Filing Guideline for Plan Year 2026 ACA Forms and Rates
Tennessee is a Federally Facilitated Marketplace (FFM) without an Effective Rate Review Program, carriers must follow the timeline set out by CMS:
PY2026 QHP Data Submission and Certification Timeline
| Activity | Dates |
|---|---|
| QHP Application submission and data validation window opens | 4/16/25 |
| CMS reviews QHP Application data as it is submitted and releases results for issuers and states to review | 4/16/25 – 6/6/25 |
| HHS-approved QHP Enrollee Survey vendor securely submits the QHP Enrollee Survey response data to CMS on behalf of the QHP issuer | 5/16/25 |
| Rate justifications are required to be submitted to CMS in states without an effective rate review program. (This includes Tennessee) | 6/2/2025 |
TDCI Form Filing and Binder Submission Deadline |
6/11/25 |
| Initial Application Deadline: Initial deadline for issuers to submit QHP Applications to CMS, including Plan ID Crosswalk data | 6/11/25 |
| CMS reviews initial QHP Applications and releases results for issuers andstates to review | 6/12/25 – 7/11/25 |
| QHP issuer submits the validated Quality Rating System (QRS) clinical measure data, with attestation, to CMS via NCQA’s Interactive DataS ubmission System (IDSS) | 6/13/25 |
| Secondary Application Deadline: Deadline for issuers to submit their QHP Application Rates Table Templates to CMS; optional deadline for issuers to submit corrected QHP Application data to CMS | 7/16/25 |
| CMS reviews Rates Table Template data and resubmitted QHP Application data, and releases results for issuers and states to review | 7/17/25 – 8/8/25 |
| Issuers, Exchange administrators, and CMS preview the 2025 QHP quality rating information | Aug./Sep. 2025 |
| Issuer Plan Confirmation/Crosswalk Deadline: Issuers complete final planc onfirmation and submit final Plan ID Crosswalk Templates | 8/6/25 – 8/20/25 |
| Final Application Deadline: Deadline for issuers to submit changes to their QHP Applications | 8/13/25 |
| CMS reviews QHP Applications and releases results for issuers and states to review | 8/14/25 – 9/8/25 |
| CMS sends QHP Certification Agreements to issuers | 9/9/25 |
| QHP Agreement Signing Deadline: Issuers return signed QHP Certification Agreements to CMS | 9/9/25 – 9/17/25 |
| State Plan Confirmation Deadline: States complete final plan confirmation | 9/9/25 – 9/17/25 |
| Limited data correction window | 9/11/25 – 9/12/25 |
| Machine-Readable/URL Deadline: Deadline for issuers’ machine-readable data to be posted and marketing URLs to be live and active. | 9/17/25 |
| CMS releases certification notices to issuers and states | 9/30/25 –10/1/25 |
| Anticipated public display of QHP quality rating information | 11/1/25 |
| Open Enrollment begins | 11/1/25 |
Important!!!!
Please see the following link to find rate filing instructions from CMS. Note that Tennessee is a state without an effective rate review program as defined by CMS. Two rate filings will be required for both individual and small group carriers. The instructions indicate what must be included with each filing.
Insurance Standards Bulletin Series
Templates
CMS will post the relevant and required PY26 templates including:
- Business Rules Template
- Network Adequacy Template
- Network ID Template
- Plan ID Crosswalk Template
- Plans & Benefits Add-In
- Plans & Benefits Template
- Prescription Drug Template
- Rates Table Template
- Service Area Template
- Standardized Plan Options Add-In
- Transparency in Coverage Template
Filing Instructions:
- All filings to the State should be made via SERFF.
- Individual and small group filings may not be combined.
- TWO SEPARATE RATE FILINGS ARE REQUIRED within SERFF
- See the relevant bulletin posted from CMS.
- Silver loading for CSRs must be included and limited to Marketplace QHPs.
- Each plan variation, such as copay versus coinsurance, deductible only, or open or closed networks must have a separate schedule page, rates, actuarial memorandum, and actuarial value calculation.
- Each variation does not require a separate filing but may be combined with the appropriate policy or certificate of coverage.
- There may be no language variations in the schedules but the deductibles, copays, coinsurance, etc. may be bracketed with the range of number variables.
- Each filing must include the following information:
- Identification of where the plan will be sold (i.e. on/off exchange, both)
- Identification of the rating area(s) where the plan will be sold. A carrier participating in a designated rating area must make coverage available throughout the entire rating area.
- Identify metal level for each benefit design for a health plan (i.e. bronze, silver, gold, platinum).
- A separate schedule with the language for each plan design that is to be offered, numerical amounts may be bracketed.
- The Actuarial Value of each plan design must be submitted, including a screenshot of the Actuarial Value Calculator.