Reassigning the Authorized Representative (AR) and Account Manager (AM) Roles

User Management is a critical function for individuals administering RDS Plan Sponsor accounts. User Management tasks can only be completed by the Account Manager (AM) and/or the Authorized Representative (AR) in the RDS Secure Website (SWS). 
These tasks include:

• inviting individuals to register as SWS users,
• assigning individuals to applications, 
• assigning individuals application-specific privileges to complete specific RDS tasks (for example, reporting costs, requesting payment, submitting appeals, etc.) while meeting RDS’ separation of duties requirements. 

CMS’ RDS Center understands that all organizations that participate in RDS—commercial businesses, government agencies, nonprofits, religious organizations, and unions—are subject to staffing and organizational changes that could impact user role assignments. However, systematic and security constraints in the SWS determine how quickly a role reassignment can be processed. 

As a reminder, AM and AR reassignments do not take effect immediately. 

When reassigning these roles, please keep the following information in mind:

New AMs & ARs cannot access the Plan Sponsor account on the same day the role is reassigned.

• Due to risks associated with not being able to complete program requirements, reassignment of the AR role should not be performed within the 24 hours immediately preceding an Application or Reconciliation deadline. 
• Terminated AMs & ARs will be valid on the account until 11:59 PM Eastern Time (ET) of their Termination Date.
• Newly assigned AMs & ARs are effective on the account at 12:00 AM ET on the day immediately following the Termination Date of the previous user.
  • For example: If the AM role is reassigned on June 30 with a Termination Date of June 30, the terminated AM will be valid until 11:59 PM ET on June 30; the new AM will have access to the Plan Sponsor account and applications no earlier than 12:00 AM ET on July 1, predicated on a successful registration. 

Registration for a user account does not guarantee same day access.

• The Registration email for the newly assigned AM or AR is sent as soon as the role is reassigned, regardless of their Effective Date. It is possible for an individual to register before their Effective Date.
  • In this scenario, the new AM or AR who completes Registration and Multi-Factor Authentication (MFA) activation can log into the RDS Secure Website (SWS) but will not have access to the Plan Sponsor account itself or its associated applications until 12:00 AM ET on their Effective Date.
    • For example: If the AR role is reassigned on June 30 with a Termination Date of July 31, the terminated AR will be valid until 11:59 PM ET on July 31; the new AR can register any time between June 30 – July 31, but will not have access to the Plan Sponsor account and its applications until 12:00 AM ET on August 1, predicated on a successful registration. 
• If a new AM/AR does not pass automated identity validation, CMS’ RDS Center will contact the individual to resolve the issue using the email address provided during Registration; this process could take multiple business days to coordinate and complete. 
• Users should respond to emails from CMS’ RDS Center about pending user accounts as soon as possible. Failure to do so may delay access to the Secure Website. 

Termination Dates cannot be in the past.

• You cannot backdate a role reassignment. 
• You must choose the current day or a future date.
• Do not select an Application or Reconciliation Deadline as the Termination Date. 

Reassigning a Designee or Actuary to an AM or AR role takes multiple days to complete.

• If the new AM or AR is currently a registered SWS user with a different role (e.g., Designee), that user must be removed from all applications and Plan Sponsor accounts they are currently associated with before being assigned as the new AM or AR.
• Allow one business day after the user's Termination Date before assigning the new role.
  • For example: If an existing Designee needs to become an AM on June 30, the Designee must be deleted from all applications they’re assigned to, regardless of the Application Status, before June 28. If they work for multiple Plan Sponsors, this could take multiple days for the Designee to coordinate with each of their Plan Sponsors.

The AR role has critical functions that only they can perform.

• The AR is the only individual who can complete the final step of the Annual Plan Application by signing the Plan Sponsor Agreement.
• The AR is the only individual who can complete the final step of Reconciliation by signing the Reconciliation Agreement. 
• Due to risks associated with not being able to complete program requirements, reassignment of the AR role should not be performed within the 24 hours immediately preceding an Application or Reconciliation deadline. 
• For best practices, AR reassignment should be executed well in advance of deadlines and only when necessary.
• User Management is the responsibility of the Plan Sponsor. For data integrity and security purposes, CMS’ RDS Center does not alter registered user information or role assignments on the Plan Sponsor’s behalf. 

CMS’ RDS Center Call Center was discontinued in 2015.

• CMS' RDS Center's official means of communication to the Plan Sponsor is through email, at rds@cms.hhs.gov. 
• Take the necessary steps to ensure that emails sent from the RDS@cms.hhs.gov email address are not moved, deleted, blocked by any spam filters, or Blocked Senders List.
• Registered users are encouraged to use the Support Request feature of the SWS.
• CMS’ RDS Center does not maintain a phone number for telephonic support.

CMS’ RDS Center strongly encourages all Plan Sponsors to execute User Management and AM/AR Role Reassignment tasks well in advance of their Application and Reconciliation Deadlines. 

Thank you for your continued participation in the RDS Program! For additional support, please contact CMS’ RDS Center.