In today’s episode of Regulatory Joe, we’re covering everything health plans need to know to navigate the Rates and Benefits Information System (RBIS) in 2025. From the revised four-window schedule to new URL submission requirements, these updates impact how health plans ensure their data is accurate, compliant and ready for open enrollment. 

What is RBIS? 

The Rates and Benefits Information System (RBIS) is a critical process that ensures accurate health plan data is displayed on Healthcare.gov before open enrollment begins. After binder filings are approved and certified by state divisions of insurance and CMS, issuers must repackage and resubmit the same core templates in RBIS. 

This second submission fuels the risk adjustment process and ensures that plan details, such as cost-sharing information, benefits, and URLs, appear correctly for members. Though it may seem duplicative, RBIS acts as a safeguard to minimize errors and discrepancies in the data health plans present to the public. 

What’s Changing in 2025? 

• Four-Window Submission Schedule 
  CMS has introduced a four-window schedule for RBIS submissions, beginning with the 2025 plan year. Each window aligns with critical deadlines, giving issuers opportunities to review and update submissions. The 2024 cycle closes on August 2, 2024, after which RBIS transitions to 2025 data collection starting August 26, 2024, and concluding August 1, 2025. 

• Updated URL Submission Criteria
  Issuers must now complete two separate URL submissions, one during the initial MPMS/SERFF application process and one in a final RBIS-specific URL template for each submission window. 

Regulatory Joe Recommendations 

• Create a dedicated repository 
  Establish a separate location, such as a SharePoint or shared drive, to store RBIS templates. This repository should be distinct from your binder filing documents to avoid confusion or versioning errors. Use a consistent naming convention that clearly identifies RBIS files and organizes them by submission window. 

• Validate templates early and frequently 
  Even if your templates are approved by the state and CMS, errors can still arise when cross-validating in RBIS. Start validating as soon as your templates are ready, focusing on ensuring cost shares, copays, and benefit details are consistent across all submissions. Early validation allows time to address discrepancies and avoid costly rework. 

• Double-check URL submissions 
  Accurate URLs are critical for compliance. Before submission, confirm that every URL directs members to active and correct pages for SBCs, provider directories, and drug searches. If you’re using prior-year data, update the links to reflect current-year information. This step prevents issues that could escalate with CMS or create barriers for members accessing your plans. 

• Define clear roles for team members 
  Assign specific roles within your RBIS process to streamline operations. Have one person handle the data submission and another focus on validation to introduce quality checks and reduce errors. Ensure a senior leader, such as your CEO or CFO, is designated as the RBIS attester. Securing their system access early will save time and avoid delays later in the process. 

• Prioritize testing and attestation 
  Rigorous testing of your templates is essential to catch errors before submission. Once your data is validated, focus on completing attestation during the first window to avoid additional work later. This step reduces the risk of bottlenecks and ensures your submissions align with CMS expectations. 

• Utilize weekly CMS RBIS calls 
  A new dial-in format for the HIOS/RBIS/PlanFinder weekly calls begins August 28, 2024. Policy questions can be sent to CCIIOPlanFinder@cms.hhs.gov, and technical issues to CMS_FEPS@cms.hhs.gov. 

Navigating the RBIS process in 2025 requires careful preparation, attention to detail, and a commitment to data accuracy. By following these recommendations and aligning your workflows with the updated CMS requirements, your health plan can avoid common pitfalls and ensure compliance. 

Be sure to watch the full episode for a more detailed run-down of changes and recommendations. 

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VIDEO TRANSCRIPT

Welcome to Regulatory Joe. I’m Joe Boyle, President of Regulatory Solutions here at Penstock, and today we’re going to talk about the Rates and Benefits Information System, also known as RBIS. 

So, what actually is RBIS? RBIS is an annual process that generally kicks off in the fall of each calendar year but spans across each quarter of the year for the future plan year. After all binder filings are approved, disposed of, and certified by state divisions of insurance and CMS, carriers have to re-download all the template packages from their binder filings and repackage them for submission in RBIS. 

