Data Change Windows

During the certification process, CMS allows issuers to make changes to their QHP Application templates based on the guidelines below. These changes are in addition to any corrections that CMS identified during its review of QHP Applications.

Before the Initial Application Submission Deadline

Issuers may make changes to their QHP Application data without state or CMS authorization until the deadline for initial application submission.

After the Initial Application Submission Deadline

After the close of the initial QHP Application submission window, issuers may not add new plans to a QHP Application, change an off-Exchange plan to both on- and off-Exchange, or change a plan's metal level, plan type, or market. Issuers also may not change QHPs, excluding stand-alone dental plans (SADPs), from a child-only plan to a non-child-only plan. For all other changes, issuers will be able to upload revised QHP data templates and make other necessary changes to QHP Applications in response to state or CMS feedback until the final deadline for issuer changes.

After the Final Application Submission Deadline

After the final deadline for issuer changes to QHP Applications, issuers will only make corrections as directed by CMS or by their state. States may direct issuers to submit a data change request to CMS that documents State-approved corrections. If CMS approves the data change request, then CMS will open a submission window for the issuer to submit the approved corrections. Issuers with a CMS-identified correction after the final QHP Application submission deadline are required to enter a limited data correction window and may be subject to compliance action by CMS. Issuer changes made in the limited data correction window that are not approved by CMS and/or the state may result in compliance action by CMS, which could include decertification and suppression of the issuer's plans on HealthCare.gov.

After QHP Certification

After completion of the QHP certification process, CMS may offer additional data change windows. CMS will only consider approving changes that do not alter the QHP’s certification status or require re-review of data previously approved by the state or CMS. CMS will offer windows for Small Business Health Options Program (SHOP) quarterly rate updates. Administrative data changes should be made in the Health Insurance Oversight System (HIOS) Plan Finder Module and URL updates should be made in the HIOS Marketplace Plan Management System (MPMS) Module, and do not require a data change request to CMS; however, URL changes still require applicable state authorization prior to being updated.

A request for a data change after the final submission deadline, excluding administrative changes or SHOP quarterly rate updates, may be made due to inaccuracies in or the incompleteness of a QHP Application, and may result in compliance action. Discrepancies between the issuer’s QHP Application and approved state filings may result in a plan not being certified or compliance action if CMS has already certified a plan as a QHP. Issuers that request to make changes that affect consumers may have their plans suppressed from display on HealthCare.gov until the data is corrected and refreshed for consumer display. 

Before making QHP Application data changes, issuers must request to make the change and receive approval from CMS and their state. For QHPs in states that do not enforce market-wide requirements, the CMS Form Filing team, rather than the state, must authorize data changes.

To request a data change, issuers are required to provide a justification for each requested change. Issuers in Federally-facilitated Exchange (FFE) states must submit signed evidence of state authorization or CMS Form Filing approval. Issuers are responsible for ensuring that requested changes comply with federal QHP certification standards set forth in the Patient Protection and Affordable Care Act (PPACA), federal regulations, and all other guidelines discussed in the Letter to Issuers.

Data Change Requests

All issuers in FFE states and states performing plan management functions, including issuers applying for off-Exchange SADP certification, must submit data change requests (DCRs) for all changes made after the final submission deadline.

How to request a data change:

1. Gather the necessary documentation.
a. DCR Supplement
b. State Authorization (FFE issuers) 

2. Submit data change request and associated supporting documentation to CMS via the Plan Management (PM) Community.
a. CMS will deny data change requests that do not include all required elements.
b. Issuers may only submit one data change request per one template. 

3. Wait for CMS approval.

4. Make changes during assigned data change window.

Changing Plan Data

• During the initial application submission window: Issuers may change any of their data without CMS or state authorization, including adding/removing plans or changing plan type.
• After the initial application submission window deadline: Issuers may not add plans or change plan type. Plan Withdrawal Notification Forms are required to remove plans. For all other changes, issuers are not required to submit data change requests or document state or CMS Form Filing authorization to CMS.
• After the final application submission deadline: Issuers will have a final opportunity to withdraw plans during the plan confirmation process. CMS may allow issuers to make critical data corrections in order to correct data display errors on HealthCare.gov and align QHP data display with products and plans approved by the state. Data changes after the final application submission deadline that are not directed by CMS require data change requests, CMS approval, and state approval.

Plan Year 2024 Data Change Windows

CMS will offer the following three (3) opportunities for issuers to request and make PY2024 SHOP quarterly rate updates. Issuers that need to correct CMS-approved critical plan data that displays to consumers and/or align QHP data with products and plans as approved by the state should submit a data change request as soon as possible. If CMS approves the data change request(s), CMS will communicate to the issuer and state when the issuer is approved to submit its updated QHP Application data.

 NOTE: The dates listed in this table are subject to change.

Criteria for Allowable Changes:

• CMS will only consider approving changes that do not alter the QHP's certification status or require re-review of data previously approved by the state or CMS.  
• Changes to Individual Market rates, service area, or EHB percent of total premium will not be permitted unless the issuer can demonstrate specific critical issues resulting from data entry errors.
• Examples of changes that CMS may consider approving are:
• • Changes to plan or plan variant marketing names; 
  • Minor changes to cost-sharing information and limits explanations; and
  • CMS-requested data corrections.  

