How To Attest Actuarial Equivalence - Updated 07/24/07
The following document describes the Retiree Drug Subsidy (RDS) Actuarial Attestation process and step-by-step instructions on how to complete an attestation of actuarial equivalence on the RDS Secure Web Site. Specifically, this document includes information for an Actuary about the following:
- Has CMS issued any guidance on the Actuarial Equivalence Standard for the RDS Program?
- How do I get assigned to complete the attestation of actuarial equivalence?
- What tests might I use to determine actuarial equivalence?
- How do I register on the RDS Secure Web Site?
- How may I get help if I have difficulty registering?
- How will I know what to attest to?
- How do I complete the attestation?
- Must the attestation of actuarial equivalence be completed before an RDS application may be submitted?
- How will the Plan Sponsor know I have completed my attestations?
- Other than the issue of actuarial equivalence, is there any other application information I need to review?
Has CMS' issued any guidance on the Actuarial Equivalence Standard for the RDS Program?
The Centers for Medicare & Medicaid Services (CMS) has issued Actuarial Equivalence Standard guidance which can be found on the CMS web site at http://www.cms.hhs.gov/EmployerRetireeDrugSubsid/.
How do I get assigned to complete the attestation of actuarial equivalence?
Before a Plan Sponsor may assign an Actuary, they must first define all the benefit options that are included in the application. See below.
Depending on whether a Plan Sponsor is combining two or more benefit options for the net test, actuaries will either be assigned to attest to both the gross and net value of each benefit option, or the gross value for each benefit option, and one net value test for the combined benefit options.
The Plan Sponsor (Account Manager, Authorized Representative, or Designee) will assign you to complete the actuarial attestation. Please make sure that the Plan Sponsor has the following information:
- Your name (exactly as it is on file with the American Academy of Actuaries).
- Your correct e-mail address.
- Your American Academy of Actuaries membership number.
This information is needed by the Plan Sponsor to make the Actuary assignment in the RDS Secure Web Site. Specifically, the Plan Sponsor will provide this information in the Add Actuary page.
Plan Sponsors must provide CMS with an attestation that the actuarial value of the retiree prescription drug coverage is at least equal to the actuarial value of the standard prescription drug coverage under Medicare Part D (actuarial equivalence).
At the time you are assigned, the following actions will be determined:
- What benefit option, or options, you are permitted to attest to?
- For plans with more than one benefit option, actuaries must be assigned to each benefit option or combination thereof. You may be assigned to attest to one, or several, or all options for an application.
- What test, or tests, will be used to determine actuarial equivalence?
- Two possible test options may be used for each benefit option or combination. Your assignment will specify which test option you are to use for each benefit option that you have been assigned.
What tests might I use to determine actuarial equivalence?
The two test options an actuary may use are:
- For single Benefit Options - A "gross and net" value test for each benefit option. The gross test would confirm that the total value of benefits provided to the beneficiary under the employer plan is at least as generous as what they could receive under Medicare Part D. The "net" value test takes into account the extent of the employer financing of the drug coverage so that the net value of the employer plan to the beneficiary is at least equal to the net value of what they would receive under Medicare Part D.
- For combined benefit options - A "gross" value test for each separate option and a "net" value test for the combined options.
How do I register on the RDS Secure Web Site?
After you have been assigned as an actuary for an application, you will receive an e-mail invitation notifying you of your selection and inviting you to register to request a Login ID and password for the RDS Secure Web Site.
The text of the e-mail follows:
cc: AM, D (if applicable, i.e. if the designee invites the actuary)
Dear AC,
XYZ Corporation is a participant in the Medicare Retiree Drug Subsidy (RDS) program and you have been assigned as its Actuary. You will be responsible for attesting to the Part D equivalence of the identified plan.
If you already have a Login ID and password to the RDS Secure Web Site, use that Login ID and password to sign on at CMS' RDS Center web site [http://rds.cms.hhs.gov/].
If you do not have a Login ID, please go to the Actuary Registration page [ www.actuary_registration.html] to complete the Login ID creation FIRST.
If you have questions, please call the RDS Help Line at (877) RDS-HELP, or (877) 737-4357. TTY for the hearing impaired: (877) RDS-TTY0, or (877) 737-8890.
Sincerely,
CMS' RDS Center
Please Note: This e-mail message was sent from a notification-only address that cannot receive incoming e-mail, so please do not reply to the e-mail.
Your e-mail will also contain a link to the Actuary Registration page as shown below. Click the link if you have not yet registered on the RDS Secure Web Site, and do not have a Login ID and Password. You will only need to register once. After your initial registration, you can simply login and attest to any application you are assigned without the registration step. Each time you are assigned to an application, you will receive the above-mentioned e-mail informing you about the Plan Sponsor who assigned you.
Note: The upper right hand corner of each registration page has a navigation map that will indicate where you are in the registration process. This map also contains an active link to page-specific help.
To register, an actuary must follow the steps below:
- Enter your American Academy of Actuaries number.
