AttachmentG(2) QHP 2020 NonStandard Descriptions

What Is Attachment G(2)?

AttachmentG(2) is a supplemental document required by the Centers for Medicare & Medicaid Services (CMS) for Qualified Health Plans (QHPs) that are submitted for the 2020 Marketplace. It is used to convey information that does not fit into the standard benefit descriptions found in the main plan brochure. The term nonstandard descriptions refers to any benefit, limitation, or costsharing arrangement that is atypical, unique to a particular plan, or required by statespecific regulations.

Why It Exists

The Marketplace standardizes most plan information so consumers can compare plans sidebyside. However, CMS recognizes that some plans offer features that cannot be expressed in the standard tables (e.g., experimental therapies, special enrollment conditions, or statemandated benefits). AttachmentG(2) provides a structured way for issuers to disclose these items without compromising the clarity of the primary comparison tables.

Who Must Submit It

• All issuers that submit a QHP for the 2020 enrollment period.
• Plans that have at least one benefit, limitation, or costsharing rule that is not captured in the standard format.
• Staterun exchanges when they have additional reporting requirements.

Structure of the Document

AttachmentG(2) follows a tabular format mandated by CMS. Each row represents a single nonstandard description, and the columns capture specific attributes. The main columns are:

• Benefit Category The broad group (e.g., Dental, Vision, Pharmacy, Behavioral Health).
• Service Description A concise narrative of the service or limitation.
• Applicability Whether the description applies to all members, specific subgroups, or only under certain circumstances.
• CostSharing Details of copays, coinsurance, or outofpocket maximums that differ from the standard tables.
• Effective Date The date the nonstandard rule becomes active.
• Reference CMS or state regulation citations, or internal plan policy numbers.

Example Row

Benefit Category: Pharmacy Service Description: Coverage for FDAapproved investigational drugs under a clinical trial protocol. Applicability: Only for members enrolled in the trial. CostSharing: No copay; the plan covers 100% of the drug cost. Effective Date: 01012020. Reference: CMS QHP Manual 202002, 24.4.

Key Content Areas

1. Experimental and Investigational Treatments

Plans may list coverage for therapies that have not yet received full FDA approval but are approved for limited use (e.g., compassionate use programs). The description must clarify the eligibility criteria, any enrollment process, and the costsharing arrangement.

2. StateMandated Benefits

Some states require coverage for items such as autism services, fertility treatments, or postpartum depression counseling. Attachments must specify the state law, the extent of coverage, and any utilization limits.

3. TierSpecific Pharmacy Limitations

When a plan applies unique costsharing to a particular drug tier (e.g., Tier3 drugs subject to a steptherapy requirement), the details belong in G(2). The issuer must include the steptherapy protocol and any associated waivers.

4. Dental and Vision Exceptions

Standard tables typically include only basic dental and vision coverage. If a plan offers enhanced orthodontic services for children, for example, the nonstandard description must explain age restrictions, frequency limits, and the applicable copay.

5. Behavioral Health and TeleHealth Services

Plans that provide expanded telehealth benefits beyond the baseline CMS requirements (such as unlimited virtual visits or coverage for certain mentalhealth apps) must use G(2) to define the scope.

6. CostSharing Variations

Any variation from the standard costsharing chartlike an outofnetwork exception that applies only to a specific serviceneeds a clear description, including how the amount is calculated.

Compliance Considerations

Issuers must ensure that AttachmentG(2) is accurate, complete, and submitted on time. Failure to provide required nonstandard descriptions can result in:

• Plan rejection or delay in certification.
• Potential penalties or fines from CMS.
• Consumer confusion leading to increased complaints or appeals.

Review Process

CMS reviewers compare each row in G(2) with the plans contract language and the standard benefit tables. They look for consistency, proper references, and adherence to federal and state regulations. Common issues flagged during review include missing reference citations, ambiguous applicability statements, and costsharing amounts that contradict the main plan document.

Best Practices

• Use clear, concise languageavoid jargon that could be misinterpreted.
• Provide exact regulatory citations (e.g., 1902.13(b)) for each entry.
• Maintain a master spreadsheet that tracks every nonstandard item from development through submission.
• Perform an internal audit against the final submission to verify alignment with the plan contract.
• Include a lastupdated date on each row to ease future revisions.

Impact on Consumers

AttachmentG(2) is not typically displayed prominently on consumerfacing materials, but the information it contains influences the actual experience of enrollees. Understanding the nonstandard descriptions can help consumers:

• Identify additional benefits that may be valuable for their specific health needs.
• Recognize any extra costs that are not evident in standard tables.
• Determine whether a plan meets statespecific requirements (e.g., autism coverage).
• Plan for eligibility requirements such as prior authorization or enrollment in a clinical trial.

Consumer advocacy groups encourage issuers to make the G(2) content more accessible by linking it to the plans online summary of benefits. Transparency reduces surprise billing and improves overall satisfaction.

Historical Context

The need for a dedicated attachment emerged during the 2016 Marketplace rollout when issuers struggled to fit numerous statemandated benefits into a single standardized table. CMS introduced AttachmentG(2) in the 2017 regulatory update, and the format has remained largely unchanged through the 2020 filing season. The 2020 version includes minor clarifications on the Applicability column to better capture subgroup limitations.

Evolution of NonStandard Reporting

Prior to the formal attachment, issuers submitted supplemental PDFs that varied widely in format, making CMS review inefficient. By standardizing the layout, CMS achieved faster turnaround times and reduced the likelihood of misinterpretation. The attachment also supports automated data extraction, facilitating better marketlevel analyses of how many plans use nonstandard benefits.

Future Outlook

Looking ahead, CMS is considering enhancements to the G(2) process:

• Machinereadable XML schema to replace the current Excelbased submission.
• Consumerfriendly web display that integrates nonstandard descriptions directly into the plan comparison tool.
• Expanded guidance for emerging benefit areas such as digital therapeutics and geneediting therapies.

These changes aim to improve both compliance for issuers and transparency for consumers. Until the new system is in place, the 2020 AttachmentG(2) remains the authoritative source for any nonstandard benefit information for that enrollment year.