Program Components:
Pursuant to 42 C.F.R. 423.888, there are multiple scenarios during the Payment Validation process that can delay or stop a payment request from being processed. Furthermore, payments that remain on hold for 60 days that are not resolved by the Plan Sponsor are subject to cancellation by the RDS Center.
When a payment request is placed on hold, CMS’ RDS Center will conduct outreach to the Plan Sponsor to provide guidance for resolving the issue. Please respond to any requests for additional information or action on the part of the Plan Sponsor as soon as possible.
The following table lists common reasons that a payment request may be placed on hold and what the Plan Sponsor should do to resolve the issue.
| Hold Reason | What It Means | What You Should Do | Who Can Resolve |
|---|---|---|---|
| Banking Information rejected | The payment request or pre-note authorization sent to the Plan Sponsor’s bank failed because some or all of the Plan Sponsor’s Banking Information is invalid. |
Contact your bank and/or internal finance department to ensure that all Banking Information is entered correctly in the Secure Website:
Update the Banking Information in the Secure Website as needed, then re-sign the Plan Sponsor Agreement. Refer to Application Submission: Banking Information, Manage Banking Information, and Reconciliation: Banking Information for step-by-step instructions. |
Account Manager Authorized Representative Designee(s) with the Manage Banking Information privilege |
| Invalid user account status: Account Manager is Disabled |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Disabled – Federal Security Regulations require that a user log into CMS' RDS Secure Website at least every 180 days to maintain an active account. If you do not log into the RDS Secure Website at least every 180 days, your user account will become disabled. |
Enable the Account Manager user role as soon as possible. Refer to Enable Your User Account for step-by-step instructions. |
Account Manager |
| Invalid user account status: Account Manager is Expired |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Expired – The user has been terminated and all credentials have been removed from the system. The Account Manager and Authorized Representative must be registered RDS Secure Website Users and maintain their active Login ID and Password. |
Reassign the expired Account Manager user role as soon as possible. User Management is the responsibility the Plan Sponsor. For data integrity and security purposes, CMS' RDS Center does not alter role assignments on the Plan Sponsor's behalf. Refer to Reassign the Account Manager and Authorized Representative Roles for step-by-step instructions. |
Authorized Representative |
| Invalid user account status: Account Manager is Inactive |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Inactive – CMS’ RDS Center detected an issue with the user’s registered email address. |
The Account Manager must log into the Secure Website to verify their email address. Refer to Verify Email Address for step-by-step instructions. |
Account Manager |
| Invalid user account status: Account Manager is Locked |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Locked – User accounts are locked after multiple failed login attempts. The user is required to change their password. |
The Account Manager must change their password to unlock their account. Passwords can be changed five (5) times in a 24-hour period. If a user changes their password the maximum five (5) times and then locks their account again on the same day, the user cannot change their password to unlock their account until 24 hours have passed. CMS' RDS Center cannot unlock user accounts. Refer to Change Password If Account Is Locked for step-by-step instructions. Note: Repeated login failure may be caused by a faulty Google Authenticator configuration on the device used for Multi-Factor Authentication (MFA). If you continue to experience trouble logging into the RDS Secure Website, CMS’ RDS Center recommends that you reset MFA before attempting to log into the RDS Secure Website. Please refer to the MFA Technical Article and Quick Start Guides on the RDS Public Website for step-by-step instructions associated with the type of device you are using. |
Account Manager |
| Invalid user account status: Account Manager is Pending |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Pending – The user has not registered an RDS user account. All RDS participants must complete Registration to access the Secure Website. |
The Account Manager must complete Registration and activate Multi-Factor Authentication (MFA). Refer to Register as an RDS Secure Website User and Account Manager Registration for step-by-step instructions. Note: If the pending user role is the result of a role reassignment related to a change of Plan Sponsor Name or Employer Identification Number (i.e., a change of ownership), refer to Report a Change of Plan Sponsor EIN or Company Name for more information. |
Account Manager |
| Invalid user account status: Authorized Representative is Disabled |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Disabled – Federal Security Regulations require that a user log into CMS' RDS Secure Website at least every 180 days to maintain an active account. If you do not log into the RDS Secure Website at least every 180 days, your user account will become disabled. |
