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

Issue Date: April 05, 2016

Program Area: CSR Reconciliation (CSR)

Question: CMS tells issuers to aggregate policies for one (1) person under one (1) subscriber. Does CMS object if an issuer wants to keep the subscribers separate so that they match enrollment data?

Answer: Issuers should aggregate policies for the same subscriber in the plan variation, regardless of whether accumulators carry over. CMS instructs issuers to aggregate policies in a plan variation in the case of a change in circumstance or gap in coverage to avoid duplication of reporting and because in many cases, accumulators carry over. Even when not required to carry over accumulators, the issuer uses the same parameters to re-adjudicate these policies. When aggregating policies, report only one (1) Subscriber ID (for Data Element ID 302 "Exchange Assigned Subscriber ID" in the Policy Detail Record) and include only one (1) Subscriber ID in the count of "Total number of Exchange Subscriber IDs in this plan variation for the benefit year" in the Plan Summary level. If an issuer does not combine the policies into one (1) record and reports them separately, CMS will not reject the record or file. However, if the issuer submits multiple policy records under the same Exchange Subscriber ID, the issuer must ensure that cost-sharing information is not duplicated. Whether combining records or reporting them separately, the issuer must follow accumulator rules to determine CSR provided.

HHS is committed to making its websites and documents accessible to the widest possible audience, including individuals with disabilities. We are in the process of retroactively making some documents accessible. If you need assistance accessing an accessible version of this document, please reach out to the guidance@hhs.gov.

DISCLAIMER: The contents of this database lack the force and effect of law, except as authorized by law (including Medicare Advantage Rate Announcements and Advance Notices) or as specifically incorporated into a contract. The Department may not cite, use, or rely on any guidance that is not posted on the guidance repository, except to establish historical facts.