Crosswalk of Changes

Crosswalk for Changes to the
2016 Unified Rate Review Template Instructions (CMS 10379) Following the
60 Day Comment Period
Table of Contents
A.

Introduction…………………………………………………………………………..1

B.

Changes to 2016 Unified Rate Review Template Instructions………………………1

A. Introduction
CMS received 5 public comments regarding the notice of the revised Unified Rate Review
Template (URRT) PRA package published in the Federal Register on February 19, 2016 (81 FR
8498). The 60-day comment period closed on April 19, 2016. The PRA package contains a
collection of information known as the Rate Filing Justification that issuers must file with the
state and CMS each year. The PRA package modifies the 2015 Instructions to the URRT (Part I
of a Rate Filing Justification), which were previously approved by OMB under OMB Control
Number 0938-1141. The other parts of the Rate Filing Justification, which were also previously
approved under the same OMB Control Number, are not being revised at this time.
B. Changes to URRT Instructions
Most of the comments on the URRT Instructions requested clarification of the instructions and
correction of errors and inconsistencies. The following table contains the list of changes made to
the 2016 URRT Instructions as a result of internal review and in response to comments received
following the 60-day public comment period.

Page 1 of 5

2016 URRT Instructions
Changes Following the 60-Day Comment Period

1

Section
Edited
Title Page

Revision
(Red indicates modified language)
Date changed to January 20, 2015 May 25, 2016

2

Page 4

Updated language to clarify that Part III is required
for all QHP filings and whenever a state or CMS
requires it for non-QHP filings

3

Page 5

Revised the instructions to insert the due date for
proposed rate filings. New language is:
Issuers must submit annual rate filings for both
QHPs and non-QHPs in the single risk pool by the
earlier of: (i) July 15, 2016 or (ii) the date the
State requires.

4

Page 8

5

Page 8

6

Page 9

7

Page 11

Revised the definition of “index rate” to include the
word “allowed.” Definition now reads:

Rationale
In response to
comments; to correct
typographical error
In response to a
comment; to correct
typographical error
In response to a
comment requesting
clarification of due
dates in accordance
with CCIIO Bulletin
that was issued after
60-day comment
period.
In response to a
comment; to correctly
capture definition of
“index rate.”

The Index Rate is the allowed claims costs for
providing Essential Health Benefits (EHBs) within
the single risk pool of that market expressed on a
per member per month basis.
Revised the fourth bullet under Plan Adjusted
In response to a
Index Rate to read:
comment.
Administrative costs, excluding Exchange user
fees and Risk Adjustment user fees (which are
already accounted for in the Market-Wide
Adjusted Index Rate).
In the first sentence of the second paragraph
regarding Calibration, added the phrase “each of.”
The sentence now reads:
“For each of the allowable rating factors of age
and geography, there is only one calibration
allowed.”
Added a new “tip box” to remind issuers to make
sure any formatting of copied and pasted cells into
the URRT uses the correct formatting

Page 2 of 5

In response to a
comment requesting
clarification on
permissible
calibration for rating
factors.
In response to a
comment requesting a
reminder of the
important of correctly
formatting the

8

Page 12

9

Page 13

10

Page 14

Revised language in last paragraph as follows:
Effective Date: This is the effective date for which
rates are being submitted. This field is automatically
populated based on the Effective Date entered in
Row 24 25 of Worksheet 2. All products and plans
must have the same effective date.
Revised language throughout first paragraph of 2.1.2.
to use the term “joint” policy rather than “wrap”
policy.

In the first full paragraph on Page 14, revised
language to read as follows:
Start with premiums earned during the experience
period, including the expected Risk Adjustment
and Risk Corridor receivables or payables.
Subtract the actual or estimated MLR rebates
incurred during the experience period.

11

Page 15

12

Page 25

13

Page 28

14

Page 28

Added a “tip box” to highlight the fact that The index
rate of experience period must be entered as a whole
dollar value. The URRT will not accept decimal
places in this field.

URRT.
In response to a
comment; to correct
typographical error

In response to
comments that
expressed confusion
around the term
“wrap” policy;
changed the language
to use the term
“joint” policy.
In response to
comments, to clarify
how issuers should
report premiums (net
of MLR rebate) in the
experience period.

In response to a
comment; to remind
issuers to enter the
index rate as a whole
dollar value without
decimal places.
Edited instructions in last full paragraph on page 25: In response to a
In prior years, CMS allowed issuers to use a plan
comment; to clarify
averaging option, but that option is no longer
that issuers cannot
available because the trigger for a product being
use a plan average
subject to a threshold increase review occurs at the and should use plan
plan level.
specific projections.
Edited instructions in (1)(b)(iii) to add:
In response to
comments; to clarify
The largest terminating plan should be determined
how issuers should
based on the experience period member months.
determine the “largest
terminating Plan
In response to a
Edited instructions in (3)(b) to read:
comment; to clarify
which plans should
Each single risk pool plan that was effective
be included in
during the experience period, terminated prior to

Page 3 of 5

in the rating period, and not mapped into another
single risk pool plan should be included in
Worksheet 2 in its own column. Information
associated with the experience period should be
included in Section III but Section IV should be
entered as 0 or other appropriate value. See the
Actuarial Memorandum instructions under
“Terminated Plans and Products” for more
information.
15

Page 29

16

Page 29

17

Page 31

18

Page 35

19

Page 37

20

Page 39

Edited instructions in 2.2.1 to read:
The list of single risk pool plans that are
terminated in the projection period prior to the
projection period should be included in the
Actuarial Memorandum.
Added a “tip box” to highlight that HIOS does not
report product names containing special characters.
Consider spelling out name of special characters, e.g.
“20Percent Coinsurance” rather than “20%
Coinsurance.”

Edited instructions for AV Pricing Value:
For non-single risk pool products that are reported
on a combined basis as terminated products prior
to the Projection Period, enter a value of 0 0.01.
Revised language in the “Plan ID” section and
throughout to correctly reflect that Plan IDs contain
14 digits.
On Page 35 revised language:
Plan IDs include four multiple digits
Revised language after “Cumulative Rate Change
Percent (over 12 months prior):
This should be measured as the change in
premium rates tables over the 12 month prior rate
table using the plan’s current distribution of
enrollment by age, geographic area, and tobacco
status.
Revised language after “Average Current Rate
PMPM”:
"In the case of small group rates where a trend is

Page 4 of 5

Worksheet 2

In response to a
comment; to correct
typographical error

In response to a
comment; to provide
clarification on how
issuers should enter
product names to
avoid any HIOS
errors.
In response to a
comment; to correct
typographical error
In response to a
comment; to correct
typographical error

In response to a
comment; to correct
typographical error

Language was
updated in response
to a comment; for
consistency

21

Page 50

filed and approved, the Average Current Rate
PMPM should reflect the latest approved rate, or
the latest rates that are currently under review by
the applicable regulatory agency, or are
anticipated to be submitted.
Revised language in The Net Amount of
Reinsurance Section:

In response to a
comment; to correct
typographical error

As proposed in the 2017 Payment Notice, the
reinsurance program will end with the 2016
benefit year, it is expected issuers will populate
this field will be populated with “0.”
22

23

Page 51

Revised language in fifth bullet:

Page 59

Administrative costs and anticipated profits
margins.
Revised language at top of Page 59:
As proposed in the 2017 Payment Notice, the
reinsurance program will end with the 2016
benefit year, it is expected issuers will populate
this field will be populated with “0” for the 2017
plan year.

Page 5 of 5

In response to
comment

In response to
comment