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

Issue Date: October 07, 2014

Program Area: Reinsurance-Contributions (RIC)

Question: For the Actual Count Method, can Contributing Entities use any day within a month to count and tie these membership numbers to the manual payment process through the Centers for Medicare & Medicaid Services (CMS)?

Answer: Applicable to All Reinsurance Contributions Benefit Years: No, the Actual Count Method requires a Contributing Entity to add the total number of lives (enrollees) covered for each day of the first nine (9) months of the benefit year and divide that total by the number of days in those nine (9) months [see 45 CFR153.405(d)(1))]. However, Contributing Entities may want to use a different counting method, such as the Snapshot Count Method, set forth in 45 CFR 153.405(d)(2), if an entity chooses to use only one (1) day per month, if those membership counts include all of the covered lives enrolled in the Contributing Entity's plan(s) and coverage. Please We note that submission for the manual payment process is only for Qualified Health Plans (QHPs), and the requirement to make reinsurance contributions is not limited to enrollment in a QHP. CMS encourages Contributing Entities to review "The Transitional Reinsurance Program Operational Guidance: Counting Method Examples for Contributing Entities." for the applicable benefit year.

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