Regulatory Joe

Navigating RBIS in 2025: Essential Tips for Health Plans

In today’s episode of Regulatory Joe, we’re diving into the 2025 Rates and Benefits Information System (RBIS) updates, highlighting what health plans need to know to ensure accurate and compliant submissions. 📌 Key Takeaways: The new four-window CMS schedule and how to stay ahead of critical deadlines Updated URL submission criteria and best practices for mapping and validation Tips for ensuring data accuracy and avoiding common RBIS submission errors And more! 🔔 Subscribe for more regulatory insights and health plan updates!

Duration:: 8m
Broadcast on:: 04 Dec 2024
Audio Format:: other

📌 Key Takeaways:

The new four-window CMS schedule and how to stay ahead of critical deadlines
Updated URL submission criteria and best practices for mapping and validation
Tips for ensuring data accuracy and avoiding common RBIS submission errors
And more!

🔔 Subscribe for more regulatory insights and health plan updates!

- Welcome to Regatory Joe. I'm Joe Boyle, President of Regatory Solutions here at PennStock. And today we're going to talk about the rates and benefits information system also known as Arbus. So what actually is Arbus? Arbus is an annual process that generally kicks off in the fall of each calendar year, but spans across each quarter of the future plan year. After all binder filings are approved, disposed, and certified by all state divisions of insurance and CMS, carriers then have to redownload all the template packages from your binder filings and repackage them for submission in Arbus. You may be thinking, well, why do I have to make the same submission twice? Well, making the same submission twice into a different system will then kick off a process that fuels risk adjustment. This is generally driven by a health plan, operation, or filing team. For those of you close to the work, you recently received a new release from CMS, publishing the new four window schedule for calendar year 2025. As Arbus is almost the last line of defense before open enrollment begins, the submission is critical to make sure it's quality, timely, and compliant with all CMS standards, including understanding the new changes that CMS is proposing or the implications of other changes impacting the Arbus submission. Making sure that your plans display correctly on finder.healthcare.gov and also transferring to healthcare.gov will be key as well. While CMS has simplified the special enrollment period regulations to ensure income matching is equitable for all members, shopping for a health plan on healthcare.gov, it should not preclude issuers from still completing a robust testing process to make sure that your costures and copays and benefit level information on your file templates in your approved binders match the submission that you actually upload and validate within Arbus. Just because the data has been approved and disposed by state divisions of insurance and as well as accepted by CMS does not mean that there is room for manual error or data error when your plans go up on healthcare.gov. It's important to remember that any change published or not carriers would need to honor the benefit that's given to the member regardless if it's correct or in the member contract. The biggest change we see during the Arbus process for 2025 is definitely the URL submission criteria that issuers need to complete. If you're close to the work that you do know that there's actually two different types of URL submissions that need to occur. The URL submission process, prior to your CMS application being approved within the MPMS system, followed by the URL submission within the Arbus specific URL template that's provided when the window schedule opens. Understanding that you are not able or not allowed to use the same URL tables that you completed in your initial application for your Arbus submission, that data actually needs to be transferred, removed from your final application template, produced back into the Arbus URL schedule and then uploaded to the system to be validated. So making sure that if you do not complete this data conversion from your final approved application to your Arbus submission template, you will expect errors that will need to be reworked and also recorded by CMS in your Arbus validation process. Making sure that your URLs are active will also be very critical to the process to make sure that there is an active web page behind the link housing your plan data, whether it's your SBC documents, your SOB documents or landing pages where members can actually search and shop for a provider or a specific drug within a drug directory. Also making sure that if you are starting with using prior year URL data that you're actually remapping those web pages to current year URL web pages so that members can access the information that they need quickly to prevent any escalations or negative feedback from CMS on your submission will be very important. So make sure all of your URLs are active and bringing you to the right place that you intended to bring your members to. So when we talk about the process for the health plans and what they actually need to do to execute a successful Arbus submission, there's a couple things to be mindful of. What we've learned in the past is number one, it's important to have a local repository either on a SharePoint or a ShareDrive to collect, save and download all required templates for submission. Now you may already have a repository where all of your core filing documents are housed today, whether it's your binders or your forms and that's