Response to 60-day comment

Comment Summary: One comment was received on this information collection request to
decrease the currently approved burden estimates. The commenter opposed continuing
with the manual Enrollment and Payment Data template during State transitions and
expressed concerns about inefficiency and unsustainability. The commenter suggested
using automated and standardized application programming interfaces (APIs).

Response: We acknowledge the commenter’s concerns about streamlining data
collection, improving accuracy and scalability, and reducing administrative burden.
However, we do not believe the issuers’ temporary usage (six months) of the manual
Enrollment and Payment Data template represents a significant increase in administrative
burden. It is also necessary for CMS to have a temporary mechanism upon which it can
compare the newly implemented and automated State-based Exchange (SBE) enrollment
and payment data submission process against issuer submitted data. Once CMS is
assured that the SBE data is reflective of issuer data, this temporary, manual process is
discontinued.