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.
Background
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.
If discrepancies are identified after Reconciliation has been completed, Plan Sponsors must notify CMS’ RDS Center. CMS will then reopen the Reconciliation determination in accordance with 42 C.F.R. § 423.890.
For information about submitting documentary evidence of incomplete or inaccurate data to support an appeal, please refer to Include Supporting Documentary Evidence in the RDS User Guide. An RDS Appeals Documentary Evidence Example is also available for your convenience.
If you need more information, contact CMS' RDS Center.