Marketplace Plan Management System (MPMS) FAQs

States, Exchanges, and Issuer Type

Q1: Do SADP issuers use MPMS?

  • Yes, both SADP and QHP issuers will use the MPMS Module.

    SADP issuers will no longer be required to submit the Actuarial Value (AV) or Essential Health Benefit (EHB) Apportionment forms. Instead of submitting these completed forms, SADP issuers will attest to meeting EHB Allocation and AV requirements when they agree to comply with the attestation required of SADP issuers. 
Q2: Where do issuers in SERFF states submit their application?
  • Issuers should submit their QHP Application(s) through SERFF if they reside in states performing plan management functions and in State-based Exchanges on the Federal Platform (SBE-FPs). An issuer in these states should submit QHP data through SERFF and the state will transfer the application data to HIOS. However, there is some information which must be entered in the MPMS Module, regardless of Exchange model, including interoperability, ECP, NA, NSPOLE justification, Plan ID Crosswalk, and URL data.

    SERFF issuers are required to use the Plan Validation Workspace in the MPMS Module to validate templates prior to submission of templates to SERFF. The Plan Validation Workspace will identify errors and allow the issuer to correct data prior to SERFF submission, as well as allow the issuer to perform cross validations on their data. While SERFF Validate & Transform does not identify warnings, the Plan Validation Workspace does provide feedback to issuers regarding data issues that will not prevent submission, but that may need additional attention from issuers to resolve. 

    Issuers should contact their state for additional application requirements. Additional instructions for HIOS vs SERFF users is included in the MPMS User Guide which is available on the Submission Systems webpage of the QHP certification website. 
Q3: If an issuer submits via SERFF and intends to offer Individual plans on/off-Exchange and Small Group plans that are off-Exchange, what information should be submitted in SERFF? What validations will occur during SERFF Validate & Transform?
  • Issuers who intend to offer Individual plans both on/off-Exchange and Small Group plans that are off-Exchange, should upload the respective binders in SERFF to allow for state review. During SERFF Validate & Transform, applicable errors will be returned for on-Exchange QHPs or SADPs. Validations will not be run for off-Exchange-only medical QHPs. Issuers are encouraged to use the Plan Validation Workspace within the MPMS Module to validate their templates prior to transmitting their templates through SERFF.
Q4: Should issuers with off-Exchange-only plans be using the MPMS Module to validate their templates?
  • For certification purposes, CMS does not review data for a QHP that is categorized as “Off the Exchange” in the Plans & Benefits Template. As such, use of the MPMS Plan Validation Workspace is optional for issuers with off-Exchange-only QHP data. The Plan Validation Workspace will run only a limited set of validations that would be applied to off-Exchange-only QHPs, to ensure that data entered for these plans is in the correct format and conforms with template technical requirements. The MPMS Module will not prevent submission of a template containing off-Exchange QHP data as long as the data do not generate any validation errors or cross validation errors.

    CMS does review data for an SADP that is categorized as “Off the Exchange” in the Plans & Benefits Template, for SADP issuers that elect to submit off-Exchange SADPs for CMS certification. SADP issuers who submit off-Exchange SADP data to CMS must use the MPMS Plan Validation Workspace, before submitting these data to CMS through either the MPMS Module or SERFF.
Q5: Is the Plan Validation Workspace required for SBEs?
  • For issuers in State Based Exchanges that use the federal platform for eligibility and enrollment (SBE-FP), use of the Plan Validation Workspace is required to ensure that QHP Application template data are validated and hence eligible for successful SERFF transfer to CMS. Note that the presence of any template-specific error will result in unsuccessful SERFF transfer of template data from an issuer to a state. Additionally, the presence of any cross-template error will result in unsuccessful SERFF transfer of template data from the SBE-FP state to CMS.

    For issuers in a State Based Exchange (SBE) that uses a State-based platform for eligibility and enrollment, use of the Plan Validation Workspace is optional. Note that not all validations performed by the Plan Validation Workspace would be applied to an SBE issuer.

