Important Reconciliation Deadline Information
All Plan Sponsors with Retiree Drug Subsidy (RDS) applications for plan years ending in 2006 (with payment reconciliation deadlines of March 31, 2008) have been afforded additional time and have a new reconciliation deadline of June 30, 2008. This additional time applies to calendar and non-calendar year RDS applications that have plan years ending in 2006. Also, Plan Sponsors with RDS applications that have plan years ending in the first quarter of calendar year 2007 (January, February, March 2007) have been afforded additional time equivalent to that given 2006 plan years (an additional 3 months) and have a new reconciliation deadline of July 31, August 31, or September 30, 2008, respectively.
For Plan Sponsors with RDS applications with plan years ending on or after April 1, 2007, the reconciliation deadline will remain unchanged. That deadline will remain the last day of the fifteenth month following the last day of the RDS plan year specified in the application.
Please be advised that Plan Sponsors with a 2006 or 2007 application affected by this notice that fail to meet the new reconciliation deadlines above will not be granted any additional time to complete reconciliation (i.e., CMS will not provide a longer time limit and no Plan Sponsor requests for deadline extensions will be considered).
For Plan Sponsors with 2006 or 2007 applications affected by this notice that fail to meet the new deadlines above and have received interim payments for these applications, the sum of those payments will become overpayments and CMS will initiate immediate overpayment recovery action. Plan Sponsors with 2006 or 2007 applications affected by this notice that fail to meet the new deadlines above and have not received interim payments will not be eligible for any subsidy payments for those applications. 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.
| Plan Year Ended In... | Previous Deadline | New Deadline |
|---|---|---|
| January - December 2006 | March 31, 2008 | June 30, 2008 |
| January 2007 | April 30, 2008 | July 31, 2008 |
| February 2007 | May 31, 2008 | August 31, 2008 |
| March 2007 | June 30, 2008 | September 30, 2008 |
