Plan Sponsors continuously manage current RDS Secure Website user roles to prevent delays in tasks being completed. User management includes not only maintaining roles and user information, but also remaining in compliance with Federal Security Regulations by logging into the RDS Secure Website at least once every 180 days.
Assigning and Reassigning User Roles AM AR D
During the phases of an application, Plan Sponsors may assign and reassign user roles and privileges as needed to ensure timely completion of tasks. If the Authorized Representative (AR), Account Manager (AM), or Actuary are unable to complete their tasks, reassign their role or privilege as soon as possible to prevent delays.
Things to Consider with the Authorized Representative (AR) AR
- Does the AR have the proper legal authority? The AR role must be fulfilled by an individual who has the legal authority to bind the company to the Plan Sponsor Agreement signed during the annual Application Submission Process and the Reconciliation Agreement.
- When should the AR role be assigned or re-assigned? The AR is invited by the AM when the AM registers the Plan Sponsor with the RDS Program. The AR role must be reassigned when the individual fulfilling the AR role no longer possesses the proper authority to bind the Plan Sponsor (i.e., leaves the Plan Sponsor organization). The AR's responsibilities known as privileges in RDS are automatically defined and will carry forward to the new AR.
- Is the new AR responsible for applications signed by the previous AR? An AR's authority spans across all of the Plan Sponsor's previous, current, and future applications. For example, should pertinent banking information change on an approved application, the new AR is required to review the banking information and re-sign the application agreement. The new AR is also responsible for submitting the Reconciliation payment request when Reconciliation is not complete on an application.
- Who can fill the AR role? The AR must be an employee of the Plan Sponsor. For multi-employer plans, the AR does not have to be an employee of the Plan Sponsor, but may be a member of the jointly appointed board of trustees, which includes both labor and management trustees. The AM role and AR role must not be fulfilled by the same person. The AR must be assigned the same role for each Plan Sponsor they are associated. The replacement must be selected when assigning the AR.
- Is the AR leaving the company? The AM needs to reassign the AR role to another individual.
- Does the AR have an active user account? An AR is invited to register through an email from CMS' RDS Center. An AR is required to be a registered RDS Secure Website user and maintain an active Login ID and Password. Maintaining an active user account is essential to RDS Program participation including submitting applications and completing Reconciliation. A Plan Sponsor cannot receive payments without an active AR.
- Will the AR be available to complete their RDS tasks? The AR is responsible for Step 8: Plan Sponsor Agreement of the Application Submission Process. The AR is also responsible for Step 11: Approve Electronic Funds Transfer (EFT) Information and Step 12: Review And Submit Reconciliation Payment Request of the Reconciliation process. If the AR will not be available, the AM must reassign the AR role.
Things to Consider with the Account Manager (AM) AM
- Is the AM role being reassigned? The AM may be an employee of the Plan Sponsor organization. If not directly employed by the Plan Sponsor, the AM may act as an agent on behalf of the Plan Sponsor. The AM role and AR role must not be fulfilled by the same person. The AM must be assigned the same role for each Plan Sponsor they are associated.
- Is the AM leaving the company? The AM or the AR needs to reassign the AM role to another individual. The reassignment may be postdated.
- Does the AM have an active user account? If the AM role is reassigned, the new AM is invited to register through an email from CMS' RDS Center. An AM is required to be a registered RDS Secure Website user and maintain an active Login ID and Password. Maintaining an active user account is essential to RDS Program participation including submitting applications, receiving payments, and completing Reconciliation.
- Is a Designee being reassigned the AM user role? The Designee must be deleted from all applications prior to the reassignment of the AM role.
- Does the AM have the time to manage all of the Plan Sponsor's applications? The AM oversees all of the Plan Sponsor's applications. These applications are most likely in different phases. For example, at the same time, the AM could be responsible for submitting the Plan Sponsor's application for the next plan year, monitoring cost reporting and requesting interim payments for the current plan year, and reconciling the previous plan year. The AM may want to consider delegating tasks to other individuals by adding Designees to the applications and assigning specific privileges to assist with the workload.
Things to Consider with the Actuary AC
- Does the Actuary have an active user account? The Actuary is invited to register through an email from CMS' RDS Center. The Actuary is required to be a registered RDS Secure Website user and maintain an active Login ID and Password. Maintaining an active user account is essential to RDS Program participation including attestation.
- Is the Actuary a member of and in good standing with the American Academy of Actuaries? CMS requires Actuaries to be a current member and in good standing with the American Academy of Actuaries.
- When is an Actuary required? An Actuary is assigned to an application during the annual Application Submission Process. The Actuary is required to attest an application prior to submission of the online application. The Actuary is not required to perform any other tasks for an application.
Things to Consider with the Designee D
- What tasks will the Designee perform on the application? A Designee's privileges are application specific and can only be assigned by the AM or AR.
- Will Designees have different responsibilities for the application? Multiple Designees can be assigned to the application through the Maintain Designee and Payment Setup functions. Responsibilities are defined as privileges and are unique to the individual Designee. More than one Designee can be assigned the same privilege and a Designee can be assigned multiple privileges.
- Will the Designee report costs? Is the Designee submitting costs on the behalf of a Vendor? Designee cost privileges are maintained in Payment Setup. A Designee who reports costs can be defined as either a Vendor Designee or a Plan Sponsor Designee.
- Does a Designee need to be added or removed from the application? Designees can be added or removed from the application throughout the application's phases. Unlike an AR or an AM whose role automatically carries over to each of the Plan Sponsor's applications, an individual Designee must be specifically added or removed from each application.
- Has a Designee's duties changed? Most privileges can be added or removed throughout the application's phases. The Report Costs privilege cannot be removed if the Designee has entered costs. The Request Payment privilege cannot be added if the Designee already has the Report Costs privilege.
- Has a cost report been submitted? You cannot remove the Report Costs privilege from the AM or Plan Sponsor Designee if that specific person reported costs.
Tips for maintaining an active account:
- Keep user accounts active. Maintaining an active user account is essential to RDS Program participation including submitting applications and completing Reconciliation. CMS' RDS Center will not make payments to a Plan Sponsor if the Authorized Representative or Account Manager has an inactive user account.
- Log into the RDS Secure Website at least once every 180 days. This maintains an active user account status. CMS' RDS Center understands that certain users of the RDS Secure Website may need to log in more often than others. However, Federal Security Regulations mandate this rule.
- Remind new users to log into the RDS Secure Website. The rule applies to new users even if they have never logged into the RDS Secure Website. New users have 180 days to log into the RDS Secure Website from the date they are activated and are required to log in at least once every 180 days thereafter to maintain an active account.
- Beware of critical path users who don't log in frequently. An AR with an inactive user account cannot submit an application or Reconciliation payment request, and an Actuary with an inactive user account cannot sign the Attestation Agreement.
- Use the warning email as a reminder. CMS' RDS Center sends a warning email when a user account is about to be disabled. Use this email as a reminder. Select the link in the email and log into the RDS Secure Website. Doing this resets the 180-day clock and keeps your account active.
- Check spam filters. Take the necessary steps to ensure that warning emails are received and not marked as "spam" or automatically deleted for any other reason. Make the necessary adjustments to your email account, or contact your network administrator to ensure that emails sent from the following email addresses are not blocked by any spam filters or Blocked Senders List: