Essential Community Providers FAQs

PY2025 ECP Changes

Q6: What key changes to essential community provider (ECP) policy and operations will take place beginning in PY2025?
There are no essential community provider (ECP) policy updates for PY2025.
Beginning in PY2025, all issuers (except those operating in State-based Exchanges), including issuers in states performing plan management functions and State-based Exchanges on the Federal Platform (SBE-FP) states, will submit ECP data directly into MPMS rather than through an Excel template.
For convenience and ease, issuers may choose to import their ECP data from their PY2024 application and then make updates.
The ECP Review Tools and the ECP Write-in Worksheet can only be used by issuers operating in State-based Exchanges (SBEs).

ECP List and Review Tools

Q1: Why am I not receiving credit for certain ECPs when they are included on the Final Plan Year ECP List?

The Final Plan Year ECP List reflects the universe of ECPs at a particular snapshot in time, but in reality the ECP landscape changes regularly. Therefore, at times, providers may appear on the Final Plan Year ECP List that are not recognized when entering ECP data into MPMS, resulting in error messaging.

To keep the ECP List as accurate as possible, CMS routinely performs research and outreach to providers on the ECP List to verify information about ECPs collected via the ECP petition site. During these efforts, CMS sometimes identifies providers requiring removal from the ECP List, usually for one of the following reasons:

The provider has closed.
The provider has undergone a status change, such as termination of participation in the 340B program, that has made them ineligible for inclusion on the ECP List.
The provider has been found not to be open year-round, making them ineligible for inclusion on the ECP List.
The provider has temporarily or permanently stopped providing either medical or dental services at a facility that once offered both medical and dental services, and therefore may no longer be recognized when entering ECP data into MPMS.

When CMS discovers such provider status changes after the Final Plan Year HHS ECP List has been released, and prior to/or during QHP application submission season, the providers remain on the Final Plan Year ECP List but may have been removed from the list of ECPs from which issuers may select in MPMS. Similarly, when providers are removed from the ECP Tools due to no longer being eligible, issuers will not receive credit toward meeting the ECP standards for having contracted with these providers, nor will they be penalized for an inability to contract with them.

The latest versions of the ECP Tools (that can only be utilized by issuers in State-based Exchange states, beginning in PY2025), available on the QHP certification website have been updated to provide issuers with clearer messaging about provider status changes that may result in removal of providers from the ECP Tools.

Q11: How do issuers use the Data Consolidation Review Tool and the ECP Tools to assess their compliance with ECP requirements for medical QHPs and stand-alone dental plan (SADP) QHPs, given that ECP data are no longer collected within the NA Template?

Starting in Plan Year 2025, issuers operating in Federally-facilitated Exchange (FFE) states, including states performing plan management functions, and State-based Exchanges that use the Federal Platform (SBE-FP) are unable to directly use the Data Consolidation Tool, Medical QHP ECP Tool, or Stand-alone Dental Plan (SADP) ECP Tool. Instead of entering their ECP data into a template, issuers in the above state Exchange types must complete all ECP-related activities within the Marketplace Plan Management System (MPMS) ECP user interface (UI).

If your state requires issuers to use the Medical QHP ECP Tool and/or the SADP ECP Tool to satisfy state certification requirements, then issuers can:

Complete your entry of ECP data within the MPMS UI to the best of your ability.
Use the Download ECPs (CSV) button at the top of the MPMS ECP UI.
Import your Plans & Benefits Template and Service Area Template into the Data Consolidation Tool.
Open your downloaded ECPs CSV file with a name in the form of "Select_ECPs_MM-DD-YYYYTimeStamp".
Copy and paste the information from the ECPs CSV file into the 'All ECP Data' tab of the Data Consolidation Tool.

Keep in mind the ECP tools are only designed to evaluate ECP data for those providers for whom an issuer has secured a fully executed contract for the respective plan year. Therefore, an issuer should only copy and paste the provider data for which the issuer has reported a "Negotiation Status" of Contract Executed in the downloaded ECPs CSV file.

CMS can provide additional detailed guidance, as needed, on how to run the ECP Tools workaround for your state requirement if you submit a help desk ticket to the Marketplace Service Desk at CMS_FEPS@cms.hhs.gov.

ECP Standards and Requirements

Q2: Do all issuers have to submit essential community provider (ECP) data?

Yes, all issuers are required to submit ECP data. This requirement applies to both medical QHP and stand-alone dental plan (SADP) issuers. Starting in PY2025, issuers in the Federally Facilitated Exchange (FFE), including in states performing plan management functions, and State-based Exchanges using the Federal Platform (SBE-FP) will submit their ECP data via user interface within their application in MPMS. Issuers in State-based Exchange states will continue to populate the NA Template with both their ECP and their NA data.

Q4: What will happen if a QHP applicant does not meet one or more of the Essential Community Provider (ECP) standards?