Review Results and Post-Submission

Q1: Will CMS notify issuers when reviews are completed in the MPMS Module and corrections are required?

  • Yes, users associated with a QHP Application, including those with the PM Issuer Submitter role, will receive an email alerting them that there are new review results available. The turnaround time will vary by review and group, but CMS will be returning results as quickly as possible to allow issuers to have time for correction and resubmission.

    For PY2025, a subset of review areas will have results available in the MPMS Module. The review results for the remaining review areas will continue to be disseminated via the Plan Management (PM) Community. Information regarding which results are released where, is available on the Review Results webpage of the QHP certification website.
Q2: Where will URLs and interoperability data be submitted?
  • URLs will be submitted in the Issuer URLs group of the QHP Application, while interoperability data will be submitted in the Issuer Attestations and Administrative Information group within the QHP Application of the MPMS Module.
Q3: Can I make changes to my application after I submit one or all application groups?
  • Yes, however, CMS recommends users make changes before submitting an application group. If a user would like to make additional changes, or is not ready to submit, a user may select the ‘Close’ or ‘No, continue editing’ button as applicable in the confirmation pop-up window.

    After a user selects the ‘Yes, submit this group’ button, revisions can only be made after the results are returned. Once the review results have been returned and the group is unlocked, the issuer can link an updated template to the section and resubmit the group for review. Validation remains accessible in the Plan Validation Workspace to perform template checks during this time, should there be any changes identified after the application group is submitted and is still under review. 

QHP Application Submission and Template Linking

Q1: Will the copy/paste function be available in MPMS?

  • Copying and pasting is only applicable to the templates, which are still required in MPMS. As in prior years, CMS recommends against copying/pasting from prior year templates into current year’s templates, since fields may have changed from one year to the next in any given template.
Q2: Can I upload the multiple supporting documents and/or justifications at once to MPMS?
  • Currently MPMS only supports the upload of one supporting document at a time.
Q3: Is there a size limitation to the files that can uploaded in the MPMS Module?
  • The size limitation for files that can be uploaded in MPMS is 650 megabytes.

    The workspace will not support the upload of a ZIP file that includes multiple template XMLs. The Plan Validation Workspace will only support the upload of a ZIP file for the Network Adequacy (NA) Template.
Q4: How do issuers submit the QHP application?
  • A QHP Application can be submitted in the MPMS Module once all supporting templates, attestations and justifications have been completed, and applicable sections are in a status of “Ready to Submit.” At this point, issuers will need to click “Submit Group” for each applicable group. The “Submit Group” button will only submit the sections for that specific group and all sections in that group are submitted simultaneously. A pop-up window will appear notifying the issuer what happens when an application group is submitted.

    A QHP Application is considered complete when all applicable groups have been submitted without error, and indicate a status of “Submitted – Under Review,” “Corrections Required,” or “No Action Required.
Q5: What is the difference between a section of the QHP Application and an application group?
  • Sections are where issuers will link individual templates, upload supporting documents, enter data such as ECPs or URLs, and respond to attestations. Sections that may have related requirements are then grouped into application groups. 

    Sections are grouped in the following application groups:

    • Issuer Attestation and Administration Information:
      • Administrative
      • Interoperability
      • Program Attestations
    • Plan Business Rules:
      • Business Rules
    • Plan Attributes:
      • Plans & Benefits
      • Prescription Drugs
      • Service Area
      • Network ID
      • Essential Community Providers
      • Network Adequacy 
    • Plan Crosswalk
      • Plan ID Crosswalk
    • Issuer Accreditation:
      • Accreditation
    • Transparency Data:
      • Transparency in Coverage
    • Plan Rates:
      • Rates Table
    • Issuer URLs:
      • URL
Q6: Where do issuers submit their Plan ID Crosswalk Template?
  • Beginning in PY2025, issuers will submit Plan ID Crosswalk data via the Plan ID Crosswalk section in the new Plan Crosswalk application group in the HIOS MPMS Module. Issuers will upload the Plan ID Crosswalk Template to the MPMS Plan Validation Workspace, where they will validate and link the template to their QHP Application. Within the new Plan ID Crosswalk application section, issuers must then run cross validation checks and provide any necessary justifications and evidence of state authorization before submitting. Issuers who are not returning to the Exchange no longer submit a Plan ID Crosswalk Template.
Q7: Why can’t I link my template(s) to my application?
  • Only templates without errors can be linked to your application. You will need to change your templates to resolve all errors before being able to link the template(s) to your application.

