Five Questions Every Network Build Leader Should Answer Before Starting

Start With the Right Questions

Most network builds begin the same way: someone pulls a county list, someone else exports a provider database, and the team starts working through which providers to contact in which counties. It is an understandable starting point. It is also the wrong one.

The plans that file clean networks — on time, without deficiency notices, without last-minute credentialing crunches — don't start with data. They start with a set of strategic questions that force the organization to confront its constraints before the outreach clock starts. The plans that don't ask these questions find the answers anyway, but they find them in the worst possible moment: mid-build, when changing direction is expensive and options are limited.

Here are the five questions. Answer them before anyone sends a contract.

Question 1: What Is Our Realistic Submission Date, Working Backward From CMS Deadlines?

CMS network adequacy submission deadlines are not negotiable. The filing date is fixed. What is negotiable is when your build starts — and the answer should be determined by working backward from that fixed date, not forward from whenever leadership decides to kick off the project.

Working backward means accounting for the full credentialing timeline (typically 60–90 days after a contract is signed), the contract negotiation timeline (which varies by provider type but is rarely less than 30 days), the outreach timeline (which should include at least three documented attempts per provider), and the data validation timeline before submission. When you add those up honestly, most networks require 10–14 months of active build time to reach a clean submission.

Plans that ask this question first and answer it honestly will start earlier than plans that don't. That is the entire point.

Question 2: Which Counties Are High-Risk for Deficiency?

Not all counties require the same level of attention. Frontier counties, counties with known specialty shortages, and counties where your plan has historically had trouble recruiting providers deserve disproportionate early investment. These are the counties that will still be problems in month ten if you don't treat them as month-one priorities.

The county-risk analysis should run before outreach begins. Map your service area against provider density data, CMS county-type designations, and your own prior-year exception history. The counties that appear on all three of those lists as problems are the ones that need dedicated strategy — not just a larger outreach list, but a specific plan that may include telehealth pathways, AMC contracts, or pre-emptive exception documentation.

High-risk counties that get treated as routine counties produce deficiency notices. Plans that identify them early have time to develop real solutions.

Question 3: What Is Our Credentialing Capacity, and Does It Match Our Contracting Pipeline?

This is the question that embarrasses the most network build leaders in retrospect. A plan can sign contracts faster than it can credential providers — and a provider who is contracted but not credentialed cannot be listed in the HSD table. A late credentialing queue is a direct adequacy problem at submission, regardless of how many contracts were signed.

Before the build starts, the credentialing team and the contracting team need to agree on a production rate: how many providers can credentialing process per month, and how does that match the contract-signing pace the outreach team is targeting? If the credentialing team can handle 40 providers per month and the contracting team is projecting 80 signed contracts in month six, there is a credentialing backlog problem that needs to be solved in month one, not month six.

Question 4: What Is Our Exception Strategy for Markets Where Providers Won't Contract?

There are counties in every service area where no provider will contract with your plan — because the county has only one or two providers who are already at capacity, because the specialty is in shortage, or because prior contracting relationships have soured. Pretending otherwise until month eleven is not a strategy. Having a documented exception plan is.

The exception strategy question forces the organization to identify those markets early, assign responsibility for building the good faith documentation record, and decide in advance what alternative access arrangements will be offered to members. Plans that have this answer before the build starts can begin accumulating outreach documentation on day one. Plans that discover the answer in month ten have six weeks to build a documentation record that CMS expects to cover a multi-month outreach effort.

Question 5: Who Owns the Outreach Documentation Trail, and What Does "Documented" Mean in Our Organization?

CMS's good faith exception standard requires documented outreach attempts. "Documented" is doing a lot of work in that sentence. In some organizations, it means a spreadsheet with call dates. In others, it means a timestamped log in a CRM with contact method, contact outcome, follow-up date, and provider response. CMS's expectations are closer to the latter than the former.

Before outreach starts, the organization needs to agree: what constitutes a documented attempt, who is responsible for maintaining the record, where the record lives, and how it will be assembled into an exception file if needed. This is an operational decision, not a compliance decision, and it needs to be made by someone with the authority to enforce it across the contracting team.

The plans that answer these five questions before starting a build are the plans that finish it without surprises. Clarity on timeline, risk, capacity, exceptions, and documentation is not overhead — it is the build plan.

None of these questions are comfortable to answer, because the honest answers often reveal that the organization is starting too late, has insufficient credentialing capacity, or has markets with no viable contracting solution. But those are real constraints that will surface eventually. The plans that surface them in month one have twelve months to respond. The plans that surface them in month ten have weeks — and it shows in their filings.