You may be thinking, why do I have to make the same submission twice? Well, making the same submission twice into a different system kicks off a process that fuels risk adjustment. This process is generally driven by a health plan operation or filing team. For those of you close to the work, you recently received the new release from CMS publishing the new four-window schedule for calendar year 2025. 

As RBIS is almost the last line of defense before open enrollment begins, the submission is critical to ensure 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 RBIS submission. Making sure your plans display correctly on finder.healthcare.gov and also transfer properly to healthcare.gov is going to 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 shouldn’t preclude issuers from completing a robust testing process. It’s essential to ensure your cost shares, copays, and benefit level information on your file templates in your approved binders match the submission you upload and validate within RBIS. Just because the data has been approved and disposed of by state divisions of insurance and accepted by CMS, it doesn’t mean there’s no room for manual or data errors when your plans go live on healthcare.gov. 

It’s important to remember that any change, published or not, must be honored by carriers in member benefits, regardless of whether it’s correct in the member contract. 

The biggest change we see during the RBIS process for 2025 is definitely the URL submission criteria that issuers need to complete. If you’re close to the work, you know there are actually two different types of URL submissions that need to occur. The URL submission process begins with the CMS application in the MPMS system, followed by the URL submission within the RBIS-specific URL template provided when the window schedule opens. 

You cannot use the same URL tables from your initial application for your RBIS submission. The data needs to be transferred from your final approved application template, restructured into the RBIS URL schedule, and uploaded for validation. If you don’t complete this conversion, you’ll encounter errors that will need reworking and recording by CMS during the RBIS validation process. Ensuring your URLs are active is critical to the process. There must be a live webpage behind the link housing your plan data, whether it’s SBC documents, SOB documents, or landing pages for provider or drug directories. 

If you’re using prior-year URL data, make sure to remap those pages to current-year URLs so members can access the information they need quickly. This helps prevent escalations or negative feedback from CMS about your submission. 

When it comes to the health plans and what they need to do to execute a successful RBIS submission, there are a few things to keep in mind. First, it’s important to establish a local repository, such as a SharePoint or shared drive, to collect, save, and download all required templates for submission. You may already have a repository for your core filing documents, such as binders or forms, but we recommend separating the RBIS templates—even if they’re duplicative of your filing templates. 

While this might feel like extra work, it’s a way to avoid future validation issues. The next step is to download the final and approved templates from state divisions of insurance via your approved SERFF binder filings. These include the plan and benefit template, service area template, business rules template, URL template, and rate data template. These core templates represent the essence of RBIS—the Rates and Benefits Information System. Once downloaded, these templates will need to be converted into XML or zip files since RBIS does not accept Excel files. 

Another recommendation is to update naming conventions for RBIS-submitted templates to differentiate them from your previous filing documents. This prevents versioning issues and makes it clear which template is being used at which stage. 

We also advise designating one person on your team as the RBIS submitter and another as the RBIS validator. This separation ensures robust QA and QC processes, reducing rework down the road. At this stage, if you haven’t identified an RBIS attester—typically a senior executive like a CEO or CFO—you’ll need to do so. This individual must be granted access to the RBIS system. For every state a carrier operates in, about five access requests must be submitted to CMS. While this is time-consuming, the good news is it’s a one-time process, and attestation now only occurs once per year. 

For smaller carriers, this process may be more manageable, but for larger carriers operating in multiple states, it will require significant coordination. Once attestation is complete during the first window, there’s no need to repeat it in subsequent windows. 

Even with all these steps, challenges can arise. Errors like mismatches in service area, rate data, or plan-level information can occur. We recommend staying in close contact with your subject matter experts for rates, networks, and benefits to resolve these quickly. Establishing a workgroup for regular meetings—weekly or twice weekly—can help manage timelines and keep everyone aligned. 

Develop a project plan aligned with CMS’s four-window schedule, and track issues, errors, and rework items. Set reminders for window openings and closings to ensure nothing is overlooked. 

Thanks for listening to Regulatory Joe. Give us a like, share this episode, and we’ll see you next time!