For Plan Sponsors that fail to meet their Reconciliation Deadline for a given application and have received interim payments for that application, the sum of those payments becomes an overpayment, and CMS initiates immediate overpayment recovery action.
Plan Sponsors that fail to meet the Reconciliation Deadline for a given application and have not received interim payments for that application will not be eligible for any subsidy payments for that application. CMS' decision whether or not to afford additional time for Reconciliation or to deny a request for extension of the Reconciliation time limit is not subject to appeal.