Attachment G(2) QHP 2022 NonStandard Descriptions

The Attachment G(2) document is a supplemental component of the Qualified Health Plan (QHP) filing requirements for the 2022 plan year. It is used by insurers and publicsector carriers to report any benefit descriptions that deviate from the standardized language required by the Centers for Medicare & Medicaid Services (CMS). This page provides an overview of why the attachment exists, what types of nonstandard descriptions are allowed, the reporting process, and common pitfalls to avoid.

Why Does Attachment G(2) Exist?

CMS introduced a set of standard benefit descriptions to enhance comparability across QHPs, simplify the consumer decisionmaking process, and facilitate automated compliance checks. However, some health plans have unique features that cannot be fully captured by the standard language. Attachment G(2) provides a structured way for plans to:

• Explain variations in coverage that are medically or legally required.
• Document alternative benefit designs, such as tiered pharmacy formularies or customized costsharing arrangements.
• Maintain transparency while still meeting the overall filing requirements.

Key Elements of the Attachment

1. Header Information

The first section contains identification details that tie the attachment to the main QHP filing:

• Carrier name and identification number
• Plan name and metal tier (e.g., Bronze, Silver)
• Effective date and plan year
• Reference to the specific report (e.g., Form 4600 QHP Submission) that the attachment complements

2. Benefit Category Table

Each nonstandard description must be linked to a benefit category defined in the standard dictionary (e.g., Preventive Services, OutofNetwork Hospitalization). The table typically includes:

Benefit Category	Standard Description Code	NonStandard Text	Rationale / Explanation
OutofNetwork Inpatient	INPOONSTD	Coinsurance of 70% after deductible; no outofpocket maximum applies.	State law requires a higher costshare for OON services.
Prescription Drugs Tier1	RXT1STD	Flat copay of $5 for 30day supply; $10 for 90day supply.	Plan negotiates a regional rebate that lowers costshare.

3. Narrative Explanations

For each entry, a brief narrative (max 200 characters) must clarify why the description differs from the standard. The narrative should reference any statutory or regulatory provision, a collective bargaining agreement, or a medical necessity exception.

4. Certification Statement

The attachment concludes with a signoff from an authorized representative, confirming that the nonstandard descriptions are accurate, complete, and compliant with applicable law.

Types of Acceptable NonStandard Descriptions

Not every deviation is permissible. CMS outlines specific categories where nonstandard language may be used:

1. StateSpecific Mandates When a state imposes coverage rules that differ from federal standards.
2. Medical Necessity Exceptions Situations where a plan must limit or exclude a service because it is not medically necessary according to clinical guidelines.
3. CostSharing Variations Unique tiered costshare structures that cannot be expressed with the standard codes.
4. Benefit Design Innovations New models such as valuebased insurance design that alter the typical benefit language but still meet minimum coverage criteria.

Reporting Process

Submitting Attachment G(2) follows a threestep workflow:

Step 1 Populate the Template

Insurers download the CMSapproved Excel or XML template from the Health Insurance Marketplace portal. All required fields must be filled; blank cells will trigger validation errors.

Step 2 Validate Against the Schema

Before uploading, the file is run through an automated validator that checks for:

• Correct referencing of standard benefit codes.
• Character limits on narratives.
• Consistency between the main QHP filing and the attachment (e.g., same plan year).

Step 3 Upload and Review

The completed attachment is uploaded alongside the primary QHP submission. CMS reviews the nonstandard entries and may request clarification within 15 business days. If approved, the nonstandard language is displayed on the public plan comparison tool.

Common Pitfalls and How to Avoid Them

• Missing Reference Codes Always include the standard description code; omitting it will cause a rejection.
• Overly Vague Rationales Provide specific legal citations or contractual references; state law alone is insufficient.
• Exceeding Character Limits Keep narratives concise; the validator will truncate any text beyond the allowed length.
• Inconsistent Plan Year The attachment must match the plan year of the main filing exactly (2022 in this case).
• Incorrect Formatting in XML If using XML, ensure proper namespace declarations; otherwise the file will not parse.

Impact on Consumers

Transparency is the primary benefit of requiring Attachment G(2). When consumers view a plans public summary of benefits (PSB), any nonstandard language they encounter will have a clear explanation linked to it. This helps consumers:

• Understand why a particular costshare is higher or lower than the norm.
• Identify any statespecific protections that may be more generous than federal minimums.
• Make more informed decisions when comparing plans across carriers.

Resources for Further Reading

• CMS Guidance on Attachment G(2)
• HealthCare.gov Plan Comparison Tool
• U.S. Department of Health & Human Services FAQ

Conclusion

Attachment G(2) is a critical bridge between the uniformity CMS seeks in QHP reporting and the realworld variability of healthplan designs. By carefully documenting nonstandard benefit descriptions, insurers meet regulatory obligations while providing consumers with the clarity they need to choose the right coverage. Proper preparation, strict adherence to formatting rules, and clear rationales will streamline the submission process and reduce the likelihood of CMS followup requests.