Navigating the CMS HPMS Network Adequacy Submission: A Step-by-Step Guide

Overview of the HPMS Network Adequacy Submission

The Health Plan Management System (HPMS) is CMS's primary tool for managing Medicare Advantage plan submissions, and network adequacy data is one of the most detailed and error-prone components of the annual submission cycle. Plans submit their network adequacy data through HPMS as part of the MA Application process for new plans and through ongoing data submissions for existing plans, with CMS evaluating the submitted network against its adequacy standards for every county in the plan's service area.

A clean first submission — one that passes CMS's automated validations and adequacy calculations without generating a deficiency notice — is the goal. Deficiency notices require a 10-business-day response, create additional staff burden, and may result in service area reductions if the gaps cannot be resolved. This guide walks through the preparation and submission process step by step.

Step 1: Confirm Filing Deadlines and Required Data Elements

CMS publishes its network adequacy submission deadlines in the annual Call Letter and in HPMS Technical Guidance documents. These dates can shift from year to year, and the deadlines for new plan applications, service area expansions, and existing plan renewals may differ. Before beginning any submission preparation, confirm:

• The specific submission deadline for your plan type and submission purpose
• The current version of the HSD (Health Service Delivery) reference file template
• Any changes to specialty type codes or adequacy thresholds announced in the current year's guidance
• The required provider data elements for the submission (these have expanded in recent years)

CMS updates HPMS guidance documents frequently. Using last year's template or last year's specialty codes without checking for updates is a common source of submission errors.

Step 2: Build and Validate the Provider Data File

The network adequacy submission requires a provider data file that lists every contracted and credentialed provider in your network by NPI, specialty type, practice location address, and acceptance status. Building this file requires pulling data from multiple internal systems — contracting, credentialing, and the provider directory — and reconciling any discrepancies.

Critical validation checks before submission:

• Every NPI in the submission must be verified against PECOS as Medicare-enrolled in the submitted specialty
• Provider addresses must be formatted consistently and geocoded accurately — address formatting errors cause providers to map to incorrect counties
• Specialty type codes must match CMS's current HSD specialty taxonomy — providers submitted under legacy or incorrect codes will not count toward adequacy
• Accepting-new-patients status must be accurate — submitting providers as accepting when they are not creates directory accuracy failures
• Every provider in the submission must have an active, fully executed contract AND a completed credentialing approval

Step 3: Run Your Own Adequacy Analysis Before Submitting

Before submitting to HPMS, run your own adequacy analysis against the submitted provider file using your network adequacy software or an adequacy GIS analysis. This pre-submission analysis should replicate CMS's methodology: applying the time-and-distance standards for each county classification and specialty type to determine whether the submitted network meets the required adequacy thresholds.

Any county-specialty combination that fails your pre-submission analysis will also fail CMS's analysis. Identifying failures before submission allows you to either close the gap (by contracting and credentialing additional providers) or prepare a waiver request, rather than responding to a CMS deficiency notice on a 10-business-day deadline.

Pay particular attention to counties where you are close to the adequacy threshold — within a few percentage points. A provider who terminates or who CMS finds to be non-compliant with enrollment requirements can push a borderline county into deficiency. Adding buffer providers in borderline counties before submission is significantly easier than responding to a deficiency after.

Step 4: Prepare Waiver Requests for Known Gaps

If your pre-submission analysis identifies county-specialty combinations where adequacy cannot be achieved through in-person contracting — and where you are planning to request a waiver — prepare your waiver documentation before submission, not after receiving the deficiency notice. A well-prepared waiver request includes:

• A summary of the available provider supply in the county and specialty type (demonstrating why in-person adequacy is structurally impossible or impractical)
• Documentation of your good faith outreach efforts to every available in-person provider
• A description of the alternative access arrangements you have in place (telehealth, transportation benefits, care coordination)
• Evidence that members can access care through these alternative arrangements

CMS generally looks favorably on proactive waiver requests submitted with the adequacy filing versus waivers submitted reactively in response to deficiency notices, because the proactive approach demonstrates that the plan identified and addressed the gap rather than discovering it under audit pressure.

Step 5: Submit and Document

When submitting through HPMS, capture timestamps, confirmation numbers, and screen documentation of each major submission step. HPMS submissions have been known to generate system errors or lose data in edge cases, and having documented confirmation that data was submitted successfully — or identifying errors in the submission process in real time rather than waiting for a CMS deficiency — requires contemporaneous documentation.

Assign a staff member to monitor the HPMS submission status following submission. CMS's initial automated validations run within days of submission, and any data format errors will generate rejection messages that must be resolved and resubmitted before the deadline.

Step 6: Respond to Deficiency Notices

If CMS issues a deficiency notice — identifying county-specialty combinations where your submitted network does not meet adequacy standards — you have 10 business days to respond. A deficiency notice response can take one of three forms: submitting additional contracted providers that close the gap, submitting a corrected data file that fixes a data error in the original submission, or submitting a waiver request for the identified gap.

The 10-business-day response window is tight. Plans that do not have a pre-built deficiency response process — including pre-prepared waiver templates, a designated response team, and a process for rapidly identifying any available providers not included in the original submission — regularly miss the response deadline or submit incomplete responses.