Plan Withdrawal FAQs

Q1What steps should an issuer take to submit a Plan Withdrawal Notification Form and where can this form be found?

  • Issuers and states wishing to withdraw on-Exchange QHPs and on- or off-Exchange SADPs from consideration for certification should submit a withdrawal form.

    Plan Withdrawal Notification Forms can be found in the PM Community. Issuers must submit the withdrawal form prior to the final issuer plan confirmation deadline for the upcoming plan year, following the steps outlined on the Plan Withdrawal page of the QHP certification website. Issuers should note if their state has state-specific withdrawal deadlines.

    For service area changes, please follow the instructions for updating the Service Area Template. For more information, please review the QHP certification website.
Q2: When can an issuer begin to submit withdrawal forms? When is the last day an issuer can submit a withdrawal form?
  • Issuers will have the ability to submit a withdrawal form via the Plan Management (PM) Community once the initial submission window opens until the last day of issuer final plan confirmation for the given plan year. While the form is active, any PM Community user designated for their parent organization can submit a withdrawal form using the steps outlined on the Plan Withdrawal page of the QHP certification website.

    For plan year (PY) 2023 plans, the withdrawal functionality in the PM Community is active between April 21, 2022 until August 24, 2022. Issuers should note if their state has state-specific withdrawal deadlines. 
Q3: Does an issuer need to submit a withdrawal form to indicate they will not be returning to the Exchange, or reoffering a plan?
  • If an issuer does not intend to return to the Exchange for PY2023, CMS does not require them to submit a withdrawal form. However, if an issuer submits plans for CMS to review by the initial submission deadline for the PY2023 QHP certification cycle, and later decides to remove any plans from review, the issuer will need to submit a withdrawal form for those plans.

    An issuer that does not intend to return to the Exchange for PY2023 may also need to update their Plan ID Crosswalk Template, as plans offered in PY2022 need to be crosswalked to plans offered in PY2023.

    CMS encourages issuers to notify their state if they do not intend to return to the Exchange.
Q4: Is an issuer required to submit a Plan Withdrawal Notification Form for off-Exchange only plans?
  • Issuers are required to submit a Plan Withdrawal Notification Form to withdraw any off-Exchange SADPs.

    Issuers can also use a withdrawal form to change the status of an SADP from both on- and off-Exchange to off-Exchange only.

    Issuers are not required to submit a withdrawal form to CMS to withdraw any off-Exchange QHPs, as these plans are not reviewed by CMS for certification. However, an issuer may need to notify their state if they intend to withdraw any off-Exchange QHPs from the state’s certification review.  
Q5: Do issuers submitting through the System for Electronic Rates & Forms Filing (SERFF) withdraw a plan from the CMS certification process differently from issuers submitting through the Health Insurance Oversight System (HIOS)?
  • No, issuers that submit plans through HIOS or SERFF will both need to submit a Plan Withdrawal Notification Form, located in the Plan Management (PM) Community, to withdraw a plan from CMS review.

    Issuers must submit the withdrawal form prior to the final issuer plan confirmation deadline for the upcoming plan year, following the steps outlined on the Plan Withdrawal page of the QHP certification website. Issuers should note if their state has state-specific withdrawal deadlines. 
Q6: What other forms and templates are affected by a plan withdrawal made during QHP Certification?
  • To reflect their plan withdrawal, issuers should update:

    • Unified Rate Review Template (URRT) to remove withdrawn plans, or change the value of the exchange plan field from “yes” to “no”; and
    • Plan ID Crosswalk Template if any of the withdrawn plans are included in the template. No previous year plans should be crosswalked to a withdrawn plan.
However, issuers should not:
    • remove plans from the Plans and Benefits Template or Rates Table Template, even if the plan is withdrawn using a withdrawal form; or
    • remove a Service Area ID from the Service Area Template, even if the withdrawn plan was the only plan covering that Service Area ID. 
Q7: How should an issuer update their Qualified Health Plan (QHP) Application when a plan withdrawal affects the issuer's service area? 
  • Some withdrawals change an issuer's covered service areas, though not all of these changes require updates to an issuer’s Service Area template or the submission of a Service Area Data Change Request (DCR).

    Withdrawing all plans in a service area does not require a Service Area DCR, regardless of when the withdrawal is submitted; the plan withdrawal itself is sufficient. The issuer should not update their Service Area template to remove the service area ID(s) of the withdrawn plan(s).

    However, if an issuer is changing the service area of one plan to cover the service area of another plan (e.g. to cover the service area of a withdrawn plan) the issuer does need to update their Service Area template and/or Plans and Benefits template.

    An issuer can revise the service area of another plan to cover the withdrawn plan's service area by:
    • updating the Plans and Benefits template to change the service area ID associated with the plans, OR
    • updating the Service Area Template to add the counties no longer covered, due to the plan withdrawal, to an existing service area ID,
Both of these actions require a Service Area DCR if made after the initial submission deadline. Visit the Timeline webpage of the QHP certification website to check when the initial submission deadline is for the current certification cycle.