ACAP Letter to CCIIO Requesting a Delay in Risk Adjustment and Reinsurance Data Submission Deadline

The Association for Community Affiliated Plans (ACAP) is grateful for the opportunity to submit comments regarding the upcoming April 30th submission deadline for risk adjustment and reinsurance data.

ACAP is an association of 58 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to approximately 12 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for dually-eligible individuals. Nationally, ACAP plans serve roughly one-third of all Medicaid managed care enrollees. In addition, 18 of ACAP’s Safety Net Health Plan members have elected to offer qualified health plans (QHPs) in the Marketplaces in 2015; currently, ACAP members represent 14 percent of all QHP issuers that also participate in the Medicaid program.

Continually changing risk adjustment and reinsurance data requirements in such close proximity to the submission deadline and CCIIO’s technical limitations have put a greater burden on the issuers than was originally anticipated. For example, the XML files that issuers receive in response to their submissions are not usable without the issuer developing code to read the files. This has posed a particular challenge to smaller, safety net health plans. A delay on the April 30th deadline will give insurers the time needed to react to ensure that the data being submitted to the EDGE Sever is accurate and complete.

ACAP urges CCIIO to postpone the submission deadline to Friday, May 29th and also to delay all associated reporting requirements for one month. This includes a one month delay to the MLR reporting requirement and any potential rebates owed enrollees. ACAP also requests that this one-month delay allow for claims run-out until the May 29 date to ensure that plans are not penalized for any claims they may still be receiving from the 2014 benefit year. A suggested timeline is on the next page:

ACAP is grateful to the CCIIO staff, David Loda and Jeff Grant in particular, who by being very accessible and providing us with useful information have helped us support our member plans as they prepare for the final submission deadline. Thank you again for taking the time to consider this request. ACAP is prepared to assist with additional information, if needed. If you have any additional questions please do not hesitate to contact Jennifer Babcock at (202) 204-7518 or


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