Reconciliation

User Roles:

AM

AR

D

V

Program Components:

Reconciliation

This page contains answers to Common Questions about Reconciliation. Review this page to learn about how to complete Reconciliation, when an application is ready for Reconciliation, and more. For additional information refer to the Reconciliation section of the RDS User Guide.

What is Reconciliation?

ANSWER: Within 15 months after the application Plan Year End Date, Plan Sponsors complete Reconciliation to finalize their application’s Covered Retiree List and submit final cost data to CMS' RDS Center. If the Plan Sponsor did not select an Interim Payment Frequency, it must use the Reconciliation process to request its annual payment.

Note: All RDS applications have a maximum payment frequency of monthly interim payments, consistent with the general payment rules regarding timing set forth in 42 C.F.R. 423.888(b)(1). Although 12 interim payment requests are permitted, a Plan Sponsor may choose to submit fewer than 12 interim payment requests, or forego interim payments and instead choose to submit one final payment request during Reconciliation as described in 42 C.F.R. 423.888(b)(2)(ii).

Answer ID: 1000-1
Date Updated: 4/15/2022

Return to top

What is the Reconciliation Deadline?

ANSWER: The Reconciliation Deadline is the date by which a Plan Sponsor must complete Reconciliation. The Reconciliation Deadline is calculated as the last day of the fifteenth month after the Plan Year End Date (adjusted for Federal holidays and weekends). For Reconciliation Deadline dates, refer to Important Reconciliation Deadline Information. If interim payments were received and the Plan Sponsor does not complete Reconciliation by the Reconciliation Deadline, the sum of all payments received will become an overpayment, and CMS will initiate immediate action to recover those funds. Plan Sponsors that fail to meet the Reconciliation Deadline for a given application and have not received interim payments for that application will not be eligible for any subsidy payments for that application.

Answer ID: 1000-2
Date Updated: 1/08/2015

Return to top

Where can I find my Reconciliation Deadline?

ANSWER: For easy reference, the Reconciliation Deadline displays in several locations throughout the RDS Secure Website. On the Dashboard page, for each of the Plan Sponsor’s applications, the Reconciliation Deadline displays as a column in the Applications table. This is true for In Progress, Completed, and Archived applications. On the Application Overview page, the Reconciliation Deadline displays as a line item in the Plan Sponsor section. The Reconciliation Deadline also displays as a line item on the Reconciliation page.

For Reconciliation Deadline dates, refer to Important Reconciliation Deadline Information.

Answer ID: 1000-3
Date Updated: 4/15/2022

Return to top

What is the Reconciliation Agreement?

ANSWER: The Reconciliation Agreement is an agreement with payment information that displays for and must be signed by the Authorized Representative when submitting a Reconciliation payment request. The Reconciliation Agreement must be completed in the RDS Secure Website. Refer to the Agreements page to review the text of the Reconciliation Agreement.

Answer ID: 1000-4
Date Updated: 4/15/2022

Return to top

What happens if I miss the Reconciliation Deadline?

ANSWER: For Plan Sponsors that fail to meet their Reconciliation Deadline for a given application and have received interim payments for that application, the sum of those payments becomes an overpayment, and CMS initiates immediate overpayment recovery action.

Plan Sponsors that fail to meet the Reconciliation Deadline for a given application and have not received interim payments for that application will not be eligible for any subsidy payments for that application. 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.

Answer ID: 1000-5
Date Updated: 4/15/2022

Return to top

Who is responsible for completing Reconciliation?

ANSWER: Reconciliation steps are completed by a combination of individuals that include a Plan Sponsor's internal resources (such as the Account Manager, Authorized Representative, and Designee with Request Payment, Report Costs, or View/Send/Receive Retiree Data privilege) along with external resources such as Vendors who may be responsible for cost reporting, and a Plan Sponsor's banking institution.

For more information about user roles in Reconciliation, refer to Reconciliation Overview.

Answer ID: 1000-6
Date Updated: 4/15/2022

Return to top

What are the Reconciliation steps?

ANSWER: Reconciliation consists of the following steps:

Refer to the Reconciliation section of the RDS User Guide for overview information and step-by-step instructions to complete each step.

Answer ID: 1000-7
Date Updated: 4/15/2022

Return to top

When is my application ready for Reconciliation?

ANSWER: An RDS application is ready for Reconciliation when the following conditions are met.

  • The status of the application must be "Approved."
  • The application plan year has ended.
  • All desired interim payment requests have either been processed or canceled. (The maximum number of interim payment requests does not have to be used before initiating Reconciliation.)
  • At least 15 calendar days have passed from the date of the last interim payment determination.
    • Note: It is recommended that Plan Sponsors stop interim payments at least 60 days prior to an application's Reconciliation Deadline to focus on Reconciliation activities.
  • The Reconciliation Deadline has not passed.

Note: After Reconciliation is initiated it cannot be reversed.

For more information, refer to the Reconciliation Toolkit.

Answer ID: 1000-8
Date Updated: 4/15/2022

Return to top

What is the meaning of the icons next to Reconciliation steps in the Left Navigation Menu?

ANSWER: Icons appear next to each Reconciliation step on the Left Navigation Menu: 

  • Green check mark - The step has been completed and no errors or warnings are identified on the page
  • Red exclamation point - The step is incomplete and an error and/or warning has been identified on the page.

Answer ID: 1000-9
Date Updated: 4/15/2022

Return to top

How do I complete Reconciliation?

ANSWER: The RDS Program Website offers a number of resources to assist Plan Sponsors with completing Reconciliation:

Answer ID: 1000-11
Date Posted: 10/17/2014

Return to top

What should I do if there are changes to my application’s Qualifying Covered Retirees, but I’ve already completed Reconciliation: Finalize Covered Retirees for the application?

ANSWER: Despite a Plan Sponsor's best efforts to ensure that the retiree data reflected in the Covered Retiree List (CRL) is accurate, there may be instances where a Plan Sponsor becomes aware of changes to its Qualifying Covered Retirees (QCRs) after it has completed Reconciliation: Finalize Covered Retirees, but before it has completed Reconciliation: Review & Submit. In such cases, the Account Manager or Authorized Representative can reset Reconciliation using the RDS Secure Website. If the request is submitted timely, Reconciliation: Finalize Covered Retirees is changed to an "Incomplete" status after completion and ALL subsequent Reconciliation steps that were previously completed for the application—beginning with Reconciliation: Finalize Covered Retirees—are changed to an "Incomplete" status and must be completed again. However, the application's Reconciliation Deadline date does not change.

For more information, refer to Resetting Reconciliation and Step-by-Step Instructions: Reset Reconciliation.

Answer ID: 1000-12
Date Posted: 8/17/2022

Return to top