QHP Agreement and Plan Confirmation

As part of the QHP certification process, issuers must complete plan confirmation to submit their final plan offering decisions to CMS. On the first day of the plan confirmation window specified in the QHP Data Submission and Certification Timeline bulletin, CMS will notify issuers that their plans have been loaded into the Plan Management (PM) Community, and will provide instructions on completing plan confirmation; issuers should review the list of plans and confirm which plans should be made available through the Exchange. Issuer plan confirmation is the final opportunity for issuers to notify CMS of plan withdrawals. 

Issuers offering QHPs or stand-alone dental plans (SADPs) in the Federally-facilitated Exchanges (FFEs), including issuers in states performing plan management functions, must sign and submit a QHP Certification Agreement and Privacy and Security Agreement (the QHP Certification Agreement) and a Senior Officer Acknowledgement. Off-Exchange only SADP issuers do not sign the QHP Certification Agreement.

• The QHP Certification Agreement includes provisions for safeguarding plan and participant privacy and standards for issuer testing before Open Enrollment starts. The agreement must be signed by an officer of the legal entity who has legal authority to contractually bind the issuer.
• The Senior Officer Acknowledgment confirms that a senior officer of the issuer has knowledge of the content of the issuer’s plans, as well as the content of the completed attestations and the Letter to Issuers.
• When executing these documents, issuers should use the same legal entity information listed in the Health Insurance Oversight System (HIOS) under the Issuer General Information section.

Once CMS receives an accurate and complete QHP Certification Agreement and Senior Officer Acknowledgment, as indicated in the Letter to Issuers, CMS will send Certification Notices to issuers at the conclusion of the QHP Application certification process. These notices contain the final list of certified QHPs, as well as a CMS-countersigned QHP Agreement. The documents will apply to all QHPs offered by a single issuer in an FFE at the HIOS Issuer ID level or designee company. Receipt of a QHP Certification Agreement with CMS signature and final validated plan list completes the certification process for the upcoming plan year.

CMS reserves the right to identify and communicate corrections prior to and after certification based on the original QHP Application and any changes made to the application, or if CMS determines that any of the submitted information is inaccurate.

CMS will not return the Senior Officer Acknowledgement.