    If your template has only warnings, the template may be linked to your application. Depending on the warning received, you may be required to submit a justification which would then "clear the warning" and enable you to submit the group for CMS review. Users will upload these documents in the QHP Applications section of MPMS.
Q8: Why am I not seeing the Accreditation section?
  • Only issuers offering medical QHPs are required to be accredited. MPMS was designed to only display the sections relevant to the product offerings of each issuer.
Q9: Why am I not seeing all the attestations?
  • Only those attestations relevant to the product offerings are displayed.
Q10: What document type should I select if I need to submit information regarding my upcoming accreditation survey? I only see “Accreditation Certificate” and “Quality Improvement Strategy (QIS).”
  • Issuers should select the “Accreditation Certificate” as the document type.
Q11: Where do issuers submit interoperability data?
  • For FFE issuers and issuers in states performing plan management functions, CMS will collect all interoperability data (issuers' responses to the 4 interoperability questions, URLs, and the interoperability Justification Form as needed) in the Marketplace Plan Management System (MPMS) Module.
Q12: What should an issuer do if they created a new application but realize the template in the Plan Validation Workspace needs to be replaced by another revised/updated template? 
  • To replace a template, return to the Plan Validation Workspace, upload the correct template, and validate for errors. Return to the application and link that correct template from the Workspace.

    Once a new template has been uploaded and validated in the Plan Validation Workspace, only the validation results from the new template will be visible. Only one version of the template is stored in the Plan Validation Workspace, prior versions will be over-written.
Q13:What are allowable special characters for URLs that are submitted to CMS?
  • The special characters listed below are allowed in URLs that are submitted to CMS. The Marketplace Plan Management System (MPMS) will flag as validation errors the entry of other special characters within a URL.

    ~ (tilde)
    ` (grave)
    ! (exclamation mark)
    # (pound)
    @ (At Sign)
    $ (Dollar)
    % (percentage)
    ^ (carat)
    & (ampersand)
    * (asterisk)
    ( (open parenthesis)
    ) (closed parenthesis)
    _ (underscore)
    + (addition)
    - (hyphen or minus)
    = (equals)
    [ (open bracket)
    ] (closed bracket)
    \ (backslash)
    { } (open and closed braces)
    ; (semicolon)
    : (colon)
    " (quotation mark)
    . (period)
    / (forward slash)
    ? (question mark)
Q14:If an issuer is applying to offer Individual Market plans both on and off the Exchange, but only offers Small Group plans off the Exchange, when creating an application, what Market Coverage Type should be selected?
  • In this scenario, when an issuer creates its application, it should select the Market Coverage Type to be "Individual & SHOP."

Plan Validation Workspace

Q1: Will previous years’ submissions still be available in HIOS as a reference?

  • Yes, PY2024 QHP Application submissions will continue to be available in the MPMS Module.
Q2: If an issuer’s template has a mix of both off-Exchange-only plans and plans offered both on and off the Exchange, will the Plan Validation Workspace validations still work appropriately? Or do issuers need to use the review tools instead?
  • Yes, issuers can include off-Exchange-only plans in the template; the validation checks in the Plan Validation Workspace will work appropriately for all applicable plans in a given Exchange model and for a given market type.

