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 2016 benefit year and prior year restatements?

Answer: An issuer will be permitted to file a discrepancy beginning June 30, 2017 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/CSR-Reconciliation-2016-Benefit-Year-and-Prior.pdf . No discrepancy will be accepted after 11:59 p.m. ET on Friday, August 11, 2017. Issuers who identify data discrepancies related to Qualified Health Plan (QHP) ID errors, Exchange-assigned 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 Enterprise File Transfer (EFT). Issuers should not submit a discrepancy for an issue for which the issuer previously filed a discrepancy. CMS will only accept data discrepancies for data that directly impacts the calculation of the issuer's reconciled CSR amounts. CMS published an updated technical specification document (link above) outlining the format of the discrepancy file, which is similar to the file format used for submission of the 2014 and 2015 CSR reconciliation discrepancy file. We note that all issuers will be notified of CSR reconciliation payments or charges by June 30, 2017. If a discrepancy results in a payment or charge adjustment following the June 30, 2017 calculation, CMS will make any 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 2016 benefit year and prior year restatements (as applicable). We note that, pursuant to the Manual for Reconciliation of the CSR Component of Advance Payments for Benefit Year 2016, issuers may also submit additional 2016 data that becomes available after CSRs have been reconciled for the 2016 benefit year, during the 2017 CSR reconciliation reporting year cycle, in the Spring of 2018.* * See page 8 of the Manual for Reconciliation of the CSR Component of Advance Payments for Benefit Year 2016.

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