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December 2014 Retiree Drug Subsidy (RDS) Community Information Group (CIG) Webinar: The Road to Reconciliation

The Retiree Drug Subsidy (RDS) Community Information Group (CIG) hosted a webinar on Wednesday, December 10, 2014 to assist the Plan Sponsor community in preparing for Reconciliation and completing Steps 1 - 4.

The webinar covered the following topics:

Review these topics for a summary of the information presented, as well as links to recommended resources.

Webinar Topics:

State of RDS

Participants reviewed recent enhancements to the RDS system that allow RDS Secure Website users to better control their user account. Additionally, participants were introduced to the upcoming RDS Secure Website Online Support Request, as well as updated resources on the RDS Program Website.

Empowering the RDS User and Revised Security Requirements

Users can now recover their Login ID, verify and correct their email address, reset their Password even if they have forgotten the answers to their Security Questions, and enable their disabled user account without having to call CMS' RDS Center. Additionally, participants were reminded that CMS security requirements have changed so that users now need to log into the RDS Secure Website every 180 days to maintain an active account instead of every 60 days. Passwords must also be changed every 180 days.

Online Support Requests – Coming January 2015

In early 2015, an Online Support Request Form will be implemented. Users will be able to report an issue or ask a question from anywhere in the RDS Secure Website. Within one business day, users will receive either a phone call or email response.

Updated RDS Program Website Resources

The new RDS Spotlight section on the homepage highlights timely tips and reminders throughout the application plan year. Additionally, more than 200 Common Questions have been posted to help you find information about important program topics. The RDS User Guide has also been restructured to streamline the user experience.

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Examining the Impact on the RDS Secure Website User

Participants reviewed how recent RDS system enhancements affect their ability to control their RDS Secure Website user account. Scenarios were discussed for the following issues:

  • Forgotten Login ID: Previously, users who have forgotten their Login ID needed to call CMS' RDS Center to ask a Customer Service Representative to look up their ID. Now, users can request their Login ID be emailed to them using the RDS Secure Website. Refer to Request Forgotten Login ID in the RDS User Guide for step-by-step instructions.
  • Forgotten Password: Previously, users could only reset their Password themselves if they knew the answers to their Security Questions. Otherwise, they had to call CMS' RDS Center and have a Customer Service Representative unlock or look up their Security Question answers. Now, if users do not know the answers to their Security Questions or if they are locked, they can request in the RDS Secure Website to receive an email with a link (token) to reset their Password. Refer to Forgot Password in the RDS User Guide for step-by-step instructions.
  • Disabled User Account: Previously, users needed to call CMS' RDS Center to have their account enabled if it had been disabled due to inactivity. Now, the 60-day login requirement has changed to 180 days. Users will be notified when they log in that their account is disabled. Users will receive an email with a link (token) allowing them to re-enable their account. Refer to Enable Your User Account in the RDS User Guide for step-by-step instructions.
  • Inactive Account Due to Bad Email Address: Previously, if a user's email address came back to CMS' RDS Center as undeliverable, they would need to call CMS' RDS Center to have a Customer Service Representative resolve their inactive account. Now, users can correct their own email address and re-activate their account without contacting CMS' RDS Center. Users will receive an email to verify their email address. They can use either the PIN provided in the email or the link (token) for verification. Refer to Verify Email Address in the RDS User Guide for step-by-step instructions.

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Getting Started With Reconciliation

Participants were provided tips to prepare for the Reconciliation process. They were encouraged to start early to ensure success. Plan Sponsors should:

  • Know the Reconciliation Deadline – Refer to Important Reconciliation Deadline Information on the RDS Program Website, as well as the details box on the Reconciliation Checklist page in the RDS Secure Website.
  • Use the Reconciliation Toolkit on the RDS Program Website – The Reconciliation Toolkit will help create a timeline, define key Reconciliation participants, create a project plan, and outline best practices.
  • Review Key Roles – Reassign roles, and add, delete, or change Designee privileges as needed.
  • Verify the Availability of Key Players – Both the Account Manager (AM) and Authorized Representative (AR) roles are required to complete the Reconciliation process. Designees may be involved as well. The Authorized Representative is the only user who can complete the final step of Reconciliation. Ensure the AR role is current and active, and the AR will be in the office at the time you plan to complete Reconciliation. Also ensure that AR Verification is complete (review the details box on the Application Status page to confirm).
  • Keep Email Addresses Current – It's important to ensure key players have current email addresses on record with CMS' RDS Center to ensure proper communication during Reconciliation.
  • Communicate – Maintain active communication with all parties involved in the Reconciliation process.
  • Understand Each Step - Know what is involved in each step by taking advantage of the resources available on the RDS Program Website.

Note: If the Reconciliation Deadline is missed, additional time will not be granted. Interim payments will become overpayments, and CMS will initiate immediate overpayment recovery action. The Plan Sponsor will no longer be eligible for subsidy payments.

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Reconciliation Tools, Tips, and Reminders

Next, participants were provided an overview and helpful information to complete the first four steps of the Reconciliation process.

Step 1: Initiate Reconciliation

The Account Manager or the Authorized Representative complete Step 1 when the Plan Sponsor is ready to begin the Reconciliation process. Reconciliation can be initiated as early as one day after the application plan year ends, and 15 calendar days have passed from the date of the last interim payment determination. This step cannot be undone. Additionally, no interim payments can be requested after Reconciliation is initiated, and all costs submitted for the application moving forward are considered final costs. It is recommended that Plan Sponsors stop interim payments at least 60 days prior to an application's Reconciliation Deadline to focus on Reconciliation activities. If the Plan Sponsor is trying to complete Reconciliation and has an interim payment request in process, it must contact CMS' RDS Center to cancel the payment request.

