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

Issue Date: January 30, 2019

Program Area: CSR Reconciliation (CSR)

Question: Can issuers submit zero (0) dollars for Cost-sharing Reductions (CSR) provided for de minimis enrollment in certain plans (for example, American Indian/Alaska Native populations in bronze plans)?

Answer: If an issuer has few enrollees or enrollees with few or no CSR claims in any plan variation including the zero (0) and limited cost-sharing plans during a benefit year, the issuer may elect to reimburse the Centers for Medicare & Medicaid Services (CMS) the full advance payment amount for those plans rather than re-adjudicate such claims. If an issuer elects to repay the entire CSR component of advance payments for a particular Qualified Health Plan (QHP), the issuer should email CSRreconciliationattestations@cms.hhs.gov. Failure to submit a report for a plan will not trigger an error; however, CMS will automatically calculate zero (0) for CSRs provided for the plan, and issuers will be charged the full amount of the advance payment they received for the applicable benefit year. Repayment of the full advance payment does not change the issuer's obligations under 45 CFR 156.480 to adhere to, and ensure that any relevant delegated entities and downstream entities adhere to, the standards set forth in 156.705 concerning maintenance of documents and records, whether paper, electronic, or in other media, by issuers offering QHPs in a Federally-facilitated Exchange, in connection with the advance payment of cost-sharing reductions and premium tax credits. Additionally, as provided under 156.480(c), issuers that offer a QHP in the individual market through an Exchange are subject to audit by the Department of Health and Human Services (HHS) or its designee to assess compliance with the relevant requirements regarding CSRs.

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