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

Issue Date: January 30, 2019

Program Area: CSR Reconciliation (CSR)

Question: During testing for Cost-sharing Reduction (CSR) reconciliation, the Centers for Medicare & Medicaid Services (CMS) asked issuers using the Simplified Actuarial Value (AV) methodology exclusively to submit the third tab of Attestation Form C, so that issuer's files would not be rejected. Do issuers using the Simplified AV method exclusively still need to complete the third tab on Form C?

Answer: Issuers using the Simplified AV method exclusively no longer need to complete Attestation Form C to avoid file rejection. Such issuers must submit either Attestation A or B, as applicable, and D, if applicable. Attestation Form C is only for issuers using the simplified methodology or a combination of the simplified methodology and the Simplified AV methodology.

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