"[F]or consistency in MLR reporting not only among issuers, but also between the commercial and Medicare markets, we encourage CMS to state explicitly within the instructions for the Medicare MLR report that the following questions [from previously-issued FAQs] apply to Medicare MLR as well. If guidance on any of these items for Medicare MLR is not to remain consistent with the applicable guidance for commercial plans, it would be helpful for CMS to provide an explanation of the differences, possibly through a notice of rulemaking process with an opportunity for public comment." [FAQs cited in this letter were issued by CCIIO on May 13, 2011, July 18, 2011, and February 10, 2012.]  MORE >>