Letter to CMS on Cost-Sharing Reduction Reconciliation Reporting Requirements

The Association for Community Affiliated Plans (ACAP) thanks you for considering our comments and requests for clarification on CMS form 10526 related to cost sharing reduction (CSR) reconciliation reporting requirements.

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 11 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 onethird of all Medicaid managed care enrollees. Sixteen of ACAP’s Safety Net Health Plan members have elected to participate in the Marketplaces in 2014.

ACAP’s Concerns: General questions and concerns about the cost sharing reduction (CSR) reconciliation reports, form number CMS-10526, are listed below:

 As part of the interim payment process for Advance Premium and Tax Credit (APTC) and CSR, HHS is currently aggregating payments at the qualified health plan level. We request CMS provide data regarding CSR payment amounts at the member-level to aid the plans in reconciliation. Issuers will be required to report member-level enrollment and claims information, for those issuers implementing the standard methodology, in particular, member-level CSR payments will help ensure accurate reconciliation.

 The reporting requirements do not specify how issuers should report on fields that are not related to their products. If an issuer is leaving a field blanks, what value, if any should be input into the cell (i.e. “0”, “N/A”)?

 In what format will the CSR Reconciliation Data Template be required to be submitted (i.e. delimited file)? ACAP requests that this template be developed similar to the CMS Marketplace Payments template currently in use during FY 2014.

 As with all communications with issuers, ACAP requests that CMS specify which, if any, requirements are specific to the federally facilitated marketplace (FFM) or state-based marketplaces (SBM). Please coordinate with the SBMs to ensure that definitions for requirements such as “File ID” on the Issuer Summary Report take any SBM definitions into consideration as necessary.


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