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

Issue Date: January 30, 2019

Program Area: CSR Reconciliation (CSR)

Question: What is the process for issuers to file a discrepancy related to their Cost-sharing Reduction (CSR) reconciliation data submitted for the 2014 and 2015 Benefit Years?

Answer: An issuer will be permitted to file a discrepancy beginning June 23, 2016 using the technical specifications on discrepancy submission published by the Centers for Medicare & Medicaid Services (CMS), available at: https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/Cost-Sharing-Reduction-Reconciliation-Discrepancy-Resolution-Inbound-Specification.pdf. Issuers are encouraged to submit a discrepancy as soon as possible and prior to filing a request for reconsideration as explained in FAQ 16489. No discrepancy or request for reconsideration will be accepted after 11:59 p.m. EST on Monday, August 29, 2016. Issuers who identify data discrepancies related to Qualified Health Plan (QHP) ID errors, Exchange Subscriber ID errors, or errors related to the amount of Cost-sharing Reductions (CSRs) that an issuer provided at the policy level, including, for example, flawed issuer calculations or lost data, should submit data related to their discrepancy in a pipe-delimited file through electronic file transfer (EFT). CMS will only accept data discrepancies for data that directly impacts the calculation of the issuer's reconciled CSR amounts. At the same time as the discrepancy window is opened, CMS will publish a technical specification document outlining the format of the file, which generally will be similar to the file format used for submission of the 2014 and 2015 CSR reconciliation data file. We note that all issuers will be notified of CSR reconciliation payments or charges by June 30, 2016, regardless of whether a discrepancy has been filed or resolved. If a discrepancy results in a payment or charge adjustment following the June 30, 2016 calculation, CMS will make this adjustment in a monthly payment cycle following the decision. Any issuer that does not file a discrepancy will be deemed as accepting their final data submission for CSR reconciliation for the 2014 and 2015 Benefit Years (as applicable) and CMS will use this final data submission to calculate final CSR reconciliation payments or charges and will notify issuers by June 30, 2016 of their final CSR reconciliation payments or charges. We note that, pursuant to the Manual for Reconciliation of the CSR Component of Advance Payments for Benefit Years 2014 and 2015, issuers also may submit additional 2015 data that becomes available after CSRs have been reconciled for the 2015 Benefit Year, during the 2016 CSR reconciliation reporting year cycle, in the spring of 2017. * In rare circumstances, CMS may make limited exceptions to allow issuers to submit additional 2014 data during the same 2016 CSR reconciliation reporting cycle. CMS will issue guidance on the process for the 2016 CSR reconciliation cycle at a later date. * See page 6 of the Manual for Reconciliation of the CSR Component of Advance Payments for Benefit Years 2014 and 2015 and FAQs 14904, 14905, and 15457 available on http://www.regtap.info/.

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