okay, but we also recommend separating the Arbus templates even if they're duplicative or the same as the filing templates that were approved in your plan binders. So you'll see through the process that it's going to feel like a lot of rework or a lot of duplicate work, but it's a way to prevent any future issues and validation errors that we've seen in the past. The next step would be downloading the actual final and approved templates from state divisions of insurance through your approved surf binder filings, including your plan and benefit template, your service area template, your business rules template, your URL template and also your rate data template. These core templates represent the definition of Arbus, the rates and benefits information system. So all of your rates and all of your benefits are now being pulled down from the state portal and now submitted to CMS to then be submitted and then transferred to healthcare.gov. Once you download all required templates to your newly established repository, we also recommend that you complete a new naming convention for the Arbus submitted templates that differentiates them from your previous filing templates. The reason why we update new naming conventions with the Arbus submitted templates is so that we can differentiate them from the approved filing documents and so that we can prevent versioning issues or confusion about what templates going where at what time. Now, by the time that you download all your templates, they will be in Excel format. So we do need you to reconvert those to XML if you haven't already by this point because the Arbus system only accepts zip files or XML files. Once you validate those templates, you can then get to work. Another item that we recommend when actually starting the submission of this process is to designate one person from your team as a Arbus submitter and one person from your team as an Arbus validator. It's important to delineate these roles so that the same person submitting the data is not the same person validating that same data set. This is going to induce great QA and QC within your standard operating procedure. This is going to prevent a lot of rework for your teams down the road. At this point in the process, if you have not already identified in a tester for your Arbus submission, you should work with your leadership and executive team to do so. CMS has defined an Arbus a tester as generally a CEO or a CFO, somebody that's a senior officer that can find the company financially. Once you've found an appointed in a tester for your Arbus submission and received all necessary approvals, this person will then first need to get access to the system. When you're dealing with senior executives on that leadership level, it's hard to find the time to get all of the access requests done in a timely fashion. If you're a smaller carrier, it's going to be definitely easier for you to carve out the time and request all the issuer instances to Arbus. For every one state that you participate in, generally speaking, you're going to have to make about five access requests with CMS. So if you're with a larger carrier and participate in five, 10, 15 or 20 states, multiply that by five and you're going to have to spend a lot of time with your senior leaders to get them the right access to attest to all your plan data. While this is cumbersome, this is a one-time process only. Once your attester has completed this work once, they will never have to complete access requests again. CMS has moved the attesting process from four times a year to only one time a year. So for those of you out there who've done this since day one, when the ACA was passed into law, when you had to sit down with your CEOs once every four months. Now, once you complete attestation, we recommend you do it in the first window. Therefore, you do not have to attest windows two, three or four. So when looking at some of the challenges that Arbus could create internal to your organization, there's a couple of things to look out for. Just because planned data has been certified by your state, approved by CMS, does not mean that errors can be encountered when cross-validating in Arbus. We have seen on a number of different occasions that there are mismatches between service area and plan level data, rate data and service area data, based on how the templates are set up or how the system has been configured. We recommend that you are in close touch with your subject matter experts who completed those specific templates, most especially with rates, your network and your benefits and have them on standby, so that if errors do occur within the Arbus submission, you can reconcile them quickly. We also recommend you establish a workgroup within your teams to then have a weekly or twice weekly discussion, so that you can manage your timelines and actually meet all submission criteria compliantly. We recommend developing a robust project plan that's time bound, that actually follows the four Windows CMS schedule, as well as tracking a log of errors, issues or items that you have to rework. With the newly released Windows schedule from CMS, we'll throw those right up on the screen so you can make a note. We recommend that you do set reminders on your calendar for you and your internal team stakeholders when the window is open and the dates the windows close, so that you can track with calendar reminders and it won't fly under the radar. Thanks again for listening everybody, give us a like, give us a share and we'll talk to you next time. (upbeat music) (upbeat music) [MUSIC PLAYING]