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

Issue Date: January 30, 2019

Program Area: CSR Reconciliation (CSR)

Question: Is there a minimum date in 2016 through which paid claims must be included for the April 30, 2016 Cost-sharing Reduction (CSR) Reconciliation data submission deadline? If so, what is that date?

Answer: There is no minimum paid through claims date. Issuers may include late claims from services provided in the benefit year as close to the 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 submission deadline, issuers may submit these claims in the next CSR reconciliation reporting cycle. Further guidance on 2017 submissions will be provided at a later date.

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