If a Plan Sponsor misses the Application Deadline, it has two options:
Option 1: Submit a New Application
- Start a new application with a deadline the Plan Sponsor can meet. If the Plan Sponsor pursues this option, it must select a Plan Year Start Date with a future Application Deadline that allows the Plan Sponsor enough time to complete and submit a timely application. Applications for plan years whose deadline has passed will be denied.
- The Application Deadline is 90 days prior to the Plan Year Start Date specified in the application. The Plan Sponsor should start and submit the application as soon as possible. Promptly request the 30-day Application Deadline Extension to ensure extra time for submission of the Valid Initial Online Application and Valid Initial Retiree List.
- For purposes of the Retiree Drug Subsidy, a plan year is whatever period of time a Plan Sponsor designates in its Valid Initial Online Application, as long as the plan year does not exceed 12 months. An RDS plan year can be shorter than 12 months.
Remember: A timely RDS application consists of both a Valid Initial Online Application and a Valid Initial Retiree List.
Option 2: Submit Existing Application and Appeal
- Submit the existing application for the 12-month plan year whose deadline has passed.
- After CMS' RDS Center has reviewed the submitted application and determined that it was not submitted timely, the Plan Sponsor's Authorized Representative, Account Manager, and any Designees with the Appeal privilege will receive an email determination that the application is denied.
- That email will contain information about the Plan Sponsor's appeal rights and information on how to pursue such appeal.
Note: A Plan Sponsor can pursue both Options 1 and 2 simultaneously.