When a Plan Sponsor, after submitting its Reconciliation payment request, or its final payment request using the RDS Secure Website Reconciliation process, discovers that it agreed to inaccurate (as opposed to incomplete) retiree data and/or reported inaccurate cost data (see "For purposes of the RDS Program, what is "inaccurate" data, as opposed to "incomplete" data?" for examples of what constitutes inaccurate data), it must immediately determine whether the inaccurate data had the net effect of causing the Plan Sponsor to be paid too much or too little in subsidy for the application (or that the Plan Sponsor will be paid too much or too little, after CMS processes the Reconciliation or final payment request). If so, the Plan Sponsor must immediately disclose to CMS the correct gross costs, cost threshold reduction, cost limit reduction, and price concession amount in the aggregate, for the application (i.e., this post-Reconciliation or post-final payment data need not be broken down by Benefit Option, by month, for purposes of this disclosure to CMS).
The Plan Sponsor also should immediately quantify the difference in subsidy caused by the corrected data, and should immediately report, in that same disclosure, that amount to CMS (regardless of the amount). The Plan Sponsor must disclose this information either by submitting a reopening request, or by otherwise disclosing the data to CMS. For more information on disclosing the data, refer to "How would an RDS Plan Sponsor disclose to CMS the correct, post-Reconciliation or post-final payment data, and the difference in subsidy caused by the corrected data, other than by requesting a reopening?"
After the Plan Sponsor discloses to CMS the subsidy discrepancy using one of those two methods, CMS will notify the Plan Sponsor of any further action the Plan Sponsor must take, if any.