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 in FFE states 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 in states performing plan management functions and SBE-FP states 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 application data via SERFF will be unable to submit 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 in states performing plan management functions and SBE-FPs will continue to submit the majority of their application data to their states through SERFF before that data is transferred by their state; however, starting in PY2025, these issuers must also submit all required application groups relevant for each deadline within the MPMS Module. When issuers hit the ”Submit Group” button in the MPMS Module, cross validation checks will automatically run on the applicable data and display to the issuer. If changes to application data originally submitted via SERFF are necessary based on cross validation errors or warnings, issuers must work with their states to retransfer data before attempting to submit in MPMS again.

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 Groups

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

Once issuers have completed all necessary application materials, resolved all identified errors, and all applicable 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 Group	Application Section
Issuer Attestations and Administrative Information	Administrative
	Interoperability
	Program Attestations
Plan Business Rules	Business Rules
Plan Attributes	Plans & Benefits
	Prescription Drugs
	Service Area
	Network ID
	Essential Community Providers
	Network Adequacy
Plan Crosswalk	Plan ID Crosswalk
Issuer Accreditation	Accreditation
Transparency Data	Transparency in Coverage
Plan Rates	Rates Table
Plan Rates	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 groups 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 completes reviews of one or more sections within a given group, the application group will display a status of Corrections Required if there are required corrections for at least one of the completed review areas. After CMS completes reviews of all sections within a given group, the group will display a status of No Action Required if there were no required corrections 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.

Please note: The Plan Attributes group is an exception to this requirement. If the Network Adequacy review has not yet been completed and CMS has completed all other reviews in the Plan Attributes group, the group will display a status of Corrections Required or No Action Required depending on CMS’s reviews of the other five sections within the Plan Attributes group. Issuers will be able to edit the other five sections within the Plan Attributes group at that time.

Checking Submission Status

After submitting one or more groups, issuers should confirm that the submitted application groups have a status of Submitted – Under Review, Corrections Required, or No Action Required. For each application submission deadline, issuers should confirm that all applicable groups have one of these three statuses. Issuers are encouraged to refer to the Issuer Toolkit for specific submission requirements for each deadline.

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.

QHP Certification Roadmaps outlining the differing paths to certification for issuers in FFE states and for issuers in states performing plan management functions and SBE-FP states;
Steps to take prior to the initial submission deadline to help your organization prepare for the certification process;
Steps for validating data prior to submission, including how to address both validation errors and warnings;
Specific submission checklists for issuers to reference before each deadline (Early Bird, initial, secondary, and final) with differing SERFF and HIOS requirements delineated;
Detailed instructions on submitting application data within the correct submission system, including how to check the status of an application;
Actions to take when required corrections are released;
Guidance on where review results are released for each review area;
Guidance for completing certain certification activities, such as plan confirmation and agreement-signing; and
Additional tips specific to SERFF-submitting issuers for each step of the process.

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.

States’ roles and responsibilities throughout the QHP certification process;
Information on systems both states and issuers use to complete QHP certification;
Important dates and reminders;
QHP certification resources; and
A high-level summary of key updates from CMS guidance.

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.

Application Resources:

Instructional Video

How to Submit a QHP Application (Coming soon!)