Enable the Authorized Representative user role as soon as possible. Refer to Enable Your User Account for step-by-step instructions. |
Authorized Representative |
| Invalid user account status: Authorized Representative is Expired |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Expired – The user has been terminated and all credentials have been removed from the system. The Account Manager and Authorized Representative must be registered RDS Secure Website Users and maintain their active Login ID and Password. |
Reassign the expired Authorized Representative user role as soon as possible. User Management is the responsibility the Plan Sponsor. For data integrity and security purposes, CMS' RDS Center does not alter role assignments on the Plan Sponsor's behalf. Refer to Reassign the Account Manager and Authorized Representative Roles for step-by-step instructions. |
Account Manager |
| Invalid user account status: Authorized Representative is Inactive |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Inactive – CMS' RDS Center detected an issue with the user’s registered email address. |
The Authorized Representative must log into the Secure Website to verify their email address. Refer to Verify Email Address for step-by-step instructions. |
Authorized Representative |
| Invalid user account status: Authorized Representative is Locked |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Locked – User accounts are locked after multiple failed login attempts. The user is required to change their password. |
The Authorized Representative must change their password to unlock their account. Passwords can be changed five (5) times in a 24-hour period. If a user changes their password the maximum five (5) times and then locks their account again on the same day, the user cannot change their password to unlock their account until 24 hours have passed. CMS' RDS Center cannot unlock user accounts. Refer to Change Password If Account Is Locked for step-by-step instructions. Note: Repeated login failure may be caused by a faulty Google Authenticator configuration on the device used for Multi-Factor Authentication (MFA). If you continue to experience trouble logging into the RDS Secure Website, CMS’ RDS Center recommends that you reset MFA before attempting to log into the RDS Secure Website. Please refer to the MFA Technical Article and Quick Start Guides on the RDS Public Website for step-by-step instructions associated with the type of device you are using. |
Authorized Representative |
| Invalid user account status: Authorized Representative is Pending |
The Account Manager and Authorized Representative roles must be in an Active status for the Plan Sponsor to receive payment. Payment requests will not be processed until the user’s status is updated to Active in the Secure Website. Pending – The user has not registered an RDS user account. All RDS participants must complete Registration to access the Secure Website. |
The Authorized Representative must complete Registration and activate Multi-Factor Authentication (MFA). Refer to Register as an RDS Secure Website User and Authorized Representative Registration for step-by-step instructions. Note: If the pending user role is the result of a role reassignment related to a change of Plan Sponsor Name or Employer Identification Number (i.e., a change of ownership), refer to Report a Change of Plan Sponsor EIN or Company Name on the RDS Public Website for more information. |
Authorized Representative |
| Invalid application status due to Banking Information change |
The application must be in one of the following statuses for the Plan Sponsor to receive payment:
If a payment request was submitted and the application is not in one of these statuses, this indicates that the application’s Banking Information was changed, and the Authorized Representative must re-sign the Plan Sponsor Agreement. |
Re-sign the Plan Sponsor Agreement. Refer to Application Submission: Review & Submit Application for step-by-step instructions. |
Authorized Representative |
| Appealed Reconciliation Final Payment Request significantly varies from Estimated Subsidy | After reviewing the Reconciliation Final Payment Request submitted by the Plan Sponsor via appeal, RDS Center determined that the Reconciliation Final Payment Request significantly varies from the subsidy estimate disclosed during appeal submission. |
The Plan Sponsor must review the Final Reconciliation Final Payment Request to ensure accuracy. Please respond to any requests for additional information or action on the part of the Plan Sponsor as soon as possible. |
Account Manager Authorized Representative Designee with Submit Appeal privilege |
| Potential duplicate cost reports for the same Benefit Option/Plan Year Month combination | Two or more cost reports have been submitted for the same Benefit Option for the same month(s) included in the payment request. CMS’ RDS Center cannot conclusively determine whether the cost reports are duplicates. |
