The Precisely whitepaper on Policy-based Payment Reconciliation explains that direct payments from CMS to issuers place full responsibility on issuers for the accuracy of their data, as no adjustments will be made based on issuer calculations. CMS uses the Healthcare Insurance Exchange (HIX) 820 transaction to communicate remittance information for payments such as Advance Payment of Premium Tax Credits (APTCs), Cost Sharing Reductions (CSRs), user fees, and reinsurance or risk adjustments. A key challenge in this process is the frequent need for payers to reconcile their data with monthly government-issued HIX 820 files received via Electronic File Transfer (EFT), especially given errors caused by manual or semi-automated processes, which can strain internal reconciliation efforts.

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