Hello - I reached out to CMS with the exact same question last week and they confirmed that, YES, they do expect the employer or TPA to attest for the self-insured period (even though the webform does not specifically address a partial reporting period). This was the response:
"You are correct - the employer plan sponsor of the group health plan should attest on its own behalf for the pre-fully-insured period of time from 12/27/20-12/31/21.
And while you are also correct that the GCPCA webform does not have a specific place to enter the dates covered by the attestation when it is less than the entire period from 12/27/20-12/31/23 (or whatever date in 2023 the GCPCA is submitted), the Departments understand that any given attester may only be attesting for a portion of the time covered by the attestation. Similarly, the attestation may be made by an issuer or TPA for reporting entities that were only a client of the attester for a portion of the attestation period, or may only cover a subset of covered plan benefits or agreements covered by the written agreement with the plan, such as when the attester was not under contract with the entities listed on its reporting template for the entire attestation period (the case here when carrier attests for your client), or when the attester only covered some plan offerings while other entities provided the network for other plan offerings. In any of these cases, other entities may attest for the same plan for the remainder of the time period covered by the attestation, or for other product offerings of the plan, as the case may be.
That said, if you client wants to indicate in the "Other" column of the webform the dates covered by its attestation, it may do so.
We plan to address this when we update the Instructions in early 2024 as we are getting asked this question a lot. We will also address it during our upcoming GCPCA webinar on September 28."
Hope that helps!
