CMS’ RDS Center recently hosted a webinar that provided an overview of RDS program changes. One of the most exciting changes for our firm is that RDS has now simplified the process for requesting a reopening! Below is a summary of this change.
Appeals Reopening Functionality
The new appeals functionality allows plan sponsors to request a reopening using the RDS Secure Website rather than by sending a hard copy request.
In addition to the new reopening functionality, plan sponsors can upload and view supporting documentation using the RDS Secure Website. Here’s a brief review on completing these tasks:
Appealable Initial Determinations
An initial determination is the decision made by CMS’ RDS Center in response to information that the plan sponsor submits. There are the two types of initial determinations for which a plan sponsor may request a reconsideration or a reopening. Reopening is related to the second type of initial determination: when the plan sponsor disagrees with the reconciliation final payment determination and therefore wants to request a reopening.
An appeal classified as a reopening is defined by RDS as follows:
Reopening Reconciliation Final Payment: The Plan Sponsor has completed Reconciliation for a specific plan year and has discovered issues impacting subsidy dollars. The request for reopening must be submitted within 4 calendar years from the date that the CMS’ RDS Center provided the Reconciliation final payment determination.
Information That Must Be Included in Reopening Requests
Requests for reopening must comply with Federal regulations at 42 C.F.R. §423.890(d). To reopen a Reconciliation Final Payment Determination: Plan Sponsor Correcting Inaccurate or Incomplete Data, the reopening request must include:
- The plan sponsor’s Name, Plan Sponsor ID, Application ID, and contact information.
- Indication that the plan sponsor wishes to correct inaccurate or incomplete data, and is requesting a reopening.
- A request that the plan sponsor be given the opportunity to formally submit the updated data, by benefit option, by month, by resubmitting its reconciliation payment request or its final payment request using the RDS Secure Website. The plan sponsor should also disclose the amount of subsidy it received for the application.
- The gross costs, cost threshold reductions, cost limit reductions, and price concession amount that the plan sponsor now wishes the subsidy to be based upon. (For this purpose, this data can either be broken down by benefit option by month, or can be submitted in the aggregate for the entire application.) These amounts should be based upon what the plan sponsor now believes to be its accurate retiree list.
- A description of the specific facts and circumstances, including the specific reasons why the data submitted with the Reconciliation or Final Payment Request was inaccurate or incomplete, and whether or not the plan sponsor believes the Covered Retiree List it agreed to before submitting its reconciliation or final payment request was accurate.
- If the plan sponsor believes the Covered Retiree List agreed to before submitting reconciliation or final payment request was inaccurate, they must include the specific reasons why.
- In any case, the plan sponsor must specify the number of retirees the plan sponsor now believes will be included in the new Covered Retiree List.
Steps to Request Reopening on the RDS Secure Website
After the inaccurate or incomplete data has been analyzed, aggregated and corrected, it’s time to submit the reopening request on the RDS Secure Website’s Application List page. You can get complete step-by-step instructions at the online RDS User Guide (click on the Step-by-Step Instructions tab).
How Can RDS Services, LLC Help?
Although this new functionality streamlines the request for reopening to the CMS’ RDS Center, the complexities of analyzing historical claims and retiree eligibility data still exist. As the industry leader in the RDS Program, we can manage all aspects of the reopening:
- Auditing and aggregating
- Submitting the request for reopening using the new functionality
- All the follow up
- Completing your reopening reconciliation
- Getting you, the Plan Sponsor, your deserved additional subsidy