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

Issue Date: October 07, 2014

Program Area: Reinsurance-Contributions (RIC)

Question: For reinsurance membership counts, can Contributing Entities use the membership counts at the 15 for each of the nine (9) months that correspond with the Centers for Medicare & Medicaid Services' (CMS') Enrollment and Payment template for payment of Advanced Premium Tax Credit (APTC) and Cost Sharing Reduction (CSR)?

Answer: Applicable to All Reinsurance Contributions Benefit Years: Yes, if the date falls within the same week of the month of the quarter, the membership counts include all of the covered lives enrolled in the Contributing Entity's plan(s) and coverage and the Contributing Entity uses the Snapshot Count Method described in 45 CFR 153.405(d)(2). Please 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. Under the Snapshot Count Method, to determine the number of covered lives of reinsurance contribution enrollees under a health insurance plan for a benefit year, a health insurance issuer must add the total number of lives covered on any date (or more dates, if an equal number of dates are used for each quarter) during the same corresponding month in each of the first three (3) quarters of the benefit year, and dividing that total by the number of dates on which a count was made. For this purpose, the same months must be used for each quarter (for example January, April and July) and the date used for the second and third quarter must fall within the same week of the quarter as the corresponding date used for the first quarter. Contributing Entities may also reference "The Transitional Reinsurance Program Operational Guidance: Counting Method Examples for Contributing Entities" for the applicable benefit year.

HHS is committed to making its websites and documents accessible to the widest possible audience, including individuals with disabilities. We are in the process of retroactively making some documents accessible. If you need assistance accessing an accessible version of this document, please reach out to the guidance@hhs.gov.

DISCLAIMER: The contents of this database lack the force and effect of law, except as authorized by law (including Medicare Advantage Rate Announcements and Advance Notices) or as specifically incorporated into a contract. The Department may not cite, use, or rely on any guidance that is not posted on the guidance repository, except to establish historical facts.