The Annual Plan Year Application is the fundamental component of the Retiree Drug Subsidy (RDS) Program. Each year, Plan Sponsors create a new application in the RDS Secure Website. In the modernized RDS Secure Website, Plan Sponsors can create new applications in two different ways. The Plan Sponsor can either create a new application from scratch by entering all new application information, or the Plan Sponsor can create a new application by copying information from an existing prior application. A copied application retains all of the original application's Benefit Options, Actuary assignments, and Banking Information, but allows the Plan Sponsor to modify any application information that may be changing for the new Plan Year.
Regardless of how the Plan Sponsor chooses to create an application, certain required application information must be defined for an application to be considered complete and RDS eligible. Much of this required application information is defined during the Application Submission Process, before submission, whereas other required application information cannot be defined until an application is approved, after submission. The following summary will tell you everything you need to know about Application Information before and after submission.
Before submission, the Plan Sponsor must provide the following application information:
- Identifying information, including Plan Sponsor ID, Application Name/Plan Name, and Plan Year Start & End Dates;
- Benefit Options in which retirees will be enrolled, and Retiree Submission Method for each Benefit Option;
- Assign an Actuary who will Attest Actuarial Equivalence;
- Banking Information, including Account Information, Bank Contact, and Bank Address;
- Electronic signature of the Plan Sponsor Agreement by the Authorized Representative to Review & Submit Application; and
- Define the initial retiree population for the plan year by uploading the Valid Initial Retiree List.
After submission, once the application status has changed to “Approved,” the Plan Sponsor must provide additional information during Payment Setup:
- Assign Payment/Cost Privilege to Account Manager;
- Identify Payment Requesters other than the Authorized Representative, if applicable;
- Identify Cost Reporters, such as Designees and/or Vendors, if applicable; and
- Assign Cost Reporters to Benefit Options so that each Benefit Option has at least one cost reporter—Account Manager, Designee, or Vendor—to submit cost data on behalf of the Plan Sponsor.
The Plan Sponsor can change some (but not all) application information after an application is “Approved,” such as:
- Application Name/Plan Name;
- Retiree Submission Method for each Benefit Option;
- Banking Information;
- Add, Change, or Delete Qualified Covered Retirees from the application by submitting a Monthly Retiree List; and
- Recomplete Payment Setup to change Payment Requesters for the application and/or Cost Reporters for each Benefit Option.
However, some information cannot be changed after an application is “Approved,” such as:
- Plan Sponsor – Once an application is created under a Plan Sponsor account, the application cannot be transferred to a different Plan Sponsor account. All Plan Sponsor account information (including Plan Sponsor ID, Employer Identification Number, and Organization Name) applies to the application in perpetuity.
- Plan Year Start & End Dates – If the Plan Year Start/End Dates on the submitted application are incorrect, the Plan Sponsor must contact CMS' RDS Center. If the Plan Sponsor needs to shorten the plan year originally submitted with the application, refer to Common Question 7000-7.
- All Benefit Option information except Retiree Submission Method – Retiree Submission Method can be changed at any time up to and including Reconciliation: Finalize Covered Retirees.
- Actuary assignment – Attesting to the Actuarial Equivalence of the Benefit Options 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. Therefore, the Actuary assignment cannot be changed after submission.
For more information on providing and maintaining Application Information throughout the application lifecycle refer to the following topics in the RDS User Guide:
For more information on providing and maintaining Plan Sponsor Information, refer to the following topics in the RDS User Guide:
- Manage a Plan Sponsor Account
- Change Registered Plan Sponsor Information
- Report a Change of Plan Sponsor EIN or Company Name
For more information on managing your RDS Secure Website user account, including personal information and login information, refer to User Management in the RDS User Guide.
If you have questions about these or any other RDS topics, please contact CMS’ RDS Center.