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

Issue Date: April 05, 2016

Program Area: CSR Reconciliation (CSR)

Question: Can issuers use their own internal policy IDs in place of Subscriber IDs assigned by State-Based Exchanges? How will this affect audits?

Answer: For State-based Exchanges, issuers may report their internal Policy IDs instead of the "Exchange Assigned Subscriber ID," if the internal Policy ID is associated with a valid subscriber for the time period for which data is being submitted, and if the issuer believes that the internal Policy ID provides a more accurate means of identifying the policy and subscriber as compared to the "Exchange Assigned Subscriber ID". Issuers should be sure to still follow the format requirements for the "Exchange Assigned Subscriber ID", as outlined in the CSR Reconciliation Issuer to MIDAS Inbound Specification document. This will not cause an audit issue for data that is submitted in the 2016 cycle.

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