CSR Reconciliation (CSR) FAQ
Guidance for FAQ regarding Cost Sharing Reduction (CSR) Reconciliation and Data Submission
Issued by: Centers for Medicare & Medicaid Services (CMS)
Issue Date: January 30, 2019
Program Area: CSR Reconciliation (CSR)
Question: Under what circumstances will the Centers for Medicare & Medicaid Services (CMS) permit issuers to submit additional reconciliation data for 2014 benefit year cost-sharing reductions (CSR)?
Answer: Cost-sharing reduction reconciliation data submission for the 2014 benefit year closed on June 3, 2016. Issuers should use the discrepancy process to report information the issuer believes affects the accuracy of its 2014 benefit year CSR reconciliation data submission. The deadline for filing discrepancy reports for the 2014 benefit year CSR reconciliation data is August 29, 2016. As stated in REGTAP FAQ 15396, CMS will permit issuers to restate 2014 CSR reconciliation data during the data submission cycle for the 2016 benefit year (Spring 2017) only because of unusual circumstances, such as outstanding appeals or legal issues. CMS will not accept restatements of 2014 CSR data in Spring 2017 to correct for routine restatements or issuer error. Prior to submitting new data that modifies the amount of CSRs provided for a policy, issuers must adjudicate the new claim and all other claims on the policy, as applicable, and re-adjudicate all such claims using CMS methodologies and re-adjudication guidelines to determine the accurate amount of CSR provided. See https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/CMS_Guidance_on_CSR_Reconciliation-for_2014_and_2015_benefit_years.pdf
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