Program Attestations

To show compliance with FFE standards and program requirements, all issuers and their affiliates are required to submit responses to program attestations as part of their QHP Application.

Key Changes for PY2022:
  • If you are applying to issue Medical QHPs, you must submit an Interoperability Attestation and Justification Form indicating that you meet the requirements of the Centers for Medicare & Medicaid Services (CMS) Interoperability & Patient Access Final Rule. If you cannot meet the requirements, you are required to include a narrative justification in the form. This requirement does not apply for SADP-only, FF-SHOP, or SBE-FP issuers. 

Tips for the Program Attestations Section

  • You must respond to all attestation subsections.
  • If you only issue Medical QHPs, respond Not Applicable to the Attestations required in the SADP-only issuers subsection. 
  • If you only issue SADPs, respond Not Applicable to the Attestations required in the Medical QHP-only issuers subsection.
  • CMS strongly encourages you to respond Yes to the optional compliance plan attestation and upload a compliance plan that includes the Compliance Plan and Organizational Chart Cover Sheet. If you respond No to the optional compliance plan attestation, you must upload a justification form. 
  • You must upload supporting documents for your responses to the attestations.
  • Use the justification form only if you are submitting plans to the FFE using HIOS.
  • Use the State Partnership Exchange Issuer Program Attestation Response Form only if your state performs plan management functions.
  • If you issue Medical QHPs in the FFE or in a state that performs plan management functions, you must complete the Interoperability Attestation and Justification Form. If you do not attest to meeting all requirements by July 1, 2021, you must provide a narrative justification. If you did not offer plans on the Exchange in PY2021, you have until January 1, 2022, to implement these requirements. Visit the Interoperability webpage for more information.

Application Resources