March 2016 Retiree Drug Subsidy (RDS) Webinar: RDS Program Highlights

CMS’ RDS Center hosted a webinar on Wednesday, March 9 to provide the Plan Sponsor community with an overview of recent program changes, as well as reminders to help them successfully participate.

The webinar covered the following topics:

Review these topics for a summary of the information presented, as well as links to recommended resources.

Webinar Topics

What’s New In RDS

Participants were provided an overview of the following recent and upcoming program changes:

  • Appeals Reopening Functionality: The new appeals functionality allows Plan Sponsors to request a reopening using the RDS Secure Website rather than by sending a hard copy request. Participants were reminded to no longer mail in requests. In addition to the new reopening functionality, Plan Sponsors can also upload and view supporting documentation using the RDS Secure Website. For instructions on completing these tasks, review the Appeal an Initial Determination section of the RDS User Guide.
  • No Interim Payments 60 Days Before the Reconciliation Deadline: Participants reviewed the new system edit that prevents Plan Sponsors from submitting an interim payment request in the final 60 calendar days before an application’s Reconciliation Deadline. An error now displays on the Build Interim Payment Request page when a payment requester attempts to request payment in the 60 calendar days before the Reconciliation Deadline.
  • Maximum Gross Eligible Error in Reconciliation Step 7: CMS’ RDS Center discussed the new system edit that was implemented in Step 7 of the Reconciliation process. If the reported Gross Eligible costs exceed the maximum Gross Eligible amount possible for the application based on the number of retirees contributing to the Threshold Reduction, the RDS Secure Website displays an error message, and the Plan Sponsor is prevented from completing Step 7. This new edit helps to ensure final costs are accurate during Reconciliation.
  • Payment On Hold Notifications: Participants reviewed the new email notification that is sent if there is an issue with the Account Manager’s or Authorized Representative’s user account at the time CMS’ RDS Center attempts to make payment. If an issue is detected (for example, if the Account Manager’s or the Authorized Representative’s user account is disabled), the payment request is placed on hold, and the Plan Sponsor receives an email explaining how to resolve the user account issue so that the payment request may resume processing. The email provides specific links to step-by-step instructions in the RDS User Guide to help expedite resolving the account issue. A number of issues can exist on one or both user accounts, and, depending on the scenario, the Account Manager, Authorized Representative, and/or Designee with the Request Payment privilege on the application receives an email.
  • Upcoming Change of Address for Sending Overpayments: CMS’ RDS Center discussed the upcoming change of address for sending an overpayment remittance. When it is determined that there has been an overpayment on an application, CMS’ RDS Center notifies the Plan Sponsor through email. If there are no other applications available to offset the overpayment, the Plan Sponsor must remit payment by mailing in either a check or money order. CMS’ RDS Center will publish an announcement on the RDS Program Website when the change has taken effect.

Important Program Reminders

Participants reviewed the following important program reminders to help with successfully participating in the program:

  • Keep Contact Information Up to Date: CMS’ RDS Center discussed how important it is to keep contact information up to date. CMS’ RDS Center communicates with the Plan Sponsor community through email, so it is especially important for participants to keep email addresses up to date. CMS’ RDS Center sends responses to support requests, Application and Reconciliation Deadline reminders, and notifications when user and banking information is changed and when certain tasks are completed. If users need to update their information, they may log in to the RDS Secure Website and update it using the Manage User Information link in the Account Settings box.
  • Protect Your Information: Participants were reminded to protect not only their RDS Secure Website user account information, but also all personal and sensitive information by being wary of malicious activity, links, and emails. Suspicious activity or information received should be reported to the organization’s security department.
  •  Support Requests: CMS’ RDS Center reviewed the RDS Secure Website support request functionality that was introduced in January 2015. Support requests allow users to ask a question or document an issue from anywhere in the RDS Secure Website. Requests are assigned a unique reference number and responded to through email within one business day. For more information on support requests, refer to Submit or Reopen a Support Request in the RDS User Guide.
  • User Automation: Participants reviewed the user automation functionality that was implemented at the end of 2014 to give users more control over their accounts. Users are able to verify and correct their email address, enable their user account, and request their Login ID without needing to contact CMS’ RDS Center.

Timely Reconciliation Reminders

CMS’ RDS Center discussed the following Reconciliation reminders and some of the most common Reconciliation issues. Tips for many of the points discussed are available in the Technical Article Navigating Reconciliation: Timely Tips and Reminders.

