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

Issue Date: January 30, 2019

Program Area: CSR Reconciliation (CSR)

Question: The document "CSR Reconciliation Issuer to MIDAS Inbound Specifications" has the following validation on page 13, "Total number of Exchange Subscriber IDs for the Plan variation must match the Count of records listed in Policy details (03 records)." How would CMS prefer issuers to handle members with multiple enrollment spans in different products (e.g., 1/1/2014 - 3/31/2014 in Product A, and then 7/1/2014 - 12/31/2014 in Product B?)

Answer: For this validation, CMS is verifying that the Total number of Exchange Subscriber IDs for which the issuer is submitting data in the plan variation matches the count of records listed in policy details (03 records). If a member has multiple Exchange Subscriber IDs but has remained in the same plan variant during the plan year, the issuer should only report one Exchange Subscriber ID. However, if the member was enrolled in different products and plan variants (indicated by the 16-digit HIOS ID), during the benefit year, the issuer should report those products and subscriber IDs separately. In that case, the issuer should ensure that the coverage start and end dates for the member do not overlap. Issuers should ensure that the count of records reflects the count of unique Exchange subscribers in that plan variation for which the issuer is submitting data. The information reported in each policy (03 record) must be unique for the time period in which the member was enrolled.

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