Issued by: Centers for Medicare & Medicaid Services (CMS)

Issue Date: May 25, 2016

Program Area: ACA Financial Appeals (ACA FA)

Question: Will the Centers for Medicare & Medicaid Services (CMS) require issuers to run the Overlapping Claims Summary query and complete the attestation if an issuer's plans are not eligible for Reinsurance (RI)?

Answer: Yes. All issuers must run the Overlapping Claims Summary Count query and report any claims discovered by the query as a discrepancy. CMS is developing an updated query that will exclude overlapping claims for enrollees not qualified for RI. Once the new query is complete, issuers can use that query and report the results, which may report fewer overlapping claims than the current query. If an issuer runs either query and it returns zero (0) results, then the issuer does not need to submit a discrepancy.

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