Program Components:
Overview
This section provides an overview of the following topics related to the Actuary page of the Annual Plan Application Submission process:
- Introduction to the Actuary and Attesting Actuarial Equivalence
- User Roles
- Timing & Dependencies
- Modifying the Actuary
- Re-attesting an Application
Introduction to Application Submission: Actuary
An Actuary is a professional contracted by the Plan Sponsor applying to the RDS Program to attest to the Actuarial Equivalence of the Benefit Options specified in an RDS application. Any Actuary that is contracted to attest to the Medicare Part D equivalence of Benefit Options must be a member of, and in good standing with, the American Academy of Actuaries.
CMS' RDS Center requires a qualified Actuary to complete a two-part Actuarial Equivalence Test before an application can be submitted. The Plan Sponsor assigns the Actuary to each application. Each Application can only have one Actuary assigned.
Prior to being invited to attest to an RDS application, the Actuary must first opt-in to participate in the RDS program on the American Academy of Actuaries website. Refer to American Academy of Actuaries: The Retiree Drug Subsidy Program for information on this process.
Once the Actuary has opted-in, they must be invited to the application(s). After the Actuary has an active RDS Secure Website account and activated Multi-Factor Authentication (MFA), they will attest to the actuarial equivalence of the Benefit Option(s).
Attesting to the Actuarial Equivalence of the Benefit Option(s) specified in the RDS application is the only responsibility of the Actuary. Actuaries have no role in application maintenance after the application is approved, nor in Reconciliation.
The Account Manager, Authorized Representative, and Designee(s) with the Assign Actuary privilege are permitted to assign an Actuary to the application.
A qualified Actuary completes the Electronic Signature for the attestation of the Actuarial Equivalence of the Benefit Option(s) specified in the application by a Plan Sponsor. Refer to Attest Actuarial Equivalence for additional information.
The Account Manager, Authorized Representative, and Designee(s) with the View Attestation Summary privilege can view the Attestation Summary on the Application Overview page.
The Actuary can be assigned to the application at any time during the Annual Plan Application Submission Process after Benefit Options are created. One Actuary is assigned to an application to attest all Benefit Options. Benefit Options must be created before assigning the Actuary.
Actuary assignment requires entry of an email address for the assignee. Depending on the search results for the email address, one of three scenarios may occur:
- Actuary Cannot Use: The Email Address entered has been found in the Secure Website, but this person cannot be assigned as an Actuary because they are already assigned a different role.
- Actuary Found: The Email Address entered has been found in the Secure Website and this person can be assigned as the Actuary.
- Actuary Not Found: The Email Address entered was not found in the Secure Website associated to another person or role and this person can be assigned as the Actuary.
The Actuary can perform the Attestation after Benefit Options are assigned and they are invited to the application, and may re-attest any time before the application is submitted.
After the Attestation is complete, but before the application is submitted, Benefit Options can be deleted. However, the Actuary section of the application will be marked incomplete and the Actuary must re-attest the application after Benefit Options are finalized again.
Once the Attestation has been completed for all Benefit Options in the application, it can be viewed at any time throughout the application lifecycle.
The Actuary can only be changed prior to application submission. If the application has already been attested, the newly assigned Actuary must re-attest the application prior to the submission of the application.
If an application has been attested and submitted, the Actuary cannot be removed for any reason. If the Actuary retires, leaves their organization, or is not needed for any other reason, the Plan Sponsor does not need to reassign the Actuary role once the application is submitted. The attesting Actuary is associated with the application in perpetuity.
For more information on changing Actuary role assignments, refer to Manage the Actuary Role.
A single Attestation covers all Benefit Options on the application. Adding or deleting a Benefit Option may invalidate the Attestation regardless of whether the Benefit Options are being combined for the Net Value Test.
The Actuary must re-attest an application prior to application submission if any of the following events occur:
- A Benefit Option is added;
- A Benefit Option is deleted and the Actuary has combined two or more Benefit Options listed in the application to meet the Net Value Test as set forth at 42 C.F.R. §423.884(d);
- The Actuary role is reassigned;
- The Actuary is unassigned;
- The Actuary changes the Attestation Method.
The Actuary will receive a notification email if the application needs to be re-attested.
If Attestation is complete, an application is submitted, and it is later determined that the plan or a Benefit Option do not pass the Actuarial Equivalence Test, the Plan Sponsor must contact CMS' RDS Center.
Return to Application Submission: Benefit Options | Continue to Application Submission: Banking Information
Step-by-Step Instructions
This section provides step-by-step instructions to assign an Actuary. To access the RDS Secure Website, and navigate to the Dashboard page, review instructions to access the RDS Secure Website.
On the Dashboard page:
- Select In Progress to view a list of all Applications in progress.
-
Select the Application ID for which you want to assign an Actuary.
On the Application Overview page:
-
Select Actuary.
On the Actuary page:
An asterisk (*) indicates a required field.
- Enter the email address in the *Search by email field.
-
Select Search.
Depending on the search results for the email address, one of three scenarios may occur:
Scenario 1: Actuary Cannot Use:
On the Actuary page:
- Enter the email address in the *Search by email field.
-
Select Search to search again for a different Actuary.
Or
On the Actuary page:
-
Select Assign to assign this user as an Actuary or select Cancel to return to search again for a different Actuary.
-
After selecting Assign, a Success message will display. You may select Change Actuary to cancel the current Actuary assignment and search again for a different Actuary.
Note: When the Actuary is assigned, an email is sent to the Actuary indicating assignment to the application and instructing that they must attest to the Medicare Part D equivalence of the plan.
Or
Scenario 3: Actuary Not Found:
On the Actuary page:
An asterisk (*) indicates a required field.
- *Enter the American Academy of Actuaries Membership Number.
- *Enter the First Name.
- *Enter the Last Name.
-
Select Invite to proceed, or select Cancel to search again for a different Actuary.
-
After selecting Invite, a Success message will display. You may select Change Actuary to cancel the current Actuary assignment and search again for a different Actuary.
Note: When the Actuary is assigned, an email is sent to the Actuary indicating assignment to the application and instructing that they must attest to the Medicare Part D equivalence of the plan.
If the Actuary has not yet opted into the RDS program on the American Academy of Actuaries website, or if the American Academy of Actuaries Number and/or Actuary Name are entered incorrectly, an error message will display on the Actuary Page. To clear the error:
- Verify the American Academy of Actuaries Number and Actuary Name. Note: Contact the Actuary directly to verify this information, if necessary.
On the Actuary Page:
- *Re-enter the American Academy of Actuaries Membership Number.
- *Re-Enter the First Name.
- *Re-Enter the Last Name.
-
Select Invite to proceed, or select Cancel to search again for a different Actuary.
This section provides step-by-step instructions to view Attestation. To access the RDS Secure Website, and navigate to the Dashboard page, review instructions to access the RDS Secure Website.
On the Dashboard page:
- Select In Progress to view a list of all Applications in progress.
-
Select the Application ID for which you want to view Attestation.
On the Application Overview page:
-
Select Actuary.
On the Actuary page:
-
Review the details of the Attestation: Attestation Status, Attestation Method, and Attestation Date.
Return to Application Submission: Benefit Options | Continue to Application Submission: Banking Information
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