NOTE: Issuers must make all changes to administrative data, such as customer service numbers, in HIOS Plan Finder, and all changes to URLs in the HIOS MPMS Module. CMS does not require or review a data change request for administrative data changes made in HIOS Plan Finder or for URL data changes made in the HIOS MPMS Module.

Process for Requesting Changes to QHP and SADP Data:

• For issuers in Federally-facilitated Exchange (FFE) states: 
• • Issuers should submit data change requests as soon they realize a data change is required. For SHOP quarterly rate changes, issuers must submit requests by no later than the “Final Date to Submit Data Change Requests” listed in the table above for each window. All requests must be submitted in the Cases tab of the PM Community. 
  • Requests must include documented approval by the state regulator or, for issuers in states that do not enforce market-wide requirements, CMS Form Filing. 
  • CMS will respond to data change requests via email from CMS_FEPS@cms.hhs.gov. 
  • Once CMS approves a change, the issuer must resubmit their templates during the window provided by CMS in the email response. Issuers will be able to submit changes between 8:00 a.m. ET on the window start date and 6:00 p.m. ET on the window end date.
    
    
• For issuers in states performing plan management functions: 
• Issuers should submit data change requests as soon they realize a data change is required. For SHOP quarterly rate changes, issuers must submit requests by no later than the “Final Date to Submit Data Change Requests” listed in the table above for each window. All requests must be submitted in the Cases tab of the PM Community. 
• Issuers should concurrently submit requests to their state to begin the state approval process for the requested changes sent to CMS.
• CMS will respond to data change requests via email from CMS_FEPS@cms.hhs.gov. 
• QHP issuers in states performing plan management functions should work with their state to secure state approval and to request reopening System for Electronic Rates & Forms Filing (SERFF) binders once changes are approved. Issuers in states performing plan management should contact their state for the revision submission deadline prior to 3:00 p.m. ET on the transfer deadline provided in the email response from CMS.
  
  
• For issuers in State-based Exchanges on the Federal Platform (SBE-FPs): 
• Issuers in SBE-FPs should direct data change requests to their state Exchange for approval. CMS will not review requests for changes from issuers in SBE-FPs. SBE-FP issuers should contact their state for the revision submission deadline, and SBE-FP states should contact CMS in advance of transferring data from SERFF to HIOS. 

Issuers MUST include the following in their requests:

• Completed data change requests in the PM Community should include:    
• • HIOS Issuer ID
  • Issuer name
  • Issuer state
  • Impacted plan ID(s)
  • A detailed description of the QHP data change requested:    
  • • Specific information about data fields that require revisions:  
    • • Issuers requesting Plans & Benefits, Business Rules, or Service Area Template changes must complete the DCR Supplement (see below). 
    • Details about the revisions needed, including original and revised values.
  • Justification for why the change is required.    
  • • If the first justification is chosen, issuers must include copies of the relevant section of their form filing.
    • If the second justification is chosen, issuers must include screenshots of data errors.
• The justification must be signed by an authorized representative of the issuer. If the issuer received notification directly from CMS about needed data changes, include documentation of the CMS request (i.e., an email or communication) in the data change request.
• Evidence of state approval, including specific content about the requested data changes if operating in an FFE state, OR approval from CMS Form Filing if a QHP or dual issuer in a state that does not enforce market-wide requirements.   
• • The CMS Form Filing team requires the State Authorization of QHP Data Change Request Form to be submitted along with the other documentation of the requested change for authorization consideration. 
• The DCR Supplement to the Data Change Request Form—if requesting a Plans & Benefits, Business Rules, or Service Area Template change.     
• • This workbook has four tabs: "P&B Benefits Package," "P&B Cost Share Variance," "Business Rules," and "Service Area."    
  • • Fill out the tab that corresponds to the template of the proposed change. All other tabs should be blank. 
    • Each tab includes fields to be filled out as appropriate for the proposed change. All fields must be completed for all requested changes. 

Reasons for Potential Compliance Action:

• A request for a data change, excluding administrative changes, indicates the presence of inaccuracies and/or the incompleteness of a QHP Application. Because this calls into question an organization's ability to submit correct data and the validity of the final application, data changes made during a data change window may result in compliance action and/or a work plan for the issuer to address the ability to submit correct data. Issuers may face further compliance action if the work plan instructions are not followed, if there are continued inaccuracies, or if there are unauthorized data changes made. 
• Issuers with approved changes must ensure that they remain in compliance with all certification standards, including non-discrimination and cost-sharing reduction requirements. Issuers are required to use the Plan Validation Workspace within the HIOS MPMS Module to access validation errors and warnings in their updated QHP Application data, and resolve all identified validation errors prior to submitting their updated application data, regardless of state Exchange type; SERFF Validate & Transform has also been enhanced to include checks for these standards. Issuers may also check their templates using CMS's Application Review Tools, including the Cost Sharing Tool and Data Integrity Tool. CMS will consider compliance action(s), including removing the plans from sale on-Exchange, if the change results in a plan no longer meeting a QHP certification standard.

Data Change Request Instructions and Supporting Documents: