Application Submission

CMS encourages issuers to begin validating and submitting application materials to CMS as they are ready, rather than waiting until the required submission deadline, to ensure there is adequate time to resolve any identified validation errors.

Issuers submitting via the HIOS MPMS Module should begin validating their templates, linking the validated templates and other associated materials to their applications, and submitting each group of materials as they are ready. 

Issuers submitting via SERFF are strongly encouraged to use the new Plan Validation Workspace in the MPMS Module, as their templates are readied, to identify and resolve validation errors and warnings before submitting application data in SERFF. Issuers submitting via SERFF will be unable to submit application data to their state until all validation errors are resolved. While these validation errors will also be present through SERFF Validate & Transform, issuers are encouraged to leverage the Plan Validation Workspace to identify validation warnings, which are unexpected conditions in issuers’ data that CMS strongly advises issuers review prior to submitting data to CMS/states.

Issuers submitting via SERFF should also work with their states to meet any state-specific submission deadlines. Issuers submitting via HIOS should check with their states to confirm whether the state requires any materials to be submitted to SERFF in addition to HIOS. For additional details on the primary submission systems, reference the Submission Systems page.

QHP Application Sections and Groupings

The QHP Application is divided into individual sections and groupings within the MPMS Module. Application sections will display one of two statuses: In Progress or Ready to Submit. Each application grouping will display a status of Not Started, In Progress, Submitted – Under Review, Corrections Required, or No Action Required.

Once FFE issuers have created an application, they can begin editing each of the application sections. For sections that require the submission of one or more QHP Application templates, issuers will first need to upload the required templates to the Plan Validation Workspace and resolve identified errors before these templates can be linked to the corresponding section of the application. Once all sections in a group are in a Ready to Submit status, issuers can click a button to submit that group to CMS for review. 

Application Grouping

Application Section

Issuer Attestations and Administrative Information

Administrative

Interoperability

Program Attestations

Plan Business Rules

Business Rules

Plan Attributes

ECP/NA & Network ID

Plans & Benefits

Prescription Drugs

Service Area

Issuer Accreditation

Accreditation

Transparency Data

Transparency in Coverage

Plan Rates

Rates Table

URR*

Issuer URLs

URL

* Issuers do not submit the URR Template within the MPMS Module; this application section acknowledges submission of the URR Template through either SERFF or the URR Module within HIOS, depending on the issuer. 

Individual application groupings will be locked (i.e., not able to be edited) while CMS conducts reviews for any review areas with results being shared in the MPMS Module. After CMS’s review of all sections within a given group is complete, the application grouping will display a status of Corrections Required or No Action Required, depending on whether required corrections were identified as part of CMS’s reviews. Issuers will receive review results as CMS completes reviews for each application section, but issuers will not be able to make edits to any sections within a group until CMS completes reviews for all sections within that group

QHP Certification Issuer Toolkit

Issuers are strongly encouraged to download the QHP Certification Issuer Toolkit and reference the toolkit’s detailed checklists throughout application submission and plan certification. The plan year (PY) 2024 version of the toolkit is coming soon.

Issuers with questions or issues related to application submission should contact CMS as soon as possible via the Marketplace Service Desk (MSD) or their Account Manager. 

QHP Certification State Toolkit

The QHP Certification State Toolkit is a series of consolidated resources that state regulators can use throughout QHP certification to assist with plan management functions on the Health Insurance Exchanges. The PY2024 QHP Certification State Toolkit is coming soon. 

        This document is a supplemental resource and is not intended to replace official guidance or instructions.

        State regulators should send all questions regarding the QHP Certification State Toolkit to PlanManagementStateCoordination@cms.hhs.gov.