If CMS determines that a QHP applicant does not meet one or more ECP standards, the issuer can:

Add more contracted providers to the network to come into alignment with the unmet standard(s) and update the ECP section in MPMS to include these additional providers; and/or
Complete all required justification information/contract details fields and resubmit within MPMS.

CMS has retired the ECP Justification Form and the ECP Write-in Worksheet as they have been integrated into data fields within the MPMS user interface. CMS will continue to monitor ECP compliance throughout the year and will coordinate with state Departments of Insurance should it be necessary to remedy potential instances of noncompliance.

Q9: Should ECP facilities and providers only located in the same state as the plan's service area be used to meet the ECP standard?

Yes, the Marketplace Plan Management System (MPMS) will only display Essential Community Providers (ECPs) available for issuers to select in the state of the issuer’s service area. In order for the issuer to receive credit towards satisfaction of any of the three elements of the ECP standard, providers must be located in the state corresponding to the issuer’s service area for the respective plan ID and network ID combination, as the ECP standards are not based on time and distance standards as it is for Network Adequacy (NA) standards. Furthermore, in order for the issuer to receive credit towards satisfaction of the requirement that an issuer offers a contract to at least one ECP in each ECP category in each county, where available, the provider must be located in the respective county.

Q8: Can a QHP that offers a tiered network count any provider, regardless of the provider’s contracted network, toward the issuer’s satisfaction of the ECP standards?

No, for plans that use tiered networks, Essential Community Providers (ECPs) must be contracted within the network tier that results in the lowest cost-sharing obligation to count toward the issuer's satisfaction of each element of the ECP standard. For example, a QHP issuer cannot use the number of ECPs contracted with their PPO network to certify their HMO network if using the PPO network providers would result in higher cost-sharing obligations for HMO plan enrollees. For plans with two network tiers (for example, participating providers and preferred providers), such as many PPOs, where cost sharing is lower for preferred providers, only preferred providers would be counted toward ECP standards.

Q3: How should issuers enter ECP providers that practice from multiple locations?

Issuers must enter ECPs into MPMS at the facility level rather than at the individual practitioner level. For ECP facilities that are operated by a solo practitioner that practices from multiple locations, the issuer should select each facility location and the provider site name associated with each facility that appears on the HHS Final ECP List or list of available ECP Write-ins for the respective plan year.

ECP Submission in Marketplace Plan Management System (MPMS)

Q10: Where do I submit my ECP data?

Based on the Exchange Model in your state, issuers will use the following method to submit ECP data:

Exchange model	MPMS ECP User Interface (UI)*	Use of the NA Template** to submit ECP data	SERFF Plan Transfer	ECP Review Tools
FFE	YES Required to submit ECP data via the MPMS UI rather than through a template.	NO No longer available	n/a	NO Contact the Marketplace Service Desk for a manual workaround option for the ECP Tools.
SBE-FP	YES Required to submit ECP data via the MPMS UI rather than through a template.	NO No longer available	Can update their Network ID data in MPMS once their state transmits their Network ID Template through Plan Transfer.	NO Contact the Marketplace Service Desk for a manual workaround option for the ECP Tools.
States performing plan management functions	YES Required to submit ECP data via the MPMS UI rather than through a template.	NO No longer available	Can update their Network ID data in MPMS once their state transmits their Network ID Template through Plan Transfer.	NO Contact the Marketplace Service Desk for a manual workaround option for the ECP Tools.
SBE	Not Required Issuers in SBEs may elect to utilize the Plan Validation Workspace in MPMS to identify any errors prior to submitting their data to their State DOI.	Available For Use When SBE issuers indicate on the NA Template that they are in a SBE state, ECP tabs will appear for issuers to populate if the state wants them to use the template to submit ECP data. For SBE issuers in states that choose to use our PY25 NA Template, they will continue to have the option of using the template to submit both their ECP and NA data. Such SBE issuers should consult with their respective state for more detailed guidance	n/a	Encouraged for SBE Issuers Because SBE states will still have the ability to submit ECP data via template for PY2025, they will also still be able to use the ECP Review Tools.

*The MPMS ECP UI combines functions of the ECP side of the former ECP/NA Template. The ECP Write-in Worksheet and ECP Justification Form have also been integrated into MPMS for FFE issuers, including issuers in states performing plan management functions, and SBE-FP states.

**What has previously been called the "ECP/NA Template" has been renamed the "NA Template" for PY2025.

Q13: How do I upload all my ECPs for PY2025 into the Marketplace Plan Management System (MPMS)?

Issuers in Federally-facilitated Exchange (FFE) states that submitted a Qualified Health Plan (QHP) application in the previous plan year have the option to import their Essential Community Provider (ECP) data from their prior-year application into the Marketplace Plan Management System (MPMS) user interface (UI). From the ECP UI, issuers can make necessary updates to these providers, as well as add newly recruited providers that were not part of a prior-year network.

