Are all issuers required to file a request for reconsideration related to the 2016 Benefit Year Risk Adjustment (RA) and Reinsurance (RI) programs?
Answer:
No. Unlike the attestation and discrepancy reporting process, which required every issuer to submit an attestation (or attest and qualify that attestation with a discrepancy), issuers only need to request reconsideration if an issuer wishes to contest: (1) a processing error by the Department of Health & Human Services (HHS), (2) HHS's incorrect application of the relevant methodology, or (3) HHS's mathematical error related to the final risk adjustment transfers and reinsurance payment amounts. The Centers for Medicare & Medicaid Services (CMS) notes that if an issue was identifiable at the time, issuers must have filed a discrepancy to later request reconsideration on the same issue.
For more information on the reconsideration process, please visit the Registration for Technical Assistance Portal (REGTAP) Library, under the 'ACA Financial Appeals' program area, and review the training titled '2016 Benefit Year Administrative Appeals Process for Risk Adjustment Transfers & Reinsurance Payments' and the 'Request for Reconsideration (RA & RI) Quick Start Guide for the 2016 Benefit Year.
