User Roles for the Application Submission Process

This section describes the user roles required to complete and submit an application:

• Account Manager
• Authorized Representative
• Actuary
• Designee
• Vendor
• Coordination of Benefits (COB) Contractor: Voluntary Data Sharing Agreement (VDSA) or Mandatory Insurer Reporting (MIR)
• Application Submission Process User Role Table

RDS Secure Website users may only function in one user role in the RDS Secure Website, so an individual must be assigned the same user role for each Plan Sponsor to which they are associated.

To enforce a separation of duties, a user can only either report cost data OR request payments on a single application. A user cannot assume both duties on the same application.

Account Manager

• Required in order to complete the Application Submission process;
• Initiates the Application Submission Process;
• Manages the completion of tasks within the Application Submission Process; and
• Designates a qualified Actuary on each application (the Authorized Representative or Designee with the Assign Actuary privilege may also designate a qualified Actuary on each application).

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Authorized Representative

• Required in order to complete the Application Submission process;
• May begin a new application after the Plan Sponsor ID has been created;
• Is the only individual who can sign the Plan Sponsor Agreement and submit the completed application to CMS' RDS Center; and
• Designates a qualified Actuary on each application (the Account Manager or Designee with the Assign Actuary privilege may also designate a qualified Actuary on each application).

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Actuary

• Required in order to complete the Application Submission process;
• A qualified Actuary completes the Electronic Signature for the attestation of the Actuarial Equivalence of the Benefit Option(s) specified in the application by a Plan Sponsor:
  • A qualifying Benefit Option is one for which the actuarial value of the retiree prescription drug coverage under the plan is at least equal to the actuarial value of the defined standard prescription drug coverage under Medicare Part D.

• A qualified Actuary chooses whether multiple Benefit Options will be combined to pass the Actuarial Equivalence Net Test:
  • A qualified Actuary attests to the gross value of each Benefit Option, and to the net value of the combined Benefit Options.
  • A qualified Actuary attests to both the gross and net values of each Benefit Option when NOT combining Benefit Options.
• An RDS Secure Website user registered as an Actuary may not serve as the Account Manager, Authorized Representative, or Designee for any application.
• In order for actuaries to be invited to attest an RDS application, they must first opt-in to participate in the RDS program on the American Academy of Actuaries website. Refer to American Academy of Actuaries: The Retiree Drug Subsidy Program for information on this process.

Note: The Actuary's First Name, Last Name, and Membership Number must be entered into the RDS Secure Website exactly as it appears on the Actuary's American Academy of Actuaries Membership list.

The Actuary may test equivalence using one of two possible options:

• Attest Single Benefit Options
  • The Gross Value Test confirms that the total value of benefits provided to the beneficiary under the employer plan is at least as generous as what they could receive under Medicare Part D; and
  • The Net Value Test takes into account the extent of the employer financing of the drug coverage so that the net value of the employer plan to the beneficiary is at least equal to the net value of what they would receive under Medicare Part D.
• Attest Combined Benefit Options
  • A Gross Value Test for each separate option; and
  • A Net Value Test for the combined options.

Note: If an application lists more than one Benefit Option, a qualified Actuary must designate whether two or more Benefit Options are being combined for the purpose of determining that the plan meets the Actuarial Equivalence Net Test.

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Designee

Designees are optional – the Plan Sponsor does not need to assign Designees to applications nor are Designees required to submit applications. If the Plan Sponsor chooses to assign Designees to their applications, Designees can be assigned and registered to an RDS application before or after Application Submission. A Designee can be assigned privileges by the Account Manager or Authorized Representative in order to assist with RDS Program activities which may include:

• Assign Actuary
• Complete Banking Information
• Define Benefit Options
• Delete Application
• Report Costs
• Request Extension
• Request Payment
• Submit Appeal
• View Attestation Summary
• View/Send/Receive Retiree Data
• Withdraw Application

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Vendor

• A Vendor is an optional assignment that may be responsible for submitting a Valid Initial Retiree List.
• Vendors that are submitting Connect:Direct files must contact CMS' RDS Center to obtain a Vendor ID for registration purposes.

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Coordination of Benefits (COB) Contractor: Voluntary Data Sharing Agreement (VDSA) or Mandatory Insurer Reporting (MIR)

• A COB contractor is an optional assignment that may be responsible for submitting a Valid Initial Retiree List through VDSA or MIR.
• A VDSA Plan Number or MIR Reporter ID is necessary to establish the method and source for retiree list Electronic Data Interchange (EDI).
• Contact the CMS Coordination of Benefits (COB) Contractor at cobva@ghimedicare.com. The usual timeframe for completing the agreement and testing with the CMS COB contractor is 60 to 90 days for new agreements.

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Application Submission Process User Role Table

The following table describes each step of the Application Submission Process and the user roles and privileges required to complete each step:

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