Ghost Networks, ERISA Fiduciary Duty, and the Future of Provider Directory Litigation

Naga Vivekanandan examines the growing scrutiny of “ghost networks” — provider directories that list inaccurate or unavailable providers — and the fiduciary risks they pose for ERISA-governed health plans. She explains how inaccurate network data can expose plan sponsors to compliance challenges, participant complaints, and potential litigation risk, while underscoring the importance of diligent vendor oversight and fiduciary governance.