CSR Reconciliation (CSR) FAQ
Guidance for FAQ regarding Cost Sharing Reduction (CSR) Reconciliation Methodology and Simplified Methodology
Issued by: Centers for Medicare & Medicaid Services (CMS)
Issue Date: January 30, 2019
Program Area: CSR Reconciliation (CSR)
Question: At what level should the Simplified Actuarial Value (AV) method formula apply for plans with embedded out-of-pocket limitations?
Answer: The annual limitation used in the simplified AV methodology calculation is always the annual limitation of the policy level, (for example, other than self-only for the standard plan). As discussed on p. 23 of the CSR reconciliation manual for 2014 and 2015 benefit years, "Issuers must use the other than self-only annual limitation on cost sharing for the standard plan for family plans with embedded individual limits."
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