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

Issue Date: February 23, 2016

Program Area: CSR Reconciliation (CSR)

Question: If CMS has a record of a subscriber with CSRs, but the issuer does not submit a 03 record for that subscriber (i.e., issuer orphan), will CMS identify this as an error when validating data?

Answer: No, if an issuer has a subscriber for which it does not submit a policy level '03' record that will not trigger an error in the system. However, CMS notes that, if no data is submitted for that policy, any CSRs that the issuer provided for that policy will be counted as zero (0) when reconciled CSR amounts are calculated.

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