Step 2: Review Payment Setup

The Account Manager or Authorized Representative complete Step 2 to review the cost reporting and payment request privileges needed for Reconciliation. Once Reconciliation is initiated, Payment Setup can only be accessed through the Reconciliation Checklist. Payment Setup should be updated if there are changes to the Plan Sponsor's methods, sources, or Cost Reporters that were used for interim cost reporting.

Common Mistakes

Some common mistakes in Payment Setup include:

  • Not Assigning a Vendor to a Benefit Option – If a Vendor is not assigned to a Benefit Option, Mainframe cost reports will be rejected.
  • Not Attaching Designees to a Vendor – The RDS system assumes a Designee is assigned to the Plan Sponsor. If Designees are not attached to a Vendor, Data Entry cost reports are then inaccurately assigned to the Plan Sponsor source. Also, Plan Sponsor Designees do not have access to Vendor Mainframe cost reports.

Best Practices

  • Verifying Payment Setup is Complete - If Payment Setup is incomplete, costs cannot be entered on the RDS Secure Website, and Vendor Mainframe cost reports will be rejected. Ensure all steps in the Payment Setup menu are complete.
  • Switching Vendors – If the Plan Sponsor is switching Vendors, it cannot delete the old Vendor, only add the new Vendor. Be sure to coordinate Thresholds and Limits. During Payment Setup, add the Vendor to the application, assign Designees, and attach Designees to Benefit Option(s). Once Payment Setup is complete, notify the Vendor and monitor reports.

Tips

  • Work with your Vendor to determine Designees and establish the proper Cost Reporter relationship in Payment Setup.
  • Consider using Quick Access Reports (QAR). QAR assist and accelerate the cost reporting activities of Vendors and Plan Sponsors by delivering consolidated cost reporting information.
  • Use one source to report cost data for each Benefit Option, if possible. This will help eliminate the possibility of duplicate cost reporting.

    Note: If changing sources for final cost reporting, you will not be permitted to remove Cost Reporters if they have previously reported interim costs – you may need to assign multiple sources to the Benefit Option.

Step 3: Request List of Covered Retirees

The Account Manager, Authorized Representative, or Designee with both the Request Payment privilege and View/Send/Receive Retiree Data privilege request a Covered Retiree List (CRL) in Step 3. The CRL includes records for each Qualifying Covered Retiree (QCR), Benefit Option, and Subsidy Period approved by CMS' RDS Center. The CRL must be used to prepare and report costs. Costs can only be submitted for the Beneficiaries, Benefit Options, and Subsidy Periods listed in the CRL.

The CRL is created by CMS' RDS Center on a nightly basis and is available for download within two business days after the request. Because Step 3 requires an overnight batch process that is only performed during weekdays, if this step is initiated on a weekend or observed Federal holiday, the request is generated the next business day.

Best Practices

  • Consider who is going to send the final retiree files to CMS' RDS Center and process the Retiree Response Files for each Benefit Option. If this source is different from previously sent retiree information for each Benefit Option, Retiree Electronic Data Interchange (EDI) Methods and Sources must be updated.
  • Send a final retiree file with ADD, UPD, DEL records to CMS' RDS Center.
  • Verify and troubleshoot the Retiree Response File (send a copy to the RDS Secure Website).
  • Process any Weekly Notifications received after the Retiree Response File.

Note: You must request the CRL from Step 3 to complete the step. Additionally, you must request a new CRL after each Retiree Response File or Weekly Notification File is received. If you send a new retiree file to CMS' RDS Center, you must wait for a Retiree Response File (4 to 5 business days) to request the CRL. The Download link will be available in the RDS Secure Website when the CRL is processed (2 business days).

Step 4: Finalize Covered Retirees

The Account Manager or Authorized Representative agrees to the accuracy of the Covered Retiree List (CRL) in Step 4. Designees with the Request Payment privilege may view this step but cannot complete it. Designees with both the Request Payment and View/Send/Receive Retiree Data privileges may download the CRL. When the CRL is finalized, CMS' RDS Center stops all retiree processing for that application.

The CRL must be created after the last Retiree Response File and Weekly Notification File is processed. The latest CRL must be downloaded to complete the step.

Best Practices

  • Scrutinize Retiree Response Files. Import response files to Microsoft Excel or another spreadsheet tool. Use the Text Import Wizard to avoid losing leading zeroes. Sort the file by Reason Code and Determination Indicator. Reason Code 00 means the Qualifying Covered Retiree's coverage periods have been accepted by CMS' RDS Center, and no action is required by the Plan Sponsor. However, Reason Codes 10, 11, 12, 16, 20, 21 require the Plan Sponsor to take action.
  • Remember that finalizing retirees is an iterative process that requires sending retiree information to CMS' RDS Center, scrutinizing response files, processing response and notification files, downloading the latest CRL, and checking retiree counts and validating the CRL against the Plan Sponsor's records.

    Tip: The CRL always wins!

  • Distribute the CRL to Cost Preparers. This is critical because costs can only be submitted for the Beneficiaries, Benefit Options, and Subsidy Periods listed in the CRL.

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Helpful Resources

Participants were provided links to helpful Reconciliation resources on the RDS Program Website:

General Reconciliation

Step 1: Initiate Reconciliation

Step 2: Review Payment Setup

Step 3: Request List of Covered Retirees and Step 4: Finalize Covered Retirees

Upcoming Webinars

Register for the RDS CIG January 7, 2015 webinar, Best Practices for Reconciliation Success, for tools and tips to complete Reconciliation Steps 5 – 12, understanding and satisfying an overpayment, and more.

If you have questions or need additional information, contact CMS' RDS Center.

 

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