Essential Community Providers FAQs

PY2025 ECP Changes

Q1: 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

Q2: 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.

Q3: 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.

Q4: What can we do when we are not able to contract with Indian Healthcare Providers on the ECP list in MPMS?

To meet the Indian Health Care Provider (IHP) element of the Essential Community Provider (ECP) Standard, issuers must offer contracts in good faith to all available Indian health care providers in the plan’s declared service area to participate in the plan’s provider network for the respective Qualified Health Plan (QHP) certification plan year.

Issuers will need to conduct outreach and offer a contract to all IHPs to meet this requirement; frequently, outreach requires multiple efforts via multiple channels. Whether by phone, mail, or email, issuers should make multiple good faith attempts to reach out to the provider, including calling at different times during the day (i.e., a health clinic may have only morning or afternoon hours), different days of the week (i.e., a health clinic may be open only certain days of the week), and combining phone calls with emails and letters. CMS would not consider an issuer who reached out to a provider only once at the beginning of the QHP certification season to be in compliance with the requirement to make a good faith contract offer to the provider, unless the issuer made actual contact with the provider and was able to offer a contract to that provider that was either ignored or rejected by the provider.

Issuers should document their outreach efforts so that they can demonstrate their good faith attempts during a compliance review.

Q5: What is the difference between the Final PY2025 ECP List and the Rolling Draft ECP List and when are these lists updated?

Since the ECP landscape changes regularly, CMS generates two versions of the ECP List (i.e., the Final PY2025 ECP List and the Rolling Draft ECP List) to ensure that the ECP Reference Data embedded in the MPMS is kept up to date so that issuers are not unfairly penalized for failing to contract with facilities that have closed or become ineligible after the Final ECP List has published. These two ECP Lists are used to assist Qualified Health Plan (QHP) issuers with identifying providers that serve primarily low-income and medically underserved populations and that qualify for inclusion in an issuer’s plan network toward satisfaction of the ECP standard under 45 CFR 156.235.

The Final PY2025 ECP List is a static list of available ECPs that shows a snapshot of the universe of ECPs at a particular time.

As stated in the Description Sheet for the Final PY2025 ECP List, providers included on the final CMS ECP list for the plan year 2025 reflect those providers that submitted an online ECP petition between December 9, 2015, and August 16, 2023.
The Final ECP List is a static list; providers are not added or removed from the Final ECP List after it has been posted.
Last updated on 4/16/2024. CMS does not have intentions to update this final list for PY2025. This list is released annually, and the cutoff for the Final ECP List occurs each year in mid-August.
Posted at https://www.qhpcertification.cms.gov/s/Essential%20Community%20Providers.

The Rolling Draft ECP List is a dynamic list that contains the most recent ECP information.
This active list is continually changing; providers can submit a petition to be added to the rolling draft list, update their existing petition, or remove their ECP from the list.
This list is not used for certification requirements since this would create a moving target for issuers, given that providers are regularly added to this list throughout the year.
Updated at least monthly to include recently approved provider petitions submitted after the Final PY2025 ECP List cutoff (8/16/2023) that are eligible for inclusion on the PY2025 List of Available ECP Write-ins (8/17/2023 - 8/14/2024).
Posted at https://data.healthcare.gov/rolling-draft-list.
The MPMS ECP Reference Data is exclusively used in MPMS for QHP Certification Reviews. CMS uses the Final PY2025 ECP List and accounts for provider closures and ECP eligibility changes that occur after the release of the Final PY2025 ECP List on the QHP certification site.
Although this dataset is not static, new ECPs are not added. ECPs are only removed from the list once they are no longer interested in participating, no longer operating, or no longer eligible as an ECP.
If an existing ECP is no longer providing specific services or has an ECP category change, MPMS will reflect that change via a separate list of newly available “write-ins” that will not affect the denominator of the issuer's ECP threshold calculations unless an issuer voluntarily chooses to contract with the respective provider and then the issuer will be credited for the contract.
The ECP reference data in MPMS is updated every two weeks.
There is no published MPMS ECP Reference Data list due to frequent changes that account for facility closures and ineligibility statuses; however, issuers and MPMS users can see all the available ECPs in their service area within the MPMS ECP user interface.

ECP Standards and Requirements

Q6: 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.

Q7: 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.

Q8: 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.

Q9: 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.

Q10: 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)

Q11: 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.

Q12: 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.

Q13: 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.

Q14: 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.

Q15: 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

Q16: 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.

Q17: We encountered an ECP error when validating on MPMS. The MPMS error indicates that an ECP we selected for our network does not correspond with an ECP on the CMS ECP List; however, we identified it on the Final Plan Year ECP List. Why are we getting this error and what should we do?

CMS conducts provider outreach throughout the year to update and revise provider data on the ECP List for the respective plan year. These revisions include updating provider contact information, modifying the types of health services displayed on the list as available at specific provider facilities, and removing provider practices that are no longer in business, no longer accepting plans purchased through an Exchange, or no longer eligible for inclusion on the ECP List.

Once CMS identifies a provider that no longer qualifies for inclusion on the ECP List for one of the reasons described above, that provider is removed from the ECP List so that issuers are not penalized for failure to contract with the ineligible provider. Sometimes these provider changes and removals occur after the release of the Final Plan Year ECP List that is posted at https://www.qhpcertification.cms.gov/s/Essential%20Community%20Providers. These provider updates ensure that the MPMS ECP Reference Data reflect a more dynamic and up-to-date version of the ECP List. If an issuer has already contracted with a provider that has recently lost its ECP eligibility (e.g., no longer located in a Health Professional Shortage Area, no longer eligible for the 340B program, etc.), the issuer may continue to include the provider in its provider network although the issuer will not receive credit for the provider toward satisfaction of the ECP standard.

If an issuer receives this MPMS error, the issuer can clear the error by simply removing the ineligible provider from the issuer's ECP User Interface in MPMS. The issuer can then focus on recruiting additional eligible ECPs to participate in its provider network toward satisfaction of the ECP standard. MPMS enables issuers to update their ECP information and resubmit repeatedly throughout the QHP application season. Issuers may continue to update their ECP information up until the final application deadline on August 14, 2024.