The Centers for Medicare & Medicaid Services’ (CMS’) Retiree Drug Subsidy (RDS) Center is sending this critical information to RDS Plan Sponsors that have an RDS application(s) with a reconciliation deadline of June 30, 2008, as well as Plan Sponsors that have other deadlines for submitting reconciliation.
There are various steps within the reconciliation process that may require CMS’ RDS Center’s intervention. Plan Sponsors may find themselves in a position where they cannot move forward with reconciliation until CMS’ RDS Center completes certain actions. It is critical for Plan Sponsors to know what those actions are, and how much time it will take for CMS’ RDS Center to complete those actions. This knowledge will help Plan Sponsors plan accordingly, so that they can meet their reconciliation deadline.
Following is a list of circumstances where CMS’ RDS Center might have to take certain actions and the estimated length of time it will take for CMS’ RDS Center to complete those actions. Plan Sponsors and RDS stakeholders MUST incorporate these timeframes into their current process to ensure the reconciliation deadline is met.
Processing of Authorized Representative Verification Form
A Plan Sponsor cannot complete reconciliation Step 12: Review and Submit Reconciliation Payment Request unless CMS’ RDS Center has received and approved an Authorized Representative Verification Form. The Authorized Representative Verification form is written documentation from the Plan Sponsor verifying that the individual listed on the RDS application as the Authorized Representative is authorized to act on the Plan Sponsor's behalf. If the Plan Sponsor does not have an approved Authorized Representative Verification Form on file with CMS’ RDS Center, the Plan Sponsor must submit a new Authorized Representative Verification Form to CMS’ RDS Center. Please be aware that it will take CMS’ RDS Center up to 10 business days after a valid form is received, to process and either approve or reject the form. Also, please be aware that Plan Sponsors must submit a new Authorized Representative Verification form when the role of Authorized Representative is reassigned.
Requesting a Covered Retiree List
Reconciliation Step 3: Request List of Covered Retirees requires a Plan Sponsor to request a covered retiree list from CMS’ RDS Center. Please be aware that when a covered retiree list is requested, the covered retiree list should be available for download in the RDS Secure Web Site mailbox within two business days from the time of the request.
Receiving Retiree Response Files
When a Plan Sponsor submits an add/update/delete retiree file, a retiree response file will post to the RDS Secure Web Site using the same retiree submission method in which it was received from the Plan Sponsor. Please be aware that it will take CMS’ RDS Center three to five business days after submission of the add/update/delete retiree file to post the retiree response file to the RDS Secure Web Site.
Request Step 3 and Step 4 of Reconciliation to Change from “Complete” to “Incomplete” Status
It is critical that Plan Sponsors agree to a correct covered retiree list in reconciliation Step 4: Finalize Covered Retirees. CMS’ RDS Center would like to remind Plan Sponsors that it is in their best interest not to complete Step 4 until the Plan Sponsor is certain the retiree data reflected in the covered retiree list requested in reconciliation Step 3: Request List of Covered Retirees is accurate.
Despite a Plan Sponsor’s best efforts to ensure that the retiree data reflected in the covered retiree list is accurate, there may be instances where a Plan Sponsor becomes aware of changes to its qualifying covered retirees after it has completed Step 3 and Step 4, but before it has completed reconciliation Step 12 : Review and Submit Reconciliation Payment Request. Such changes may include additions or deletions of qualifying covered retirees, changes to the approved subsidy periods, and/or changes in which benefit option a qualifying covered retiree is enrolled. In such cases, the Plan Sponsor must contact CMS’ RDS Center Help Line, prior to the completion of Step 12, to request that reconciliation Step 3 and Step 4 be changed to an “Incomplete” status. Although reconciliation Step 3 and Step 4 can be changed to an “Incomplete” status after they are completed, ALL reconciliation steps that have already been completed, beginning with Step 3, will be changed to an “Incomplete” status and must be completed again in such instances. Please be aware that it will take CMS’ RDS Center up to 5 business days to change Step 3 and Step 4 of reconciliation from “Complete” to “Incomplete” status.
Changing Key User Roles and Privileges
While reconciliation does not necessarily require a change in user roles and/or privileges, to complete reconciliation a Plan Sponsor is required to have an active Account Manager and Authorized Representative. All new RDS Secure Web Site users must complete registration and be systematically validated by CMS’ RDS Center. Please be aware that it takes CMS’ RDS Center a minimum of 3 business days to validate a new user.
Changing Electronic Funds Transfer (EFT) Information
EFT information may be changed on submitted applications. However, Plan Sponsors approaching their reconciliation deadline should NOT change EFT information before reconciliation is initiated as it will take CMS’ RDS Center 10 business days to process this request, and during the EFT verification process the Plan Sponsor will be unable to initiate reconciliation on that application. Plan Sponsors approaching their reconciliation deadline should only change EFT information during reconciliation Step 10: Review Electronic Funds (EFT) Information which does NOT prevent the Authorized Representative from completing reconciliation Step 11: Approve Electronic Funds Transfer (EFT) Information, and Step 12 to finalize reconciliation.
Submitting an Interim Payment Request
Plan Sponsors cannot submit an interim payment request after they complete reconciliation Step 1: Initiate Reconciliation. A Plan Sponsor should not submit an interim payment request for an application during the final 30 calendar days before the application’s reconciliation deadline, due to the fact that Step 1 cannot be completed until at least 30 days after an interim payment request has been submitted to the RDS Center, or at least 15 calendar days have passed since an interim payment was determined.
For information on the RDS reconciliation deadline, please see Important Reconciliation Deadline Information on the RDS Program Web Site.
For information on the RDS reconciliation process, including the topics discussed above, go to the RDS Program Web Site.
If you need further information, please contact the CMS' RDS Center's Help Line.
Sincerely,
CMS’ RDS Center