- Read the User Agreement and Privacy Policy. When you have finished reading these, click the I accept the User Agreement and Privacy Policy above box.
- Click the Continue button to proceed.
Note: You may select the Cancel button to stop the process and return to it at a later time. - Enter your personal information on the Actuary
Personal Information page as shown below.
Note: When registering for the RDS Secure Web Site, you must enter your name exactly as it is on file with the American Academy of Actuaries. - When you have entered the required and/or optional personal information relating to you and/or your company, click the Continue button to proceed to the Actuary Login Information page shown below.
- Enter the Login ID, password, and select security questions and answers that you would like to identify you on the RDS Secure Web Site. Please make note of your Security answers. You will need to provide these answers at the time of attestation for authentication purposes.
- When you have entered the required information, click the Continue button to proceed to the Actuary Summary page shown below.
- Check the information displayed for accuracy. You may edit the information by clicking on the Edit button. That action will return you to the Actuary Personal Information page illustrated in Step 4 above.
- The RDS
System will display a personalized Thank You
page as shown below. Please print this page for your records.
- Clicking on the Exit button will return you to CMS' RDS Center home page (http://rds.cms.hhs.gov). From the home page you can immediately log into the RDS Secure Web Site using your RDS Login ID and password. The Actuary registration process is "real time," so once the actuary registration pages are successfully submitted, you may immediately begin using the RDS Secure Web Site.
How may I get help if I have difficulty registering?
Page-specific help is available during the registration process. These help pages will provide guidance and answers for most of your questions.
CMS' RDS Center home page (http://rds.cms.hhs.gov) contains a wealth of information and links on the RDS program. Similarly, this information may answer most of your questions.
In addition, the RDS Customer Service Center is available if you need further assistance. You can reach the Customer Service Center by calling:
- (877) RDS-HELP or (877) 737-4357
- (877) RDS-TTYO or (877) 737-8890
Finally, the American Academy of Actuaries home page (http://www.actuary.org) has additional help in the "Tools for Medicare Rx work" section.
How will I know what to attest to?
The test option (or options) and the benefit option (or options) that you have been assigned will be shown on the Application Summary page. This page will be discussed in detail in the How do I complete the attestation? instructions.
An example of this page is shown below to illustrate how the benefit option(s) and test(s) appear.
In the sample page shown, the benefit options are combined and the test to be applied is the gross value test. The example implies that another actuary has been assigned for the net value test, which would be required for combined benefit options.
How do I complete the attestation?
An assigned actuary must first accept the e-mail registration invitation and complete the registration process to get a Login ID and Password for the RDS Secure Web Site. This process need only be completed ONCE. Your Login ID and Password can then be used to attest to each application/option to which you have been assigned.
To attest to the actuarial equivalence of a plan (or benefit option within a plan), an assigned and registered actuary must follow the process outlined below:
- Go to CMS' RDS Center home page (http://rds.cms.hhs.gov) and enter your Login ID and Password to access the RDS Secure Web Site.
- The Actuary Home page displays as shown below.
- Click on the Plan Sponsor ID to access information on the application (or applications) to which you have been assigned.
- The Plan Sponsor ID page displays as
shown below.
Note: If more than one actuary has been assigned to attest to the benefit options in this plan and one of them has already submitted their attestation you will notice that the Attestation Status column will have Attested as the status. This notice does not affect your attestations. - Click on the App Number link (this is the RDS application number that contains the benefit option(s) you have been assigned to attest to). This will bring you to the Attestation Summary page that applies to you.
- On the Attestation Summary page, click the Attest Now link.
- The Attestation page displays as shown below. To complete the attestation you must:
- Click the Attest Now box.
- Answer both security questions.
- Please note that the answer fields are case sensitive.
- Click the Continue button.
- The Continue button will return you to the Attestation Summary page shown below. The benefit option you have attested to will now been shown as Attested.
- To exit this page, click on the Home link in the top navigation bar. This will return you to CMS' RDS Center home page.
Must the attestation of actuarial equivalence be completed before an RDS application may be submitted?
Yes. All necessary attestations of actuarial equivalence must be completed by the assigned actuary(ies) before the RDS application can be submitted.
How will the Plan Sponsor know I have completed my attestations?
The Plan Sponsor (and those authorized by the Plan Sponsor to work on the application) can access the Application List page to determine whether or not a specific attestation has been completed. A sample page is shown below. (In the sample, the actuary assigned has completed the attestation of actuarial equivalence.)
This completes the process the Actuary uses to provide his or her attestation of actuarial equivalence for a Plan Sponsor benefit option.
Other than the issue of actuarial equivalence, is there any other application information I need to review?
Yes. Before attesting to the actuarial equivalence of the plan in the RDS Secure Web Site, you should review the plan year start and end dates to ensure they are accurate for the plan for which you are providing the attestation. Additionally, for each benefit option for which you are attesting, verify the benefit option plan design (whether self funded or fully insured) to assure the accuracy of the attestation.
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