CMS' RDS Center is pleased to announce that beginning May 8, 2020, all RDS applications' Payment Frequency will be set to a maximum frequency of monthly interim payments, consistent with the general payment rules regarding timing set forth in 42 C.F.R. 423.888(b)(1). This enhancement will be applied to all current and active RDS applications, as well as all future RDS applications. Plan Sponsors who had previously selected the Quarterly or Annual Payment Frequency option on their current applications will now be eligible to submit interim costs and request interim payments more frequently than quarterly or annually, if so desired. No action is required on the part of the Plan Sponsor or its Vendors to implement this new feature.
The Interim Monthly Payment Frequency allows Plan Sponsors to make a maximum of 12 interim payment requests for a plan year. Although 12 interim payment requests are permitted, a Plan Sponsor may choose to submit fewer than 12 interim payment requests. The first payment request may be submitted as early as one month from the start of the plan year after interim costs have been reported. Subsequent payment requests may be made if 16 days have passed since the last payment approval (if the payment amount was greater than zero), or if 31 days have passed since the last payment request, whichever date is later. A Plan Sponsor is notified through email when a payment request is approved. Plan Sponsors may not submit an interim monthly payment request once payment Reconciliation has been initiated. Plan Sponsors are required to submit a Reconciliation payment request by the Reconciliation Deadline, consistent with 42 C.F.R. 423.888(b)(4). The Interim Payment process is described in the Interim Payment section of the RDS User Guide and includes step-by-step instructions.
Consistent with current practice, a Plan Sponsor may forego interim payments and instead choose to submit one final payment using the RDS Secure Website payment Reconciliation feature. See 42 C.F.R. 423.888(b)(2)(ii). The one-time final payment request is described in the Reconciliation section of the RDS User Guide.
During the RDS Annual Plan Application process, Step 6: Payment Frequency will be modified to reflect the changes described in this announcement. The Account Manager, Authorized Representative, or Designee with the Define Payment Frequency privilege may complete Step 6 of the Application Submission. Plan Sponsors are encouraged to review their application's Payment Setup to ensure the appropriate cost reporters and payment requestors have been correctly established. Please refer to the RDS User Guide: Information Required to Complete an Application section for additional helpful information.
CMS' RDS Center strongly encourages Plan Sponsors to review the information contained in the Avoid an Overpayment at Reconciliation section of the RDS User Guide. An overpayment occurs when the sum of all interim payments received for an application exceeds the sum of the Reconciliation payment request. There are many scenarios which can lead to an overpayment, however the information included in this section explores the most common reasons for an overpayment, and explains how to avoid an overpayment situation at Reconciliation. CMS' RDS Center understands that not all overpayments can be avoided. Nevertheless, carefully reviewing your cost data prior to submission can dramatically reduce unnecessary overpayments.
If you need more information, please contact CMS' RDS Center.