Report a Change of Plan Sponsor EIN or Company Name

• Introduction to Reporting a Change of Plan Sponsor EIN or Company Name
• User Roles
• Instructions to Begin the Process
• Required Information
• Required Supporting Documentation
• Review Old Plan Sponsor ID in the RDS Secure Website

Introduction to Reporting a Change of Plan Sponsor EIN or Company Name

The Authorized Representative must notify CMS' RDS Center of a change of Plan Sponsor EIN or Company Name. A change of ownership or Company Name is defined as a change in a Plan Sponsor's Federal Tax ID Number or Company Name that is recorded by the US Department of Treasury. As part of the Plan Sponsor Agreement and in accordance with 42 C.F.R. §423.892 of Federal regulations, Plan Sponsors are required to provide CMS with notice at least 60 days prior to the anticipated effective date.

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User Roles

The Authorized Representative is the only user role who can initiate a change of Plan Sponsor EIN or Company Name.

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Instructions to Begin the Process

To begin the process, the Authorized Representative currently registered in the RDS Secure Website must send an email to CMS' RDS Center at RDS@cms.hhs.gov and include the following required information.

Note: If the change of ownership has already taken place, the email must be sent from the individual acting as the Plan Sponsor authority (Authorized Representative) for the entity identified as the "new" Plan Sponsor. The email must include the person's role or title.

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Required Information

Provide the following information in the e-mail:

• Name of the person sending the email
• RDS user role
• RDS user's email address
• Contact phone number of the user sending the email
• The existing RDS Plan Sponsor ID(s), Company Name(s) and Employer Identification Number(s) (EIN)
• The reason for the Change of Name/Ownership
• Effective date of the change
• New Company Name (if changing)
• New Plan Sponsor EIN (if changing)
• New Plan Sponsor ID (PSID), if already created. (If a new PSID has not already been created, do not create one until directed by CMS' RDS Center.)
• Has the new Plan Sponsor assumed liability for the prescription drug costs of the existing organization? Answer "Yes" or "No."
• Have any of the following areas been affected by the Change of Name/Ownership?
  
  • Prescription Drug Benefits (Answer "Yes" or "No." If yes, describe the change.)
  • Cost Sharing (Answer "Yes" or "No." If yes, describe the change.)
  • Premium Contributions (Answer "Yes" or "No." If yes, describe the change.)
  • Retiree Mix (Answer "Yes" or "No." If yes, describe the change.)

Note: For applications that have not yet been approved, if there was any change to the Prescription Drug Benefits, Cost-Sharing, Premium Contributions, or Retiree Population, Actuarial Equivalence Tests must be re-performed in a manner consistent with Federal regulations and guidance for each application that the Plan Sponsor was impacted by the change, and where the Actuarial Attestation did not take into account the change.

If any Benefit Option fails the Actuarial Equivalence Test, the Plan Sponsor must report it to CMS' RDS Center. For all applications (both approved and not yet approved), if every Benefit Option passes the Actuarial Equivalence Test, the Plan Sponsor must maintain the Actuary's work papers demonstrating that the tests were performed and produce them upon request.

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Required Supporting Documentation

Supporting documentation is required to substantiate a change of Plan Sponsor EIN or Company Name. You can obtain this information by calling the Internal Revenue Service (IRS) at 1-800-829-4933. Scan and attach any additional or supporting documentation concerning the change of ownership or Company Name and/or EIN change to an email to RDS@cms.hhs.gov.

The following forms of documentation are accepted:

• IRS Form 147C
• SS-4 Form
• Letter from the US Department of Treasury (must include the Plan Sponsor Name, address, and EIN)
• Certificate of Amendment of Articles of Incorporation

The following forms of documentation are not accepted:

• IRS Form 5500
• The application for the SS-4 Form

Note: The Plan Sponsor Name on the form must be an exact match to the legal name on record with CMS' RDS Center.

When CMS' RDS Center receives the email, the submitted information will be processed, and the Plan Sponsor will be contacted to discuss next steps, details, and instructions.

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Review Old Plan Sponsor ID in the RDS Secure Website

After a change has been reported to CMS' RDS Center and the change of ownership has been processed in the RDS Secure Website, the old Plan Sponsor ID displays with a status of "Former" on the Dashboard page.

Note: If an RDS Secure Website user tries to access a Plan Sponsor ID designated as "Former" or attempts to start a new application for a Plan Sponsor ID marked as "Former," a warning message appears stating "This Plan Sponsor is designated as 'Former.' You cannot create new applications for this Plan Sponsor."

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