Data Validation

The Plan Validation Workspace is a new feature for 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. 

Starting in PY2024, issuers in all states will be required to validate their QHP Application data for compliance with these federal standards prior to submitting these data either to CMS (via HIOS) or to their state (via SERFF).  

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.
All issuers are required to validate their QHP Application data in the Plan Validation Workspace 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 to their state via SERFF until all validation errors are resolved.

As in prior years, issuers in states performing plan management functions and SBE-FP issuers must pass validations within SERFF Validate & Transform in order to submit their QHP Applications to their states. SERFF Validate & Transform has been enhanced for PY2024 to include several new validations, including those related to data integrity and standardized plan options.

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.
  • 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.
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.

Uploading Data to 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.

MPMS Validations List

The MPMS Validations List provides a comprehensive list of validations performed by the MPMS Module. 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.

Cross Validating Templates

After reviewing and correcting validation errors and validation warnings (if applicable), issuers are able to proceed with cross validating their QHP Application templates. While issuers are able to cross validate within the Application Overview page, CMS encourages issuers cross validate within the Plan Validation Workspace. Only templates in a validation status of “No Errors Found” or “Warnings Found” can be cross validated.
Issuers are required to cross validate their templates and remediate any identified errors prior to submission to CMS. 

Additional Resources: