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Reminder: Post-Reconciliation Discrepancy Disclosure

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CMS’ Retiree Drug Subsidy (RDS) Center would like to remind the Plan Sponsor community that, pursuant to 42 C.F.R. § 423.888, RDS subsidy payment “is conditioned on provision of accurate information.” If a Plan Sponsor discovers after, completion of Reconciliation for an application, that it agreed to inaccurate retiree and/or cost data, that Plan Sponsor must report the discrepancy to CMS’ RDS Center.


Within 15 months after the application Plan Year End Date, Plan Sponsors must complete Reconciliation. As a requirement of Reconciliation, each Plan Sponsor must finalize their application's Covered Retiree List (CRL) and submit final cost data to CMS' RDS Center. Despite a Plan Sponsor's best efforts to ensure that retiree and cost data are accurate, instances may occur in which a Plan Sponsor becomes aware of discrepancies after completing Reconciliation.

In accordance with 42 C.F.R. § 423.890, if discrepancies are identified after Reconciliation has been completed, Plan Sponsors have the right to request a Reconsideration appeal or reopening. Please review Appeal an Initial Determination in the RDS User Guide for important information on this topic.

For information about submitting documentary evidence of incomplete or inaccurate data to support an appeal, please refer to Include Additional Documentary Evidence in the RDS User Guide. An RDS Appeals Documentary Evidence/Post-Reconciliation Discrepancy Example is also available for your convenience.

If a Plan Sponsor wishes to notify CMS of a post-Reconciliation discrepancy but does not wish to file a Reconsideration appeal or reopening, please refer to "How would an RDS Plan Sponsor disclose to CMS the correct, post-Reconciliation or post-final payment data, and the difference in subsidy caused by the corrected data, other than by requesting a reopening?" on the Common Questions: Reporting Inaccurate or Incomplete Data page.

If you need more information, contact CMS' RDS Center.

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