To add or update provider information in MPMS, the issuer will need to:

Navigate to the ECP Introduction screen of MPMS and click “Yes, I will select networks to import” for the question, “Do you want to import the ECPs you entered on last year’s application into this year’s application?” The issuer can then choose which networks to import.
If the issuer elects to use this method, all the prior-year template data including the selected prior year network IDs will be imported into MPMS.

Note that imported ECPs that have closed or lost their ECP eligibility will not be transferred.

Issuers that import their prior-year ECPs may also add additional ECPs to their networks.

To change network assignments in MPMS, issuers can:

Edit network IDs for PY2025 directly on the Select ECPs Table in the UI; or
Click "Edit" in the "Status & Action" column, which will take the issuer to the Edit Details screen.

Issuers that decide against importing their prior-year ECP data and issuers that are new to the Marketplace must first:

Navigate to the Select ECPs screen in MPMS and then select Add ECPs to add providers.
The Add ECPs screen displays relevant information about providers that are on the Final ECP List. Issuers select providers from that list with whom they have fully executed contracts for the upcoming plan year. Letters of Intent and Letters of Agreement do not equate to a fully executed contract with a provider that is legally enforceable.

Issuers in FFE States performing plan management functions will need to create their QHP Applications in MPMS, before being able to input or transfer their ECP data. Once their QHP Applications have been created in MPMS, they will be able to navigate to the ECP section within the Plan Attributes Group to input their data.

Issuers in FFE States performing plan management functions and issuers in State-based Exchanges on the Federal Platform (SBE-FPs) can enter and save their ECP data within the ECP UI prior to Plan Transfer. Once the state transfers an issuer's Network ID Template from the System for Electronic Rates and Forms Filing (SERFF) to MPMS, the issuer can then update the required Network ID field in the ECP UI. The issuer may then validate and complete submission in MPMS.

Q12: How do issuers select Write-in ECPs to help meet the ECP requirements?

Available Essential Community Provider (ECP) Write-ins are providers that have been approved by CMS for inclusion on the subsequent plan year’s Final ECP List, and appear on the Rolling Draft ECP List and in the Marketplace Plan Management System (MPMS) user interface (UI). To select Write-in ECPs, the issuer will need to navigate to the 'Select ECPs' screen of the ECP UI, and select 'Add ECPs.' On the 'Add ECPs' screen, issuers should check the 'New Write-in ECPs' box to search and select available Write-in ECPs to add to their ECP list.

Alternate ECP Standard issuers (defined as an issuer that provides the majority of their covered professional services through physicians employed directly by the issuer or through a single contracted medical group) can add custom Write-in providers by selecting the ‘Write-in ECP’ button in the 'Select ECPs' screen of the MPMS ECP UI; a pop-up screen will appear allowing the issuer to enter required information about the custom Write-in provider.

Q7: Where do issuers upload their ECP Template and ECP Write-in Worksheet within the Health Insurance Oversight System (HIOS)?

CMS has retired the ECP Justification Form and ECP Write-in Worksheet; issuers will enter this information directly into MPMS via the user interface for PY2025. FFE issuers, issuers in states performing plan management functions, and issuers in State-based Exchanges on the Federal Platform (SBE-FP) will submit their ECP data in the QHP Application they create in the Marketplace Plan Management System (MPMS) Module within HIOS, as described in the ECP Instructions found on the QHP certification website. CMS has integrated the ECP Justification and ECP Write-in Worksheet into MPMS and issuers will no longer complete or upload either of these documents.

Q5: Can issuers submit the ECP section within MPMS with missing data?

All Provider Contract Details fields in the ECP section of MPMS are required. Depending on the issuer’s negotiation status, the ECP screen in MPMS will dynamically update applicable fields to collect additional justification information based on user responses.

MPMS Validation Warnings, Errors, and Corrections

Q15: Where can issuers find more detailed information about their ECP corrections within MPMS?

The Plan Attributes/Essential Community Provider (ECP) section does not include detailed information regarding corrections, including the impacted counties and categories. To access a detailed file that includes this information, please navigate to the ECP section of Marketplace Plan Management System (MPMS) and click on the 'Save and Complete' button at the bottom of the screen.

The ECP Validation Results will reappear, and you will have the opportunity to download the results in .csv format. It may be helpful to save this file for future reference.

Q14: We encountered an ECP error when validating on MPMS. The MPMS error indicates an ECP selected in our network does not correspond to an ECP on the CMS ECP List, but we identified it on the CMS list. Why are we getting this error? What should we do?

As stated in Q1, CMS performs routine research to remove providers no longer eligible. Issuers will NOT be penalized for their inability to contract with these ineligible providers.

Issuers can remove the ineligible provider in MPMS and add more contracted providers to the network to come into alignment with the ECP standards by updating the ECP section in MPMS to include these additional providers. MPMS enables issuers to update their ECP information and resubmit repeatedly over the certification cycle. The final application deadline is August 14, 2024. Issuers may continue to update their application information until that date.