Most plans have no visibility into what CMS does between submission and approval — and that gap leaves them unprepared when deficiency notices arrive.
The Black Box After Submission
For most Medicare Advantage plans, the network adequacy submission process ends when they click submit in HPMS. What happens between that moment and either an approval or a deficiency notice is largely opaque. Plans wait, sometimes for weeks, with no feedback on whether their submission is progressing normally or sitting flagged in an analyst's queue.
That opacity is a problem because the review process has identifiable stages — and plans that understand those stages can take concrete actions during the review period to improve their odds of a clean approval. More importantly, plans that understand how CMS analysts review submissions can build their data more defensively from the start.
Stage One: HPMS Automated Validation
The first thing that happens after submission is not human review. HPMS runs an automated validation pass that checks for structural completeness: are all required fields populated, are NPI formats correct, are specialty codes valid, does the submission include every required county. This stage will catch obvious errors — missing HSD table rows, malformed provider identifiers, incomplete geographic coverage — and return them to the plan as system-level flags before any analyst sees the file.
Plans that submit clean data clear this stage quickly. Plans with data quality problems — stale NPIs, incorrect specialty designations, providers listed in counties they no longer serve — will see their submission kicked back at this stage for corrections. The practical implication is that the NPI and specialty data in your HSD table should be validated against NPPES before you submit, not after. HPMS's automated validation is running the same cross-reference CMS analysts will run manually in the next stage.
Stage Two: Analyst Review and Time-Distance Calculation
Once the automated validation clears, human analysts take over. The core of their review is a cross-reference of your HSD table against NPPES and PECOS — the national provider databases — to verify that the providers you've listed are actively enrolled, practicing in the specialties you've designated, and located where you've reported them. Providers who have retired, moved, or changed their enrollment status since your last update are identified at this stage.
After the provider verification pass, CMS runs the time-distance calculation. Your network is measured against county-type thresholds — the standards vary by whether a county is urban, suburban, rural, or frontier. For each specialty in each county, the system identifies whether your nearest in-network provider meets the required distance and travel time standard.
Counties that fail the time-distance test are flagged for analyst review. Not all flagged counties result in deficiency notices — the analyst review that follows is where exception documentation, telehealth arrangements, and good faith evidence become relevant. But if your submission has multiple flagged counties in the same specialty, or if the flagged counties are concentrated in a particular service area, expect deeper scrutiny.
Plans sometimes receive targeted secret shopper calls during this period. CMS contractors will call provider offices listed in your network to verify that they are accepting new Medicare Advantage patients, that they are contracted with your plan, and that appointment availability is consistent with adequacy standards. A provider that answers "we're not accepting new patients" or "we don't contract with that plan" creates a direct problem for your adequacy determination regardless of what your HSD table says.
What Plans Can Do During the 45–90 Day Review Window
The review process typically runs 45 to 90 days. Plans that treat this as a passive waiting period are missing their last opportunity to influence the outcome before a deficiency notice issues.
- Monitor HPMS for flags. The system will surface notifications if there are data quality issues or if CMS has questions about specific counties. Check regularly — notifications that go unread for two weeks cost you response time.
- Keep provider data current. If a provider in your network retires, relocates, or terminates their contract during the review period, update your data immediately. A provider that was valid at submission but is unreachable at review is a liability.
- Prepare good faith documentation for flagged counties. If you have counties that you expect may be flagged based on your time-distance analysis, have your exception documentation ready before the analyst asks for it. A well-organized exception file — outreach logs, provider response records, alternative access arrangements — can move through analyst review faster than a reactive assembly of documents.
- Verify your providers are answering correctly. Run your own spot-check calls to providers in counties you consider marginal. If a provider in a borderline county is telling callers they're not accepting MA patients, you need to know that before CMS does.
The review process is not a judgment on your network. It's a data verification exercise. Plans that submit accurate data and maintain it through the review period clear faster than plans that treat submission as the finish line.
Understanding the mechanics of the CMS review process does not change the underlying standards — but it changes how plans prepare. Every step of the review, from HPMS automated validation through analyst scrutiny to secret shopper verification, has a corresponding action a plan can take before and during submission to reduce the chance of a deficiency finding. Plans that know the process build toward it. Plans that don't are always surprised by the results.