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

Issue Date: March 24, 2016

Program Area: CSR Reconciliation (CSR)

Question: In REGTAP FAQ 14874, CMS noted that issuers using the simplified Actuarial Value (AV) methodology should enter a negative number for CSR provided for a policy when the standard plan cost-sharing is less than what the enrollee paid. Should issuers also enter a negative amount when the standard plan cost-sharing is less than the amount the enrollee paid when using the standard methodology?

Answer: For the standard methodology as well as for the simplified methodology, if the standard plan cost-sharing (312) is less than the cost-sharing paid by the enrollee, for example when the enrollee shifts to a more generous plan variation during the year, the issuer should enter the negative amount of CSR provided (313).

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