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

Issue Date: April 13, 2016

Program Area: CSR Reconciliation (CSR)

Question: Can you provide clarification on whether understating the Cost-sharing Reductions (CSR) for a reported claim has any audit implications? We know that not reporting eligible claims doesn't have audit implications, but weren't sure about erring on the side of a conservative calculation.

Answer: The Centers for Medicare & Medicaid Services (CMS) expects issuers to submit accurate data on cost-sharing reductions provided, and all amounts are subject to audit. However, in remedying any inaccuracies in a submission, CMS will consider the financial impact of the inaccuracy.

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