    Issuers are welcome to use the Excel-based review tools to identify and resolve errors prior to using the Plan Validation Workspace, but it is not necessary to do so. The Plan Validation Workspace will identify all applicable validation errors and warnings.

    For off-Exchange-only data, issuers may elect to use the Data Integrity Tool (DIT), which has functionality to run checks for off-Exchange-only plans. The Plan Validation Workspace will not return validation results for medical off-Exchange-only plans, but can be used to validate off-Exchange-only dental plans.
Q3: Do the MPMS submission requirements apply to templates submitted in Rates & Benefit Information Systems (RBIS) or only for those requiring CMS certification for display on the Exchange?
  • MPMS submission requirements do not apply to templates that are submitted to RBIS.  
Q4: In reference to the Warnings Found badge, can CMS explain what is meant by an “unexpected data condition?”
  • An unexpected data condition is a scenario where the data submitted in one or more templates does not match what CMS would expect to see. As an example, if rates were submitted in the Rates Table Template for a plan ID that does not exist in the Plans & Benefits Template, then an "unexpected data condition" will be assigned.
Q5: What is the validation process? 
  • The Plan Validation Workspace within the MPMS Module performs automated validations that are traditionally associated with review tools such as the Data Integrity and Cost-sharing Reduction (CSR) Tools (note there will be differences in wording/format between the Plan Validation Workspace and tool results). CMS will continue to perform QHP certification reviews based on QHP Application submission (i.e., post-submission to CMS). SERFF-submitting issuers are expected to use the Plan Validation Workspace to validate their data prior to submitting their templates through SERFF.

    • Instructions for how to get access to the MPMS Module, as well as a User Guide for using the MPMS Module, is available on the Submission Systems webpage of the QHP certification website. 
Q6: If an issuer disagrees with a validation error generated from the Plan Validation Workspace, how does the issuer communicate the discrepancy to CMS?
  • If issuers have an inquiry on the Plan Validation Workspace results, to include disagreement with a result, CMS encourages issuers to submit a help desk ticket for further CMS review. Within the ticket, please attach and identify the specific result(s) within the Plan Validation Workspace output on which there are questions and attach the relevant template(s) that trigger the result(s). CMS will review the information and respond to the issuer.
Q7: Can you please clarify if the Plans & Benefits Template is a required template when running cross validation?
  • Yes, an error-free Plans & Benefits Template must be uploaded in the Plan Validation Workspace in order to run applicable cross validations within MPMS.
Q8: Do the Data Integrity Tool and Data Consolidation Tool (formerly referred to as the "Master Review Tool") need to be run in addition to running validations in the Plan Validation Workspace?
  • All issuers seeking QHP certification on the Exchange should use the Plan Validation Workspace prior to submitting an application. As in past years, CMS will continue to provide QHP Application Review Tools, including the Data Integrity Tool and Data Consolidation Tool (formerly referred to as the "Master Review Tool"), as an optional resource. The review tools may be used to support pre-validation data checks.
Q9: Do issuers have to have all templates uploaded in the Plan Validation Workspace to run validations? Or can issuers upload a handful of templates, like Plans & Benefits, Service Area, and Transparency in Coverage Templates, and run the check?
  • It is possible to upload templates one at a time and still receive validation results. However, cross validations are only able to run when multiple error-free templates are available.
Q10: Will Plan Preview be available for PY2025 plans?
  • Plan Preview for PY2025 will be available in the MPMS Module. More information may be found on the Plan Preview webpage of the QHP certification website.
Q11: Does this validation process replace CMS’s validation tools, such as the Data Integrity Tool, which issuers used to run before submitting the templates?
  • Beginning in PY2024, issuers are required to use the Plan Validation Workspace to upload QHP Application templates for validation. Similar to CMS’s review tools, the Plan Validation Workspace allows issuers to receive validation results at any time prior to the submission of a QHP Application.  Issuers may continue to use CMS’s review tools to complement the Plan Validation Workspace and further ensure compliance with certification standards.
Q12: Will MPMS check for consistent benefit and cost sharing information between the Plans & Benefits Template and SBC URLs?
  • The Plan Validation Workspace will perform cross validations between templates. However, the system will not check for consistency between benefit and cost sharing information in the Plans & Benefits Template and what is contained in SBC URLs upon linking of the template or upload of the URL. These consistency checks will continue to be performed once data is submitted by the issuer, and these results will be returned to issuers.
Q13: What is the difference between plan validation and cross validation? 
  • Plan validation, or template validation, is the first step in which a user-uploaded template is processed for potential template errors. Plan validation will provide validation results that describe if warnings or errors were found on the specific template. The results are found in the Validation Results section.

