CMS-10371 - APPENDIX A - Response to comments

APPENDIX A – CMS RESPONSES TO PUBLIC COMMENTS RECEIVED FOR CMS-10371
The Centers for Medicare and Medicaid Services (CMS) received four comments, all from individual
members of the public (four were anonymous), all of which were generally within the scope relative to
CMS-10371. Since the comments were brief, they have all been quoted below along with CMS’s
response.
Comments:
1. The new requirements appear to double the workload of this already extensive report. We believe
CMS has significantly underestimated the level of effort required for States to develop this report and
the burden it places on States.
2. The window for a State to generate the current version of the OE Expanded Priority report is already
short and does not properly allow for any technical challenges and extended internal QA and review
time. CMS is suggesting that the metrics be doubled. How long will States now be given to produce
this report after OE ends?
3. Gender vs. Sex Assigned at Birth: Some of the proposed metrics in the OE Expanded Priority report
continue to reference "gender," while the current (non SOGI) data collection focuses on "sex assigned
at birth." We recommend aligning the terminology of the current and proposed gender metrics to
prevent confusion and ensure consistency across reporting and data collection systems.
4. Some of the proposed changes to the OE Expanded Priority metrics lack clarity or appear inconsistent
with current practices.
For example:
a. Reporting on the CSRs applied to non-silver plans (unless referring to AI/AN plans with CSRs)
b. Reporting on APTC applied to catastrophic plans
If proposed changes are imposed, we request clear definitions and explanations for these metrics to
ensure accurate reporting.
Response:
1. Thank you for your feedback. We acknowledge the increase in workload and will take this into
consideration. Please note that not all changes would be implemented immediately after PRA
finalization. Prior to making additions to the current SBM Expanded and Bi-Annual reporting
templates, CMS will collaborate with SBM teams for feedback on any potential additional data
requirements and reporting timelines.
2. Thank you for your feedback. We acknowledge the increase in workload and will take this into
consideration. Please note that not all changes would be implemented immediately after PRA
finalization. Prior to making additions to the current SBM Expanded and Bi-Annual reporting
templates, CMS will collaborate with SBM teams for feedback on any potential additional data
requirements and reporting timelines.
3. Thank you for your feedback. We will take this into consideration. The Metal Level by Financial
breakouts were intended to align with HealthCare.gov reporting in the current Public Use Files.

Additionally, CMS intends to remove the relevant financial breakouts for catastrophic plans. Prior to
making additions to the current SBM Expanded and Bi-Annual reporting templates, CMS will also
collaborate with SBM teams for feedback on current SBM operational practices to align reporting
definitions.
4. Thank you for your feedback. We will take this into consideration to align reporting terminology with
the HealthCare.gov application, SBM applications, and current directives.