Review submitted costs included in the payment request. If costs were reported correctly, contact CMS’ RDS Center. If costs were reported incorrectly, the payment request must be cancelled and resubmitted. For step-by-step instructions, refer to the Common Question, “How may a Plan Sponsor request cancellation of a payment request?” Refer to Changing Cost Reporter Vendors and Doubling Costs on the RDS Public Website for more information. Please respond to any requests for additional information or action on the part of the Plan Sponsor as soon as possible. |
Account Manager Authorized Representative Designee with Report Costs privilege |
| Reported costs exceed allowable costs for payment request | The Gross Eligible Costs included in the payment request are too high for the Unique Retiree Count, Benefit Options, and/or Subsidy Periods included in the Covered Retiree List (CRL). Plan Sponsors can only submit interim or final costs for the Qualified Covered Retirees (QCRs), Benefit Options, and Subsidy Periods listed in the CRL. |
Request and download the most recent CRL, then complete a detailed comparison of the Plan Sponsor's internal records of Qualifying Covered Retirees (QCRs), Benefit Options, and Subsidy Periods with CMS' RDS Center records represented by the CRL. The Plan Sponsor will be instructed to make changes to the Unique Retiree Count to support the existing payment request by submitting an updated Monthly Retiree List, or the payment request will be cancelled. For step-by-step instructions, refer to the Common Question, “How may a Plan Sponsor request cancellation of a payment request?” Please respond to any requests for additional information or action on the part of the Plan Sponsor as soon as possible. |
Account Manager Authorized Representative Designee with View/Send/Receive Retiree Data privilege |
| Reported Gross Eligible Costs exceed Maximum Gross Eligible Costs for Reconciliation Final Payment Request |
The Gross Eligible Costs included in the Reconciliation Final Payment Request for a specific Benefit Option are too high for the number of Qualified Covered Retirees (QCRs) enrolled in the Benefit Option. These failures are detected after submission of the Reconciliation Final Payment Request. |
The Plan Sponsor must review the costs for this payment request as a whole and for the specific Benefit Option for accuracy and provide an explanation for exceeding the Maximum Gross Eligible costs for the Benefit Option. Refer to Cost Reporting Example Illustrating Gross Eligible Costs Exceeding Maximum Possible Gross Eligible in the RDS User Guide for more information. Please respond to any requests for additional information or action on the part of the Plan Sponsor as soon as possible. |
Account Manager Authorized Representative Designee with Report Costs privilege |
| Reported Gross Eligible Costs do not meet the Cost Threshold |
The Gross Eligible Costs included in the payment request do not meet the minimum Threshold Reduction for the Unique Retiree Count. The Threshold Reduction amount is calculated per Qualifying Covered Retiree and aggregated by Benefit Option and plan month. The Threshold Reduction amount is not eligible for subsidy and reduces the Gross Retiree Cost when calculating subsidy. |
Request and download the most recent CRL, then complete a detailed comparison of the Plan Sponsor's internal records of Qualifying Covered Retirees (QCRs), Benefit Options, and Subsidy Periods with CMS' RDS Center records represented by the CRL. If reported costs included in the payment request do not meet the minimum Threshold Reduction, the Plan Sponsor will be instructed to make changes to the Unique Retiree Count to support the existing payment request by submitting an updated Monthly Retiree List, or the payment request will be cancelled. For step-by-step instructions, refer to the Common Question, “How may a Plan Sponsor request cancellation of a payment request?” Please respond to any requests for additional information or action on the part of the Plan Sponsor as soon as possible. For more information on accurately calculating Threshold Reduction, refer to Underreporting Threshold Reduction and Limit Reduction. |
Account Manager Authorized Representative Designee with View/Send/Receive Retiree Data privilege |
| Reasonability of Reported Gross Eligible Costs | The payment request includes unusually high or unusually low Gross Eligible Costs for the Unique Retiree Count included in the Covered Retiree List (CRL). The reported Gross Eligible Costs per Qualified Covered Retiree (QCR) is too high or low based on the maximum number of QCRs contributing to the Threshold Reduction. |
If reported costs included in the payment request are unusually high or unusually low, the Plan Sponsor must review cost reports to ensure accuracy and provide an explanation to support the reported costs compared to the Unique Retiree Count. The Plan Sponsor should review the reported costs vs. the maximum number of retirees recorded in the most recent CRL. This number should be referenced against the Cost Threshold and Cost Limit By Plan Year on the RDS Public Website. Please respond to any requests for additional information or action on the part of the Plan Sponsor as soon as possible. |
Account Manager Authorized Representative Designee with Report Costs privilege |
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