RDS Services, LLC has been servicing Plan Sponsors under CMS’s Retiree Drug Subsidy program since it was launched in 2005. However, from the program’s inception, there have been questions as to how a plan sponsor amends or corrects a prior period RDS reconciliation.
Regulations allow plan sponsors, under very specific circumstances, to remedy situations where inaccurate or incomplete data was inadvertently submitted on application years that are now closed. These regulations allow a plan sponsor to recoup subsidy that was missed in prior years. Our experience shows that recoveries can range up to 25%! This process is commonly known as an RDS Reopening.
Retiree Drug Subsidy (RDS) Reconciliation
The purpose of the RDS Reconciliation process is to report actual total gross retiree prescription drug costs, including actual rebates and price concession data, for a specific application year. The RDS program allows Plan Sponsors to go back and “reopen” past reconciled plan years to see if they captured all eligible members and eligible prescription drugs that qualify for Retiree Drug Subsidy under the CMS RDS Program.
The Centers for Medicare and Medicaid Services (CMS) recognize that Plan Sponsors or their vendors may not have the systems and processes in place to identify optimal membership and maximize eligible prescription drug claims. Reopening reconciled plan years gives Plan Sponsors a second chance to capture the entire subsidy that they are owed.
Recouping Your Subsidy
If you believe that you may be due additional subsidy, it is important to act right away. There are very specific steps that need to be followed and deadlines that must be met. Engaging an organization that understands the ins and outs of this program will help you identify and recoup the maximum subsidy due to you.
How We Can Help
RDS Services, LLC has a team of experts ready to manage all aspects of your reopening – from auditing and aggregating past claim and eligibility files to completing the Request for Reopening and submitting the necessary data to CMS. Getting started is easy. Contact us for a no-risk consultation.
Our fee structure is based on a percentage of recovery. If there is no additional subsidy, there is no fee.
Additional Subsidy Payment
When additional subsidy is acknowledged by the CMS, funds are deposited directly into the Plan Sponsor’s designated bank account.
It is important to note that at times, a Reopening and Reconciliation effort shows that everything was filed correctly and no inaccuracies exist. In this case, there would be no additional subsidy. Moreover, if the inaccuracy resulted in a Plan Sponsor receiving too much subsidy, by law this must be reported as part of the Reopening and the excess subsidy funds must be returned to CMS.
