrutiny.
Prediction 4: Technology Adoption Will Become a Competitive Differentiator
For the last five years, technology in the network build space has been sold primarily as an efficiency story: same work, fewer hours, lower cost. That positioning is over. In 2026, the technology gap between plans will start showing up in outcomes — in submission quality, in deficiency notice rates, in how quickly plans can respond to emerging coverage gaps.
Plans with real-time adequacy monitoring will catch gaps 60 to 90 days before they become compliance problems. Plans running quarterly snapshots against static spreadsheets will keep catching those gaps in CMS's enforcement reports.
The technology gap is also a talent gap. The network operations professionals who are best at this work — the ones who can run a multi-county build with 400 providers across six specialties — are moving toward platforms that give them real data and real tools. Plans that haven't modernized their network build infrastructure will find it harder to recruit and retain the people who know how to use modern infrastructure.
What We're Most Worried About
Here is the honest answer: we are most worried about the plans that are still running their entire network build operation on spreadsheets.
Not because spreadsheets are unsophisticated. We know exactly how they work — most network build leaders have spent years building elaborate, carefully maintained spreadsheet systems. The problem is that spreadsheets have no memory of what changed, no alerts when a provider's credentialing lapses, no real-time distance calculation against your current member distribution, and no audit trail that holds up under CMS scrutiny.
In a zero-margin-for-error compliance environment, a spreadsheet is not a system of record. It is a liability.
CMS is operating with better data than it had three years ago. The plans that are going to navigate 2026 without a deficiency notice are the ones whose internal data is at least as good as CMS's. Right now, for too many plans, it isn't. That gap closes with investment in process and technology — not with more hours spent in Excel. If there's one thing we'd push every network build leader to address before Q2, it's that.