How do state exchanges publish and update the plan-level data used to compute SLCSPs (public-use files and QHP landscapes)?
Executive summary
State exchanges publish the plan-level data used to compute second-lowest-cost silver plans (SLCSPs) through standardized application templates and rate filings that feed into CMS public-use files (PUFs) and QHP Landscape datasets; much of the SBE data CMS publishes are aggregated from SERFF submissions via the NAIC while Federally Facilitated Exchange (FFE) and SBE-FP states are included in the main Exchange PUFs [1] [2] [3]. The datasets are updated on an annual cadence tied to the QHP certification and Open Enrollment process, with CMS documenting import cutoffs and reporting windows and producing specialized files (Plan ID crosswalks, service-area PUFs, landscape snapshots) that researchers must stitch together to reproduce SLCSP calculations [2] [4] [5].
1. How plan-level data originate: insurers file standardized templates and rate forms
The raw plan-level inputs begin with issuers’ QHP applications and rate & form filings — templates and service-area spreadsheets submitted into state and national systems such as SERFF, which the NAIC extracts and provides to CMS; CMS explicitly says the SBE QHP PUFs are built from data available in SERFF [3] [1]. Those filings include premiums, benefit design and the percent of premium attributable to Essential Health Benefits (EHBs), which are the fields used later to rank silver plans for SLCSP determination [6] [7].
2. How CMS assembles and publishes PUFs and QHP Landscape files
CMS aggregates these inputs into multiple public-use products: Exchange PUFs (covering FFEs, some SBE-FPs, MSPs and off‑exchange SADPs), SBE-specific QHP PUFs (for state-based platforms using non‑federal IT), and the QHP Landscape files that are intended as a snapshot of available QHPs and SADPs by geography and metal level [2] [4] [8]. CMS and data.healthcare.gov host these downloadable datasets — including Plan ID crosswalks that map plan identifiers across files — so researchers can link premium, service-area and plan characteristics needed to compute benchmarks [5] [8].
3. The update cadence: annual certification windows, import cutoffs, and OE reporting periods
Updates follow the annual QHP certification and Open Enrollment timelines: issuers submit plan data during certification, CMS imports the finalized datasets by scheduled cutoffs (for example, data for the 2026 Exchange PUFs were last imported by December 16, 2025), and the Open Enrollment reporting windows define the enrollment snapshot period that accompanies some PUF releases [2] [9]. CMS also warns that data are subject to change from plan withdrawals and state-specific schedule differences [10] [9].
4. From plan files to the SLCSP: ranking silver QHPs by EHB-attributable premiums
The operational SLCSP computation uses the landscape/PUF plan rows: for each county (or defined service area) CMS ranks silver-level QHPs by their EHB-premium amounts and selects the second-lowest value as the benchmark used to calculate APTC; methodological reports for PY24 and PY25 describe this ranking and calculation process in detail [6] [7]. The eligibility and APTC distribution logic in HealthCare.gov then applies household rating rules and crosswalks to convert that plan-level benchmark into individual tax-credit amounts [6].
5. Limits, transparency gaps and competing incentives in the data pipeline
The public process is transparent in form but constrained in practice: CMS excludes SBEs that do not rely on the federal platform from the Exchange PUFs (while providing a separate SBE QHP PUF sourced from SERFF) and notes the PUFs do not include enrollment or claims data — limitations that can matter for researchers validating benchmark outcomes [1] [3] [2]. Further, reliance on SERFF means CMS’ SBE PUFs only contain fields that states require to be filed there, and plan withdrawals or late changes can create divergence between the snapshot used to compute an SLCSP and what consumers actually see [3] [10]. Stakeholders — states, insurers, and CMS — each carry incentives (regulatory compliance, market signaling, administrative simplicity) that shape what gets filed, how complete it is, and when CMS freezes datasets for publication.
6. Practical advice for reproducing or auditing SLCSPs using PUFs
To reproduce or audit SLCSPs, researchers must combine the QHP Landscape medical files, the service-area PUF (SA-PUF) and the Plan ID crosswalk, check the import date or OE reporting window for the applicable plan year, and account for state-specific exclusions (SBE-only platforms) and known plan withdrawals; CMS guidance and the landscape methodology documents are the authoritative references for the ranking rules and age-rating redistribution logic [4] [5] [6]. Where the dataset lacks an element needed for a full audit — for example, enrollment-weighted recalculations tied to post‑certification plan changes — reporting limitations should be acknowledged rather than assumed resolved, per CMS’ documentation [2] [4].