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

Issue Date: February 05, 2020

Program Area: Payment Policy and Financial Management Group External Audits (PPFMG EA)

Question: Should the enrollment and payment data reported in the desk audit file be prorated?

Answer: 2014 benefit year audits: There were no proration requirements for the 2014 benefit year; therefore, the premium and Advanced Payments of the Premium Tax Credit (APTC) amounts reported in the desk audit file should only be prorated if the data reported in the final, restated 2014 benefit year EPDW was prorated. The count of members in the policy reported in the desk audit file should not be prorated. 2015 benefit year audits: There were proration requirements for the 2015 benefit year; therefore, the premium and APTC amounts reported in the desk audit file should be prorated. The count of members in the policy reported in the desk audit file should not be prorated.

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