The H.R. 5376 Inflation Reduction Act of 2022 (IRA) was signed into law by President Biden on August 16th, 2022. The IRA makes improvements to Medicare that will expand benefits, lower drug costs, keep prescription drug premiums stable, and improve the strength of the Medicare program. CMS’ RDS Center wants to hear from you—the RDS users—about the impact of IRA on the RDS Plan Sponsor community. We are currently recruiting volunteers for Listening Sessions on this topic. If you are a current, active RDS Secure Website user assigned to at least one RDS Plan Sponsor account and/or application and are interested in participating in this initiative, please review the material below and email CMS’ RDS Center by Monday, April 3, 2023, to express your interest in volunteering.
Announcements
Authorized Representatives: Confirm your access to the RDS Secure Website now! To avoid missed program deadlines and delayed subsidy payments, ensure that your RDS user accounts and Multi-Factor Authentication (MFA) are active and that you are able to access the RDS Secure Website today!
In the coming months, CMS’ RDS Center will implement two new Reason Codes that will be used to communicate RDS eligibility information during retiree data transfers. These codes will support the conditions defined in 42 CFR § 423.4 stating that a retiree is not eligible for RDS subsidy when: the retiree is not legally present in the United States and/or the retiree is incarcerated.
If a Plan Sponsor decides to submit interim payment requests, it must adhere to all terms and conditions specified in the Interim Payment Agreement. Please do not wait until Reconciliation to make sure your data is accurate. Submit “true, accurate, and complete” retiree lists and cost reports throughout the plan year, whenever your Plan Sponsor makes an interim payment request.
Starting today, January 16, 2023, Retiree Drug Subsidy (RDS) Plan Sponsors will now utilize the new CMS Office of Hearings Case and Document Management System (OH CDMS) for their Second Level Appeals. The OH CDMS is a web-based portal for RDS Plan Sponsors to submit and maintain their Second Level Informal Hearing Appeals and to correspond with the CMS Hearing Officer. This information is only relevant to Plan Sponsors who pursue an RDS Second Level Appeal. In support of this change, CMS’ RDS Center has published updated educational materials as well. Because the OH CDMS portal falls entirely outside of the RDS Program’s purview, CMS’ RDS Center will not provide technical support for this web application.
On January 16, 2023, the new CMS Office of Hearings Case and Document Management System (OH CDMS) will become available for RDS Plan Sponsors pursuing RDS Second Level Appeals. The OH CDMS is a web-based portal for RDS Plan Sponsors to submit and manage their Second Level Informal Hearing Appeals and to correspond with the CMS Hearing Officer. This information is only relevant to Plan Sponsors who pursue an RDS Second Level Appeal. This Second Level Appeal process change will not be relevant to First Level Reconsiderations or to Third Level Administrator Reviews.
RDS Spotlight
As a requirement of Reconciliation, Plan Sponsors must finalize their application's Covered Retiree List (CRL) and submit final cost data to CMS' RDS Center. Please review the following guidance and resources for successfully reporting final costs during Reconciliation.
As a requirement of Reconciliation, Plan Sponsors must finalize their application's Covered Retiree List (CRL) and submit final cost data to CMS' RDS Center. Please review the following guidance and resources for successfully finalizing your application’s retiree count during Reconciliation.
In preparation for the final Reconciliation payment request, the Plan Sponsor agrees to the CRL in the Reconciliation: Finalize Covered Retirees step by completing the following tasks:
To avoid missed Reconciliation Deadlines and delayed subsidy payments, ensure that your RDS user accounts and Multi-Factor Authentication (MFA) are active and that you are able to access the RDS Secure Website today! Please encourage all users assigned to your RDS application(s) to log in to the Secure Website as soon as possible, and well in advance of your deadline date.
Review the summary of Reconciliation steps and the user roles responsible for completing each step. Know your responsibilities during Reconciliation, coordinate with other Plan Sponsor users and vendors (if applicable), and protect your Plan Sponsor’s subsidy!
The busiest RDS Reconciliation season is approaching – within 15 months after the application Plan Year End Date, Plan Sponsors must complete Reconciliation to finalize their application's Covered Retiree List and submit final cost data to CMS' RDS Center. This is a requirement for each application for which the Plan Sponsor is seeking subsidy. As such, now is the perfect time to familiarize yourself and your Plan Sponsor organization with the new, modernized Reconciliation process in the RDS Secure Website.
The Annual Plan Year Application is the fundamental component of the Retiree Drug Subsidy (RDS) Program. In the modernized RDS Secure Website, Plan Sponsors can create new applications in two different ways. Regardless of how the Plan Sponsor chooses to create an application, certain required application information must be defined for an application to be considered complete and RDS eligible. Much of this required application information is defined during the Application Submission Process, before submission, whereas other required application information cannot be defined until an application is approved, after submission.
