This is a very common question, but the answer is always the same; absolutely not.
One of the biggest challenges Plan Sponsors face with the RDS program is coordinating between the Centers for Medicare and Medicaid Services (CMS), multiple vendors, and data sources to compile the necessary information to receive subsidy payments. In summary, the CMS requires Plan Sponsors and their vendor(s) must do the following to compile the requisite information:
- Identify and match members to the Medicare Database;
- Filter claims made by eligible members to ensure only Part D prescriptions are included for subsidy payment;
- Match eligible claims to approved, eligible members.
While these requirements are simple enough in theory, more often than not, each piece is completed by different parties. This means that when the time comes to compile this information, miscommunications and oversights can only be expected. This confusion is only compounded by sometimes conflicting and generally complicated rules and restrictions for each item, which are set by the CMS.