Throughout the QHP Application validation and submission process, CMS releases review results to issuers to communicate validation errors and warnings as well as required corrections that issuers need to make to their applications.
CMS’s review results are categorized as pre-submission review results, or validation results, and post-submission review results, or required corrections.
Pre-Submission Review Results:
Issuers receive pre-submission review results by validating application data in the Plan Validation Workspace, interacting with SERFF Validate & Transform, or by cross validating application data in either the Plan Validation Workspace or the MPMS Module. There are two types of pre-submission review results:
- Validation Errors: These identify data integrity and other data errors present in issuers’ applications. Issuers are required to correct all validation errors prior to submitting an application.
- Validation Warnings: These identify potential issues present in issuers’ applications, including those related to data integrity or the submission of supporting documents and justifications.
Post-Submission Review Results:
Issuers receive post-submission review results after CMS receives one or more components of an issuer’s QHP Application and reviews that data for compliance with one or more federal standards. Once CMS completes these reviews, these results are shared in either the MPMS Module or the PM Community; these review results reflect required corrections to issuers’ applications.
- For required corrections released before the final QHP Application submission deadline: Issuers should make needed corrections to their applications and submit their updated data to CMS as soon as possible, but by no later than the deadlines specified in the QHP Data Submission and Certification Timeline bulletin. For some review areas, CMS will re-review data resubmitted and release additional review results prior to the final deadline.
- For required corrections released after the final QHP Application submission deadline: Issuers should review the corrections and follow instructions from CMS to make corrections and submit updated data, if needed.
Note: For review areas for which results are shared in MPMS, individual application groups will be locked (i.e., not able to be edited) while CMS conducts reviews on the submitted data. Issuers will receive review results as CMS completes reviews for each application review area. Issuers will not be able to make edits to any sections within a group until CMS completes all applicable reviews related to sections within that group. As CMS completes reviews, the relevant application groups will display one of the following statuses:
- Corrections Required: CMS has completed the review of one or more review areas affected by this group and there are corrections needed for at least one of the completed review areas.
- No Action Required: CMS has completed the review of all review areas affected by this group and there are no corrections needed for the completed review areas.
Please note: The Plan Attributes group is an exception to this requirement. If the Network Adequacy review has not yet been completed and CMS has completed all other reviews in the Plan Attributes group, the group will display a status of Corrections Required or No Action Required depending on CMS’s reviews of the other five sections within the Plan Attributes group. Issuers will be able to edit the other five sections within the Plan Attributes group at that time.
Please be advised that CMS’s review is limited to compliance with QHP/SADP certification standards and does not constitute or imply a determination of the QHP Application’s compliance with requirements under state law. Issuers should consult with the applicable state(s) (and CMS in states that do not enforce market-wide requirements) regarding the requirements and processes for any rate or product reviews.
Ensure You Receive Communications from CMS Regarding Your QHP Application
To ensure receipt of communications regarding QHP certification, issuers
should manage their contacts within the Organizations tab of the PM
Community. For more information on maintaining contacts for your
organization, visit the
Register for Updates webpage.
Please
note: Notifications regarding review results’ availability in the MPMS
Module will be sent to all points of contact with a PM Issuer Submitter
role for a given issuer ID.
Review Results by Exchange Type & System
This table indicates which review areas issuers in each state Exchange
type can expect to receive review results for, and the system in which
they will receive these results. Issuers and states will also receive
email notifications when one or more reviews have been completed and
results have been made available. Issuers and states can also refer to
the
Review Role by State Exchange Model (
Updated 5/17/24) for more information on each review, including guidance on whether CMS
or the state is primarily responsible for reviewing applicable QHP
Application data to ensure its compliance with certification standards.
Review Area | Affected Exchange
Models | Validation Results in
MPMS Module | Required Corrections
in MPMS Module | Required Corrections
in PM Community |
Accreditation | FFE | Y | Y | |
Administrative | FFE, state performing plan
management functions, SBE-FP | Y | | |
Adverse Tiering | FFE, state performing plan management functions | | | Y |
Cost Sharing Reduction (CSR) - Plan
Variation | FFE, state performing plan
management functions | Y | | |
Data Integrity | FFE, state performing plan management
functions, SBE-FP | Y | |
|
Dental Maximum Out of Pocket (MOOP) | FFE | Y | | |
Essential Community Providers | FFE | Y | Y | |
Interoperability | FFE, state performing plan
management functions | Y | Y | |
Machine-Readable Index URLs | FFE, state performing
plan management functions, SBE-FP | Y | | Y |
Network Adequacy | FFE, state performing
plan management functions | Y | Y | |
Non-Discrimination (Clinical Appropriateness) | FFE, state performing plan
management functions | Y | Y | |
Non-Discrimination (Cost-Sharing) | FFE | | | Y |
Non-Discrimination (Formulary
Outlier) | FFE, state performing plan
management functions | | | Y |
Non-Discrimination (Treatment
Protocol Calculator) | FFE | | | Y |
Non-Standardized Plan Options | FFE, state performing plan
management functions, SBE-FP | Y | Y | |
Plan ID Crosswalk | FFE, state performing plan
management functions, SBE-FP | Y | Y | |
Plan Marketing Name | FFE, state performing plan management
functions, SBE-FP | | | Y |
Program Attestations | FFE | Y | | |
Quality Improvement Strategy (QIS) | FFE, state performing plan
management functions | | | Y |
Quality Rating Strategy (QRS) | FFE, state performing plan
management functions | | | Y |
SADP EHB Benchmark | FFE | Y | Y | |
Service Area (Including Partial
County) | FFE | Y | Y | |
Silver/Gold | FFE | Y | | |
Standardized Plan Options | FFE, state performing plan
management functions, SBE-FP | Y | | |
Transparency in Coverage | FFE, state performing plan
management functions, SBE-FP | Y | Y | |
URL | FFE, state performing plan
management functions, SBE-FP | Y | | Y |