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

Issue Date: January 30, 2019

Program Area: CSR Reconciliation (CSR)

Question: Can Issuers include 2014 and 2015 Cost-sharing Reduction (CSR) data and runouts/adjustments through February 29, 2016 in the April 2016 CSR data submission?

Answer: Issuers may include late claims from services provided in the benefit year as close to the April 30 data submission deadline as is practical, as long as the issuer recalculates and restates all claims for the associated policy as necessary prior to a final re-adjudication of such claims for reconciliation. Our guidance specifies that if issuers are unable to fully re-adjudicate claims incurred during the benefit year by the April 30, 2016 submission deadline, issuers may submit these claims in the next CSR reconciliation reporting cycle in April 2017.

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