Attest Actuarial Equivalence

Overview

This section provides an overview of the two-part Actuarial Equivalence Test.

CMS' RDS Center requires a qualified Actuary to complete a two-part Actuarial Equivalence Test before an application can be submitted. The two-part Actuarial Equivalence Test includes a Gross Value Test and a Net Value Test. The Gross Value Test confirms that the total value of benefits provided to Medicare Part D eligible individuals under the Plan Sponsor's plan is at least as generous as what they could receive under standard Medicare Part D coverage. The Net Value Test takes into account the extent of the employer financing of the drug coverage so that the net value of the employer plan to those individuals is at least equal to the net value of what they would receive under standard Medicare Part D coverage.

The Actuary determines if multiple Benefit Options will be combined to pass the Actuarial Equivalence Net Test. If Benefit Options are combined, the Actuary will attest to the gross value of each Benefit Option and to the net value of the combined Benefit Options. If Benefit Options are not combined, the Actuary will attest to both the gross and net values of each Benefit Option. For purposes of the actuarial equivalence net test, only Benefit Options listed within a single application may be combined.

Select a link for additional information on the following topics:

• Actuaries Assigned to Benefit Options on an Application
• Attestation Method
• Timing of Attestation
• Notification that Attestation is Complete
• Re-attesting an Application

Actuaries Assigned to Benefit Options on an Application

• One Actuary may be assigned to an application to attest all of the Benefit Options.
• Multiple Actuaries may be assigned to an application to attest individual Benefit Options.
• A single Benefit Option may not be attested by more than one Actuary.

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Attestation Method

The Actuary is required to select one Attestation Method for the Net Value Test:

• Each Benefit Option individually meets the Net Value Test as set forth at 42 C.F.R. §423.884(d).
• Two or more Benefit Options have been combined to meet the Net Value Test as set forth at 42 C.F.R. §423.884(d), and each option not so combined individually meets the Net Value Test as set forth in 42 C.F.R. §423.884(d).

If more than one Actuary is assigned to the Benefit Options on an application and Benefit Options are being combined to satisfy the Net Value Test, each Actuary assigned to that application needs to answer that they are combining Benefit Options to satisfy the Net Value Test.

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Timing of Attestation

An Actuary can perform the Attestation after Benefit Options are assigned, and may re-attest any time before the application is submitted.

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Notification that Attestation is Complete

After Attestation is complete, the Account Manager and Authorized Representative will receive a notification email that the Benefit Options on the application have been attested.

Note: The Plan Sponsor (or a delegated third party), as applicable, must maintain, and furnish to CMS or the U.S. Department of Health and Human Services Office of Inspector General upon request, certain records, including reports and working documents of the Actuary/Actuaries who wrote the attestation. See 42 C.F.R. §423.888(d)

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Re-attesting an Application

A single Attestation covers all Benefit Options on the application, unless multiple Actuaries are identified on the application. Adding or deleting a Benefit Option may invalidate the Attestation regardless of whether the Benefit Options are being combined for the Net Value Test.

The Actuary needs to re-attest an application prior to application submission if any of the following events occur:

• A Benefit Option is added;
• A Benefit Option is deleted and the Actuary has combined two or more Benefit Options listed in the application to meet the Net Value Test as set forth at 42 C.F.R. §423.884(d);
• The Actuary role is reassigned for one or more Benefit Options;
• The Actuary is unassigned from one or more Benefit Options;
• The Actuary changes the Attestation Method.

The Actuary will receive a notification email if the application needs to be re-attested.

If Attestation is complete, an application is submitted, and it is later determined that the plan or a Benefit Option do not pass the Actuarial Equivalence Test, the Plan Sponsor needs to contact CMS' RDS Center .

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Step-by-Step Instructions

This section provides step-by-step instructions to Attest Actuarial Equivalence and View the Attestation.

Attest Actuarial Equivalence

To access the RDS Secure Website, and navigate to the Plan Sponsor List with Application Summary page, review instructions to access the RDS Secure Website.

On the Plan Sponsor List with Application Summary page:

1. Select a Plan Sponsor ID to view a Plan Sponsor's applications.

   

On the Application List page:

2. Select an Application ID to attest Benefit Options or select Attest/View Application from the corresponding Actions dropdown menu then select Go.

   

On the Attest Benefit Options page:

An * indicates a required field.

3. *Select one Attestation method, unless it was preselected for you:
   
   1. Each Benefit Option individually meets the Net Value Test as set forth at 42 C.F.R. §423.884(d).

   2. Two or more Benefit Options have been combined to meet the Net Value Test as set forth at 42 C.F.R. §423.884(d), and each option not so combined individually meets the Net Value Test as set forth in 42 C.F.R. §423.884(d).

      Note: If only one Benefit Option is listed in the application, the Attestation Method: "Each Benefit Option individually meets the Net Value Test as set forth at 42 C.F.R. §423.884(d)" is preselected and cannot be changed.

4. Select Continue to attest or select Cancel to return to the Application List page.

   

On the Attestation page:

An * indicates a required field.

5. Read the Attestation.
6. Select the checkbox to certify the Attestation.
7. Enter Answers to Security Questions.

8. Select Attest to complete the Attestation or select Cancel to return to the Attest Benefit Options page.

   Note: The Attestation page corresponds to the Attestation Method selected on the Attest Benefit Options page.

   

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View the Attestation

After an application is submitted, the Actuary can view the attested Benefit Options, the Attestation Method, and the Attestation.

To access the RDS Secure Website, and navigate to the Plan Sponsor List with Application Summary page, review instructions to access the RDS Secure Website.

On the Plan Sponsor List with Application Summary page:

1. Select a Plan Sponsor ID to view a Plan Sponsor's applications.

   

On the Application List page:

2. Select an Application ID to view attested Benefit Options or select Attest/View Application from the corresponding Actions dropdown menu then select Go.

   

On the Attest Benefit Options page:

3. View the Attestation Method that was selected.

4. Select Continue to view the Attestation or select Cancel to return to the Application List page.

   

On the Attestation page:

5. View the Attestation.

6. Select Cancel to return to the Attest Benefit Options page.

   

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