    Cross validation is the second step in which the MPMS Module processes validated templates from the first step (user-uploaded templates with no template errors) with other validated templates. Results from the cross validation are displayed in the Cross Validation Checks section.
Q14: Why do issuers keep getting a processing error?
  • This issue could be caused by a problem with the generated XML. To address this issue, regenerate and reload the XML file into the Plan Validation Workspace. If the issue persists, contact the Marketplace Service Desk (MSD) at CMS_FEPS@cms.hhs.gov or 1-855-CMS-1515 (1-855-267-1515) for further assistance.
Q15: How can issuers request guidance on using the Plan Validation Workspace?
  • Issuers that have questions regarding the use of the Plan Validation Workspace should submit a Help Desk ticket to the MSD at CMS_FEPS@cms.hhs.gov.

    For questions regarding specific validation errors or warnings, issuers should submit Help Desk tickets and include “Validation Result Inquiry” in the subject line. CMS requests issuers attach an exported validation result file and highlight the specific validation result row(s) that the issuer is seeking guidance on; validation result export files may be downloaded from the Plan Validation Workspace. Issuers should also attach the relevant QHP Application template(s) in Excel format that are associated with the highlighted result row(s); the attached template(s) should not be in XML format.

    For questions regarding technical and system issues within the MPMS Module, including the Plan Validation Workspace, issuers should include “MPMS Technical Inquiry” in the subject line of the submitted help desk ticket. CMS requests issuers attach screenshots of technical issues they are experiencing within the system, if possible.

    For additional guidance on navigating the Plan Validation Workspace, reference the MPMS Module User Guide.
Q16: I am a SERFF-submitting issuer. When cross-validating my QHP Application templates within the Plan Validation Workspace, why may I encounter false-positive error or warning results within the Workspace?
  • SERFF-submitting issuers may experience false positive errors when attempting to cross validate their QHP Application templates. While users are able to upload up to four Plans and Benefits templates in the Workspace (one for each Market and/or Product type), only one version of another template type can be loaded into the Workspace. MPMS may generate false positive cross-validation results because the system is unable to cross-validate data against any non-uploaded QHP Application template, whose data for Market and/or Product Type corresponds with a subset of an issuer’s uploaded Plans & Benefits templates.

    For example, a SERFF-submitting QHP issuer who offers plans in both the individual and SHOP markets may upload into the Workspace two versions of the Plans & Benefits template that are specific to each market but only one version of the Service Area template that is specific to only one market. If the issuer creates two Service Area templates that are specific to each market, then MPMS is unable to cross-validate data against the non-uploaded Service Area template and will generate false positive cross-validation errors when comparing data between the uploaded Service Area template (whose data is specific to just one market) against an uploaded Plans & Benefits template whose data corresponds to a different market.

    Please note that these false positive cross-validation results as displayed in the Workspace will not be a submission blocker when your state transfers the plans from your SERFF binders to CMS. SERFF will only cross-validate data among the QHP Application templates that are contained within a SERFF binder.
Q17:What are allowable special characters within the “free text” fields of the Plans & Benefits Template, such as Plan Marketing Name and Plan Variant Marketing Name?
  • The special characters listed below are allowed within the free text fields of the Plans & Benefits Template for purposes of submitting the template to CMS. The Marketplace Plan Management System (MPMS) will flag as validation errors the entry of other special characters within the template.

    ( ) parenthesis
    - hyphen
    – 'en' dash
    , comma
    . period
    / slash
    : colon
    & ampersand
    $ dollar sign
    ; semicolon
    ' apostrophe or single quote
    % percentage
    + addition sign
    "" double quotation marks
    @ at sign
    ! exclamation point
    _ underscore
    = equal sign
    less than/greater than sign
    \ backslash
    # hashtag
    [ ] square bracket
    '|' vertical bar
    ©
    ®
    ™
    ℠
    space
Q18: Will the MPMS Module impact the rates submission process?
  • The MPMS Module will not affect how QHP issuers submit the Unified Rate Review Template (URRT) to CMS.

    The MPMS Module will affect how issuers validate and submit the Rates Table Template to CMS. For issuers in FFE states, issuers must validate and submit the Rates Table Template through the MPMS Module. After linking a validated Rates Table Template to the Plan Rates group within MPMS, an issuer must also ensure that their Unified Rate Review Template (URRT) is submitted to CMS by the time the issuer attempts to submit the Plan Rates group through MPMS. If there are any cross validation errors between the Rates Table Template and URRT (or if the URRT is not yet submitted), the issuer will be unable to submit the Plan Rates group until these errors are resolved.

    Issuers in states performing plan management functions and issuers in SBE-FP states must validate the Rates Table Template through the Plan Validation Workspace, prior to submitting and transferring the template through SERFF. Note that SERFF Validate & Transform will also conduct MPMS error validations, and that the presence of any error would prevent successful submission of the template to the state. Additionally, issuers in these states must also ensure that their URRT is submitted to CMS, and should monitor when both the Rates Table Template and URRT are submitted to CMS.

Registration and System Access

Q1: Is access to the MPMS Module limited to a specific number of people (same ones who have access to the PM Community today)?

  • There are no limitations to the number of users that can access the MPMS Module. However, each user must request access to the MPMS Module through the Health Insurance Oversight System (HIOS). 

    It is up to issuers to determine how many users there are, within an organization, with access to the MPMS Module, as well as the level of access each user should have. The MPMS Module now offers four (4) user roles for issuers to select from:

         1. PM Issuer Viewer (New) - Grants user access to use Plan Preview, but read-only access to the rest       of the MPMS Module

         2. PM Network Validator (New) - Grants user access to the Plan Validation Workspace, Plan Preview,         and edit access to the Network ID, Essential Community Providers (ECP), and Network Adequacy             sections in the QHP application. User will have read-only access to the rest of the QHP application, as       well as to other areas of the MPMS Module

         3. PM Issuer Validator (New) - Grants user full access to the Plan Validation Workspace and Plan               Preview, but read-only access to other areas of the MPMS Module

         4. PM Issuer Submitter (Existing) – Grants the user full read/write access to all areas of the MPMS             Module

    Each user may only have one (1) of the above user roles per HIOS Issuer ID. Should a user need to change their access, they may remove their existing role in HIOS and request the new role. 

    Issuers will still use the PM Community to conduct several QHP certification activities and to display a subset of review results. The two systems are not directly connected at this time; however the MPMS Module does provide a link to the PM Community, if needed.

Q2: Will state regulators need access to HIOS? 
  • Yes, state regulators must obtain access to HIOS in order to access the MPMS Module and view submissions for issuers in their state. State regulators will need to request the "PM State Reviewer" role.
Q3: What should issuers do if they have referenced the Troubleshooting & Support section of the MPMS User Guide but still need assistance?
  • If issuers have taken the recommended corrective actions listed in the MPMS User Guide and issues remain unresolved, contact the Marketplace Service Desk (MSD) at CMS_FEPS@cms.hhs.gov or 1-855-CMS-1515 (1-855-267-1515).