For purposes of the RDS Program, inaccurate data includes situations where the Plan Sponsor over-reported or under-reported the gross costs associated with one or more specific claims for which some amount of subsidy was requested (i.e., the Plan Sponsor reported gross costs of $30 for a given claim when gross costs for that claim were $20), over-reported or under-reported the Threshold Reduction or Limit Reduction amounts for at least one month for any Benefit Option, or over-reported or under-reported rebates and other price concessions by any amount for at least one month for any Benefit Option. It also includes situations where the Plan Sponsor agreed to a Covered Retiree List that included subsidy periods for specific individuals when in fact one or more of those individuals was not a Qualifying Covered Retiree (as defined in 42 C.F.R. §423.882) for all or part of the CMS-approved subsidy period.
In contrast, for purposes of the RDS Program, incomplete data includes situations where the Plan Sponsor failed to report any of the gross costs associated with one or more specific paid claims. It also includes situations where the Plan Sponsor agreed to a Covered Retiree List that did not include certain individuals who are Qualifying Covered Retirees for all or part of the RDS plan year, and situations where the Plan Sponsor agreed to a Covered Retiree List that included certain individuals, but not for the entire period(s) of time for which those individuals were Qualifying Covered Retirees.