Interoperability FAQs

Q1: Where can issuers find the Interoperability Justification Form?

The Interoperability Justification Form can be found on the Interoperability webpage of the QHP certification website. Issuers that respond “No” to any of the four Interoperability questions in the Marketplace Plan Management System (MPMS) Module must complete the Interoperability Justification Form in its entirety and upload it through the MPMS Module. Please refer to the Qualified Health Plan Issuer Instructions, Section 2B: Interoperability, for detailed instructions about how to upload the Interoperability Justification Form. The Interoperability Justification Form asks the issuer for:

The reasons why the issuer cannot reasonably satisfy all the 42 CFR 156.221 requirements for the 2025 plan year (the root cause).
The impact of non-compliance upon issuer’s enrollees.
The current or proposed means of providing the required 42 CFR 156.221 health information to issuer’s enrollees.
Issuer’s solutions and a timeline to achieve compliance with all the 42 CFR 156.221 requirements.

Q2: How many URLs do I submit for Interoperability?

Starting in PY2025, issuers are strongly encouraged to submit only one URL for Question 3 and one URL for Question 4. Issuers should check that the URLs are live and active at the time of submission. There can be no preconditions or additional steps to access the URLs, such as requirements to sign in, register, or create an account.

Q3: Where can I find the link to submit a complaint to the FTC?

The active link for consumers to file a complaint with the FTC is https://reportfraud.ftc.gov/#/assistant. It can also be found within Patient Privacy and Security Resources. To lodge a complaint with the FTC about a mobile app’s breach of privacy or security, the consumer should select the “Something else” category and then describe the privacy and security breach.

Q4: How do I view my Interoperability required corrections in the Marketplace Plan Management System (MPMS) Module?

If you have required corrections (review results) associated with Interoperability, the Issuer Attestations and Administrative Information group (within which Interoperability is one of the sections) will display a status of "Corrections Required." To view the list of corrections, click on "View CMS Feedback."

If you have no required corrections associated with Interoperability, the Issuer Attestations and Administrative Information group will display a status of "No Action Required."