Data Validation

This page explains the validation steps issuers will follow throughout the certification process, and the systems used to complete these validations.

Plan Validation Workspace 

The Plan Validation Workspace was introduced in PY2024, and is a space within the HIOS MPMS Module in which issuers upload and validate the data in their QHP Application templates for compliance with a variety of federal standards, including data integrity and standardized plan options. 

Issuers in all states are required to validate their QHP Application data in the Plan Validation Workspace for compliance with these federal standards and remediate all identified validation errors prior to submitting their application(s). Issuers will not be able to submit their applications to CMS via the HIOS MPMS Module or submit application data to their state via SERFF until all validation errors are resolved.

Please note: Once issuers submit data to their state via SERFF (if applicable), they can view validation errors and warnings on these data in the Plan Validation Workspace; there will be a designation indicating these results are from the SERFF submission. These validation results will replace any existing results that were generated by uploading templates into the workspace. 

Validating application data or cross validating an application within the Plan Validation Workspace allows issuers to access their pre-submission review results. Pre-submission review results (“validation results”) display as either:
  • Validation errors: Issuers must correct their application to resolve these errors prior to submitting an application
  • Validation warnings: Issuers should review these warnings to determine whether a correction needs to be made to an application prior to submitting it. Some identified validation warnings may require the issuer to provide a justification prior to submitting the QHP Application.

Uploading and Validating Data in the Plan Validation Workspace

Once issuers have logged into the HIOS MPMS Module, they can take the following steps to validate their QHP Application templates:
  1. Select the plan year and issuer ID for validation.
  2. Select “Show Workspace” to begin uploading files for validation.
  3. Upload files for validation in the “Upload Files” section.
    • Note: The system will automatically identify the type of template uploaded, regardless of naming convention. Issuers may remove a file by selecting the trash can icon listed next to the template.
  4. Select “Validate” to submit the files for validation. 

Reviewing Results Received in the Plan Validation Workspace

Issuers should review each validation result listed in the Validation Results section. For any identified errors and warnings, issuers should review the detailed validation messages and then make any needed corrections, including uploading required justifications or supporting documents. 

Validation Results and Descriptions:
  • No Errors Found: The template passed all validations.
  • Warnings Found: The template is acceptable, but the user may need to provide a justification if the template is linked to a QHP Application, or there is an unexpected data condition CMS would like to flag to the user.
  • Errors Found: Errors are present within the template that require corrections before the template can be linked to the QHP Application. This status will also display if there are errors and warnings present in the template.
  • Processing Error: A processing error was encountered with the file. Try generating a new XML file using the Finalize macro in the template and re-uploading. If the issue continues, contact the help desk.

Cross Validating Templates

After reviewing and correcting validation errors and validation warnings (if applicable), all issuers should proceed with cross validating their QHP Application templates. Issuers are required to cross validate their data prior to submitting to CMS. Issuers will be unable to submit their application groups until resolution of any pending cross validation errors. Note: Only templates in a validation status of “No Errors Found” or “Warnings Found” can be cross validated. 

Starting in PY2025, when issuers in states performing plan management functions and SBE-FP issuers hit the "Submit Group" button in MPMS, cross validation checks will automatically run on the applicable data and display to the issuer. Issuers must resolve any outstanding cross validation errors and attempt to resubmit. If changes to application data originally submitted via SERFF are necessary based on cross validation errors and warnings, issuers must work with their states to retransfer data before attempting to submit in MPMS again.

As a reminder, SERFF-submitting issuers are encouraged to cross validate their application data in the Plan Validation Workspace before attempting to submit an application, in order to identify any cross validation errors that would prevent submission.

Additionally, starting in PY2025, applicable issuers must complete all required cross validation checks in specific MPMS sections before submitting the respective sections. These steps are in addition to cross validation checks performed on the rest of the issuer’s QHP Application and include: 
  • Cross validation checks within the Plans & Benefits section to identify whether Non-Standardized Plan Option Limit Exception justifications are required.
  • Cross validation checks within the Plan ID Crosswalk section to cross validate the Plan ID Crosswalk Template against the Plans & Benefits Template and the Service Area Template.

SERFF Validate & Transform

Issuers in states performing plan management functions and SBE-FP issuers must use the Plan Validation Workspace in the MPMS Module prior to SERFF Validate & Transform. Following validations in the Plan Validation Workspace, these issuers must also pass validations within SERFF Validate & Transform in order to submit their QHP Applications to their states.
  • Validate & Transform will identify the same validation errors as MPMS. Issuers must correct these errors before submitting their QHP data.
  • Validate & Transform will not identify validation warnings, which are unexpected conditions in issuers’ data.
  • Issuers can only check QHP data for validation warnings by using the Plan Validation Workspace in MPMS.
MPMS Validations List

The MPMS Validations List provides a comprehensive list of validations performed by the MPMS Module. Issuers in all states may reference this resource. The tabs for single template, cross template, application, and external application validations include details such as validation codes, validation error or warning messages, the associated template(s), and the applicable state Exchange model(s) for each validation. The ‘Definitions’ tab includes descriptions of each type of validation and state Exchange model, and the ‘Allowed Special Characters’ tab lists the special characters allowed in templates or URL submissions in the MPMS Module.

Review Results

CMS will continue to release post-submission review results (“required corrections”) for all issuers, based on data submitted by the prior submission deadline at least once before the next submission deadline. For additional information on both pre- and post-submission review results, please access the QHP Application Review Results webpage.

Additional Resources: