When a Plan Sponsor 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) after submitting a Reconciliation payment request or final payment request using the RDS Secure Website Reconciliation process, it must immediately determine whether the inaccurate data had any of the following net effects:
- the Plan Sponsor was paid too much or too little in subsidy for the application
- the Plan Sponsor will be paid too much or too little in subsidy for the application after CMS processes the Reconciliation or final payment request
If either scenario is true, the Plan Sponsor must 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 inaccurate or incomplete final payment data need not be broken down by Benefit Option, by month, for purposes of this disclosure to CMS).
The Plan Sponsor must disclose this information to CMS by submitting an Appeal via the RDS Secure Website in the form of a request for Reconsideration of Reconciliation Final Payment or a request for Reopening of Reconciliation Final Payment. The Plan Sponsor should immediately quantify the difference in subsidy caused by the corrected data and report that dollar amount to CMS as part of the Appeal (regardless of the amount).