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

Issue Date: March 11, 2016

Program Area: CSR Reconciliation (CSR)

Question: If the issuer submits an Exchange Subscriber ID that fails validation as a result of not matching FEPS records for the Federally-facilitated Marketplace (FFM), will the entire submission fail as a result of that single Exchange subscriber ID?

Answer: No. If an FFM issuer's Exchange Subscriber ID fails validation, only the policy record level ('03' record) associated with that Exchange Subscriber ID will fail. The issuer will receive an error report indicating the failure, but the rest of the file will process. However, if 50% or more of an issuer's policy records fail, CMS will reject the entire file, including any valid policy records, and the submission will not be processed. Policy records that fail will not be included in the calculation of the issuer's reconciled CSR amount. We note that CMS will only validate Exchange Subscriber IDs for policies offered through the FFM; the validation will not apply to policies offered through a State-based Marketplace.

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