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?

Such disclosure must include:

• The Plan Sponsor's Name, Plan Sponsor ID, Application ID, and contact information;
• Indication that the Plan Sponsor wishes to disclose such data and subsidy discrepancy to CMS, and is not requesting a reconsideration or reopening at this time;
• A description of the specific facts and circumstances, including the specific reason(s) why the data submitted with the Reconciliation or final payment request was inaccurate or incomplete, and whether or not the Plan Sponsor believes the Covered Retiree List it agreed to before submitting its Reconciliation or final payment request was accurate;
• The gross costs, cost threshold reductions, cost limit reductions, and price concession amount that the Plan Sponsor now believes is correct. (For this purpose, the data can either be broken down by Benefit Option by month, or can be submitted in the aggregate for the entire application.) These amounts should reflect what the Plan Sponsor now believes to be its accurate retiree list.

The Plan Sponsor should also disclose:

• The amount of subsidy it received for the application;
• The amount of subsidy the Plan Sponsor now believes is correct, based on the post-Reconciliation or post-final payment drug cost data (i.e., gross costs, cost threshold reductions, and cost limit reductions), price concession amount, and/or retiree coverage data, the Plan Sponsor now believes the subsidy should be based upon. See "How is the Retiree Drug Subsidy calculated for a given application?" for instructions on how the subsidy for an application is calculated.

A Post-Reconciliation Discrepancy Example is available for reference.

The disclosure should be sent, with a subject line of "Post-Reconciliation Subsidy Discrepancy," to CMS' RDS Center email address rds@cms.hhs.gov.

After the Plan Sponsor discloses to CMS the data and subsidy discrepancy as stated above, CMS will notify the Plan Sponsor of any further action it may or must take, if any.