Best Practices for Medicaid Secret Shopper Survey Implementation

Executive Summary

Network adequacy has long been a challenge in Medicaid managed care. According to one 2023 survey, 1 in 3 Medicaid enrollees report that in the past year an in-network provider they needed to see did not have available appointments. To address these challenges, the 2024 Managed Care Access final rule establishes new federal appointment wait time standards and requires states to conduct annual independent secret shopper surveys. While the secret shopper survey requirement will not be fully effective until 2028, many states already use this accountability tool to monitor and enforce network adequacy for Medicaid plans. Advocates should understand now what best practices make secret shopper methodologies most effective to monitor equitable access to care in Medicaid managed care.

This issue brief summarizes the new Medicaid requirements, presents several of the methodological challenges that can complicate this approach, and provides advocacy tips for secret shopper survey implementation.