Our sister company 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.