HPMS Network Adequacy
Submission Guide
Step-by-step walkthrough of the CMS HPMS network adequacy filing process — from obtaining system access to the final attestation. Includes HSD table field requirements, common upload errors, and submission calendar.
7-Step Process
How to Submit Network Adequacy Through HPMS
The HPMS network adequacy filing process has seven distinct stages. Each must be completed correctly before moving to the next — errors discovered late compress your timeline significantly.
Obtain HPMS Access
HPMS access requires a CMS-issued user account. Designated staff must complete the CMS security training modules and submit a User ID request through the HPMS Help Desk. Each user has role-based permissions — not all staff need write access to the network adequacy module.
Key Points
- Primary submitter and at least one backup should both have HPMS access before the submission window opens
- Role: 'Network Adequacy' module access is distinct from general HPMS access — verify permissions in advance
- CMS recommends testing system access 30 days before the submission deadline
Download the Current HSD Reference File
CMS updates the HSD (Health Service Delivery) reference file annually. The reference file defines the exact specialty codes, county FIPS codes, and county type classifications that must be used in your submission. Using an outdated reference file will cause validation errors.
Key Points
- Download from HPMS → Network Management → Network Adequacy → Reference Files section
- Confirm the effective date on the file matches the contract year you are filing for
- CMS typically releases the updated reference file 90 days before the filing window opens
Build Your Network Data File
The network submission consists of the HSD table — a structured data file listing your contracted providers by NPI, specialty code, county FIPS code, and service location. Each row represents one provider-county-specialty combination. The file must be formatted to CMS specifications with exact column headers and data types.
Key Points
- NPI must be Type 1 (individual) — Type 2 (organizational) NPIs are not accepted for the adequacy calculation
- Practice location zip code must match the NPI registry — mismatches trigger validation errors
- For providers serving multiple counties, submit one row per county-specialty combination
- Panel status (accepting new patients: Y/N) is a required field — do not leave blank
Run Internal Validation Before Upload
Before uploading to HPMS, run your own adequacy calculation against the HSD table. Identify county-specialty combinations that are below threshold. Resolve what you can; prepare exception documentation for what you cannot. Discovering gaps after upload forces a corrective resubmission under deadline pressure.
Key Points
- Compare your time-distance scores against the CMS threshold table for each county type (urban/suburban/rural/frontier)
- Verify that every provider in the file is currently credentialed and accepting new patients
- Flag exception-eligible counties (HRSA shortage designations, zero provider availability) for pre-emptive exception filing
Upload the HSD Table to HPMS
In HPMS, navigate to the Network Adequacy module for your contract. Upload the HSD table as a CSV or Excel file per CMS format requirements. HPMS runs automated validation on upload — you will receive an immediate error report if column headers, FIPS codes, or NPI formats are incorrect.
Key Points
- Do not close the browser during upload — large HSD tables can take 5–15 minutes to process
- HPMS validation errors (red flags) must be resolved before the submission can be finalized
- HPMS warnings (yellow flags) do not block submission but are reviewed by CMS analysts
Submit Exception Requests (if applicable)
For counties that remain deficient after uploading your HSD table, file exception requests in HPMS before finalizing the submission. Exception requests require a written narrative and supporting documentation (outreach logs for Access Exceptions; HRSA shortage data for Geographic Exceptions).
Key Points
- Exception requests are filed county-by-county and specialty-by-specialty — not a blanket filing
- Upload supporting documentation as PDF attachments within the HPMS exception module
- Pre-emptive exception filing is preferred over waiting for a deficiency notice after submission
Attest and Finalize the Submission
The final step is the network adequacy attestation — a legally binding certification by an authorized plan officer that the submitted network data is accurate and the plan will maintain adequate networks throughout the contract year. The attestation must be completed before the submission deadline.
Key Points
- Only authorized officers can sign the attestation — verify who is designated in the plan's CMS contract
- The attestation constitutes a legal certification under 42 CFR 422.116 — inaccurate attestations trigger enforcement action
- Save the HPMS submission confirmation page (timestamp) as a compliance record
HSD Table Reference
Required HSD Table Fields
The HSD table is the core data file for the HPMS network adequacy submission. Every field must be populated correctly for each provider row.
| Field | Format | Required | Notes |
|---|---|---|---|
| NPI | Numeric (10-digit) | Required | Type 1 (individual) NPIs only |
| Provider Last Name | Text | Required | Must match NPI registry |
| Provider First Name | Text | Required | Must match NPI registry |
| Specialty Code | CMS Code | Required | From current HSD reference file |
| Practice Location Address | Text | Required | Physical location; no PO boxes |
| Practice Location Zip | 5-digit | Required | Must match NPI registry location |
| County FIPS Code | 5-digit | Required | From current HSD reference file |
| Accepting New Patients | Y / N | Required | Y = open panel; N = closed panel |
| Hospital Affiliation | Text | Conditional | Required for hospital-based specialists |
| Telehealth Indicator | Y / N | Conditional | Required if counting as telehealth provider |
Error Prevention
7 Common HPMS Upload Errors (and How to Fix Them)
HPMS validation catches many errors automatically — but others slip through to CMS review and trigger deficiency notices weeks later. Fix these before you submit.
Error
Invalid NPI format
Common Cause
Using a 9-digit NPI, an organizational (Type 2) NPI, or a deactivated NPI
Fix
Verify all NPIs in NPPES before upload; filter out Type 2 NPIs; check for deactivated status
Error
FIPS code mismatch
Common Cause
Using an outdated FIPS code list or manually entered FIPS codes that don't match the current HSD reference file
Fix
Always derive county FIPS codes from the current contract-year HSD reference file downloaded from HPMS
Error
Specialty code not recognized
Common Cause
Using a specialty code from a prior year's reference file, or mapping a specialty incorrectly
Fix
Use only specialty codes from the current year's HSD reference file; confirm mappings against the CMS specialty taxonomy
Error
Practice location zip doesn't match NPI registry
Common Cause
Provider changed office location but NPI registry wasn't updated, or the zip in your system differs from NPPES
Fix
Cross-reference practice location zip with NPPES before building the HSD table; request providers update their NPPES records
Error
Duplicate rows
Common Cause
Same NPI listed twice for the same county-specialty combination
Fix
Deduplicate your HSD table before upload; each NPI-county-specialty combination should appear exactly once
Error
Missing panel status
Common Cause
Accepting New Patients field left blank or filled with values other than Y or N
Fix
All rows must have Y or N in the panel status field — blank values are treated as errors, not as Y
Error
File format error
Common Cause
Uploading an Excel file with formulas, merged cells, or non-standard character encoding
Fix
Save as plain CSV (UTF-8) before upload; no formulas, no merged cells, standard ASCII characters only
Key Deadlines
HPMS Network Adequacy Submission Calendar
CMS releases HSD reference file
HPMS network adequacy module opens
Initial HSD table upload deadline
MA bid submission deadline
CMS initial adequacy review period
Deficiency notices issued
30-day deficiency response window
Final adequacy approval
Blueprint Platform
Blueprint Prepares Your HSD Table Automatically
Blueprint maintains your provider roster in HPMS-ready format year-round. When the submission window opens, export a validated HSD table with every required field pre-populated — no manual formatting, no column header errors, no NPI lookups.
FAQ