  • Know the Reconciliation Deadline: Participants were reminded how important it is to know the application’s Reconciliation Deadline. The Reconciliation Deadline is approximately 15 months after the application Plan Year End Date. The Reconciliation Deadline displays in the Details box on all Reconciliation pages including the Reconciliation Checklist page. The Reconciliation Deadline may also be viewed from the Application Status page, any page that displays the Application Information box, or the Benefit Option Final Cost List page. Additional time is not granted for Reconciliation (no extensions will be granted). If the Reconciliation Deadline is missed, interim payments will become overpayments, and CMS will initiate immediate overpayment recovery action. The Plan Sponsor will no longer be eligible for subsidy payments.
  • Get Key Players in Place: CMS’ RDS Center advised participants to get their key Reconciliation players in place. The Account Manager and the Authorized Representative are required users to complete the Reconciliation process. Designees (either associated with the Plan Sponsor or a third party) are optional users that may also be involved to complete certain tasks. Before beginning Reconciliation, it’s important to ensure all of the proper users are assigned. Verify that Account Manager and Authorized Representative user accounts are active, and that the individuals in those roles will be available to complete their assigned tasks on time. If Designees will be assisting with the Reconciliation process, ensure those individuals have been invited to the application with the appropriate privileges and have registered in the RDS Secure Website.

    If an invited user no longer has their registration invitation email, that user may send an email to RDS@cms.hhs.gov to request that the email be resent.

  • EFT Changes Before Beginning Reconciliation: Participants were reminded that changing Electronic Funds Transfer (EFT) information right before beginning Reconciliation can delay the process. An application must be in "Approved" status to begin Reconciliation. The application will not return to "Approved" status until after the Authorized Representative re-signs the Plan Sponsor Agreement and the EFT information has been verified. EFT information can be updated in Step 10 of Reconciliation.
  • Manage Your Retirees: CMS’ RDS Center discussed the importance of managing retirees throughout the application lifecycle, not just at Reconciliation. Plan Sponsors should request the Covered Retiree List regularly and compare the list with the Plan Sponsor’s records to identify discrepancies. Additionally, Plan Sponsors should process Retiree Response Files and Weekly Notification Files. Costs may only be reported for the beneficiaries, Benefit Options, and subsidy periods listed in the Covered Retiree List.
  • Reconciliation Tips for the Most Common Issues: Participants reviewed common issues that Plan Sponsors have reported for Reconciliation Step 2: Review Payment Setup, Step 4: Finalize Covered Retirees, Step 6: Manage Submission of Final Cost Reports, and Step 7: Review Final Costs.
    • Step 2: Review Payment Setup: CMS’ RDS Center discussed a couple of common Payment Setup mistakes, such as not assigning a Vendor to a Benefit Option and not attaching Designees to a Vendor. Participants were also reminded to ensure all steps of Payment Setup are complete and that Step 2 of Reconciliation is complete. Additionally, they reviewed best practices for switching Vendors, communicating with Vendors, and using Quick Access Reports (QAR) to assist with cost reporting activities.
    • Step 4: Finalize Covered Retirees: CMS’ RDS Center reminded participants that, to complete Step 4, the Covered Retiree List must be created after the last Retiree Response File and/or Weekly Notification File was created. If the Plan Sponsor disagrees with the Covered Retiree List, it should submit a new retiree file to CMS’ RDS Center and process Retiree Response Files and Weekly Notification Files. Participants were advised to scrutinize Retiree Response Files, keeping in mind that some reason codes require action on the Plan Sponsor’s part. Once the Plan Sponsor agrees with the Covered Retiree List, it should distribute the list to Cost Preparers.
    • Step 6: Manage Submission of Final Cost Reports: CMS’ RDS Center explained the difference between a Cost Reporter and a source and method, as well as where to view and report final costs. Common cost reporting errors were also reviewed. Additionally, participants were advised to consider the following questions before closing cost reporting in Step 6:
      • Are costs reported for all expected Benefit Options?
      • Are costs reported for Benefit Options with interim payments?
      • Are reports in "Mainframe: Errors Detected" status?
      • Are reports in "Data Entry: Saved" status?
      • Are there multiple sources for the same Benefit Option?
    • Step 7: Review Final Costs: Participants were advised to investigate any cost reports that were submitted after cost reporting was closed and to review warning and error messages. CMS’ RDS Center also recommended reviewing some of the following indicators before signing off on final costs in Step 7:
      • Average costs per retiree compared to the last interim payment or last year
      • Missing Cost Adjustments
      • Duplicate costs
      • Threshold Reduction higher near the beginning of the year
      • Threshold Reduction met for every Qualifying Covered Retiree contributing to Gross Eligible
      • Limit Reduction for every Qualifying Covered Retiree with claims exceeding the Cost Limit
      • Limit Reduction higher near the end of the year as Qualifying Covered Retirees meet the Cost Limit
      • Significant changes in retirees without changes in costs from the last interim payment or last year’s application
      • Retirees in multiple Benefit Options (coordination of thresholds and limits)
      • Method of calculating Estimated versus Actual Cost Adjustments

Helpful Resources

CMS’ RDS Center reviewed the following resources available to help Plan Sponsors participate in the program and successfully complete Reconciliation: