 Channel and your name appears up here to my immediate right or left if you would make your way up here We would appreciate it, please just so you know Mark Gary just so you know they have given me a hundred and four questions We will not make it through we are going to go through the order in which they gave him to me There's a hundred and four questions. That is Good afternoon Welcome back. Did you enjoy that longer break? Yes, okay We are going to spend some time now doing a Q&A with the panel members who have presented today What will happen is the questions that have been submitted and I will tell you that I have over a hundred and four Written questions up here. There are approximately 250 more in the CMS room, so you all have done an extraordinarily good job All of those that are answered here Will be put up on the website in addition to those that are not answered here today and tomorrow so if your question is not one that was Answered today Please be rest assured that your question is very important to us and we want to be sure That it is answered in the future what happened with the questions that were submitted today a team of CMS staff personnel went through and Looked at all the duplicates where we had duplicates and then came up with the questions So that is how we will take this process. I'd like to introduce the panel To my immediate left is Mark Hamelberg Next to Mark is Jim Mayhew and next to Jim is Carol Gilbo To my immediate right is Patricia Ambrose To her right is David Gardner to his right is John Albert and to his Right is a new face up here today, and that's Gary Calabrese They will be answering the questions if the question was directed to a specific person That person will answer it otherwise all of these people wear Wonderful hats and they are interchangeable So whichever person up here wants to answer it will answer the question the first question is Will members parentheses retirees be allowed to call the RDS center? Will members parentheses retirees be allowed to call the RDS center? I think I should answer that question Retirees will actually be calling 1-800-Medicare that is totally dedicated to answering any beneficiary question Just to add to that If a if a beneficiary is by some chance Calling in on the RDS helpline We will have a facility there in the IVR to help redirect them to 1-800-Medicare so The RDS Center help helpline is not staffed to handle, you know, 40 million phone calls So but 1-800-Medicare allegedly is so How many employees will be working the customer service lines? How many employees will be working the customer service lines? As we need to handle all of the questions Of course, it's a new program and probably with our website being so available and Being informational. We really don't anticipate a lot of calls, but we will be there to help you What did you just say? Would you like to repeat that? I? Got it. I think greater than one greater than one good. Okay If we aggregate plans for net test can the same actuary who did the gross test Attestation also do the net test attestation If we aggregate plans for a net test can the same actuary who did the gross test attestation? Also do the net test attestation the answer is Absolutely, it's the plan sponsor can have the same actuary do both the gross and the net test Even in the instant whether aggregating the net test Several options within the net test. Thank you How quickly after a monthly submission to the RDS website? Will the response file be available if you submit some? subsidiary data through the USDA Is that it's not used? subsidy data Yeah, through the VDF a I think is what I was gonna make a joke about mad disease, but I decided us to DA Now as you can see my challenge is being able to decipher everyone's handwriting, so If that brings a smile to your face, that's a good thing on a monthly basis. How quickly will there's? Refault response file be provided Currently or quarterly exchange You must adhere to a 45-day response How quickly after a monthly submission to the RDS website? Will the response file be available if you submit subsidy data through the VDSA on a Monthly basis how quickly will the response file be provided currently or quarterly exchange? It must be adhered to in a 45-day response Well, I mean for the for the VDS say the only the only delay that would occur Might be a day or two as we as the data is passed back through the COB contractor to the employer submitting that data But essentially, you know if you have multiple RDS IDs that you submit through your VDS say RDS will basically return those to the to us as they process each one of those IDs And we will get them back to you So, you know, whatever time frame they that they have on there and add maybe a couple of days at most To do the work that we need on our end if we have to capture any of that data for subsidy reporting records, but we're looking at turning around the the N&D records as part of that non-MSP file within a few days Thank you Can we submit some records using the Social Security numbers and others using the HICN? Or do we have to use Social Security numbers for all records or HICN for all records? Can we submit some records using Social Security numbers and others using the HICN or? Do we have to use Social Security numbers for all records or HICN for all records? You actually have your choice In your retiree file submission, some of your retirees could be submitted with the social security number and others with the HIC number as long as we have one or the other per record. That's fine. What will happen if we have an individual covered under our prescription plan but the individual has coverage with another employer? What will happen if we have an individual covered under our prescription plan but the individual has coverage with another employer? Good question. That's going to really depend on the different scenarios like it's far under. For instance, you could have a participant in your plan. He's retired and Medicare eligible and you can collect a subsidy for that person and that person may have a spouse who's also Medicare eligible, but that spouse, an active plan with her employer, well under the MSP rule, the spouse's active plan would be primary and then your plan would be secondary and you could still perhaps collect the subsidy for the cost incurred under your plan for the spouse. So there are different scenarios where you could a spouse or a dependent could have two coverages and you could still collect the subsidy. If I could just add onto that, of course, you can't get subsidy payments on the same expense, two different employers over the same expense. In a case like what Jim just described, if your plan is secondary to somebody else you may not have actually very much incurred costs, but to the extent that you do and you otherwise comply with the other rules, you can get subsidy payments to reflect the cost incurred. Again, just to add to that, of course, the thresholds and the limits would apply too, so it's even less likely that there would be remaining. Does the non-MSP file for the VDSA need to be submitted monthly or can it still be sent on a quarterly basis like the MSP file? It's your choice. Flexibility. And there are certain ramifications to that. If you are interested in getting the more rapid feedback from the RDS Center, then you can certainly submit as frequently as monthly. One advantage of the MSP file is that you can still submit as monthly. With the VDSA process, I should have mentioned this with the previous question, is that we're going to be populating that RDS response with the Medicare entitlement information if it exists, so that's part of that several-day turnaround time on our end is to populate those subsidy records, even if they're accepted by RDS with Medicare A and B and entitlement information. Okay. When CMS sends notification that they are rejecting certain enrollees, who gets the notification? The AR, AM, or other designee. When CMS sends notification that they are rejecting certain enrollees, who gets the notification? The AR, AM, or other designee. I'll answer that question. First off, the file is transmitted back. The notification file is transmitted in the same fashion or way that you submitted your retiree files. So if it was uploaded, if you're submitting your retiree files to the website, uploading to the website, then we would be able to do that. So if it was uploaded, if you're submitting your retiree files to the website, uploading to the website, then we will post your notification file there. Like and multiple people, the authorized rep, the account manager, and designees who are, have permissions to interact with the file transfer process are able to view those notifications, and all of them will receive an email. If you're sending, transmitting your retiree files, mainframe to mainframe, or via VDSA, the file goes to one place, and it's most likely going to be one of your technical resources who's picking up that file and producing a report for you or something along those lines. But the email that goes out from the RDS Center to let you know that the file was sent goes to all of those individuals, users of the website, the authorized rep, the account manager, and the designees. However, that email does not have any detail information in it about a particular retiree. It's just a notification or an alert that a notification file is being sent. How does the AR select the AM, quote, outside of the RDS system, end quote? I did not hear you describe the procedure. How does the AR select the AM, quote, outside of the RDS system, end quote? I did not hear you describe the procedure. Well, since it's outside of the RDS environment, there's no procedure, but it's, again, this is the flexibility. A plan sponsor has the right to enter into an arrangement with consultants or benefit administrators or anyone who they feel would best act on their behalf. So that is, again, outside the RDS Center system. And the first time the interaction happens with the RDS Center is when that account manager, after they've had the conversation and have the business arrangement established, that account manager would come in and register onto the website and introduce themselves and then link themselves to that authorized rep. For retirees with multiple records coming back due to breaks in eligibility, do we continue to submit their file even though they may not be eligible or do we have to wait for you to notify us to resubmit? For retirees with multiple records coming back due to breaks in eligibility, do we continue to submit their file even though they may not be eligible or do we have to wait for you to notify us to resubmit? Well, actually, if we've responded back with two periods of subsidy coverage, you don't need to resubmit that retiree on your monthly update unless there's some change that you're aware of that you would like to notify the RDS Center about. So we'll send you back to response records or multiple response records to show start and end dates for various subsidy periods for which you may claim the subsidy for this retiree. But unless you know of a change, there's no need to send another record. What if that most recent period, though, is a period of Part D entitlement that they're enrolling though, that they now know at the most recent time? The current time that the person has Part D, maybe that's what they're asking. Do you want to? You send back two records. The guy has subsidy for a certain period of time, but like say the past couple of months, he doesn't begin because he enrolled in Part D, maybe that's what they're asking is, do they resubmit them a quarter later? They have to wait to hear from you that the guy no longer has Part D. What our intent is, is that they wait to hear from us that there's been a change in their Part D enrollment. Thank you, John, for that. That would be a redundant record if it were to come back and it really would not add any value to our system. Unless you know of a change, there's no reason to send us a new update file. Update record, excuse me. Can you edit information once the continue button has been submitted and or clicked? Is there any information that cannot be edited once submitted? Can you edit information once the continue button has been submitted and or clicked? Is there any information that cannot be edited once submitted? You will be able to edit every page of your application prior to signing the plan sponsor agreement. I want to clarify kind of the button notation. Continue is generally an action that you take when you've completed that page and you wish to go on to the next one or back to your application status page. There will be an actual submit button for the plan sponsor to, well, it's really a sign button but he is submitting his signature. So I don't want to get that confused but as you say you're an account manager going page by page you can complete say your electronic fund transfer information and then as long as your authorized rep has not submitted the signed the plan sponsor agreement and submitted the application you can go back to that page and change it the next day or on another session on the website. And if you need to change the information after you submit it again there's always the withdrawal application option if you know the incorrect information or new information before the final application has been processed and approved in or rejected you have the ability to withdraw that back if you need to. How do we make sure retirees do not sign up for Part D? Can we tell them not to sign up for Part D? How do we make sure retirees do not sign up for Part D? Can we tell them not to sign up for Part D? The answer is now you cannot prevent a retiree from signing up for Part D. The retiree in all instances must have the choice to enroll in Part D. What a plan sponsor can do is educate their retirees as to the value of the employer's benefit the sponsor's benefit and in the value of the Part D and provide enough information to the retiree for them to make an educated choice as to what benefit is best for them. In order to designate an individual to have access to all the secure website features and response files do we check that they have access to Part 6 retiree list submission? In order to designate an individual to have access to all the secure website features and response files do we check that they have access to Part 6 retiree list submission? Yes, that's actually the... I presume we're talking about the page where you're designating or naming a designee for your application and in order for them to be able to view the response file and retiree list that would be the place where you would indicate that. That's true about any of the other sets of functionality too such as submitting an appeal or ultimately sending payment requests as well or dealing with the payment information. All of those items are listed or will be listed on that screen when you assign a designee's authority. Checking the box next to that authority is making an affirmative statement that this person is authorized based on my knowledge on their knowledge of whoever's doing it. That person does have the ability to do those functions. We have one health plan with one level of benefits for retirees. Different groups of retirees pay different rates for coverage depending on union, length of service, et cetera. Would we file one application or multiple? We have one health plan with one level of benefits for retirees. Different groups of retirees pay different rates for coverage depending on union, length of service, et cetera. Would we file one application or multiple? You know, it really boils down to how the sponsor administers the benefit. It's down from the few facts that are presented that the sponsor could conceivably call this one plan with the different retiree contributions being different benefit options under the plan and they could conceivably file one application for the whole plan and then segregate out the benefit option for the gross test. But again, it really boils down to how the sponsor administers the benefits for cobalt purposes and other purposes. And just a quick add on. Of course we mentioned earlier the start and end dates for the plan benefit year. For all of those options would also have to be the same in order for those options to be aggregated under one application. If the application has been filed prior to September 30th, 2005 and is not yet approved or denied and it is getting close to September 30th, 2005, will the applicant need to request an extension or is an extension needed? If the application has been filed prior to September 30th, 2005 and is not yet approved or denied and it is getting close to September 30th, 2005, will the applicant need to request an extension or is in an extension needed? The answer to that is no. The only time you would need to request an extension is if you were fearful that the authorized wrap or whatever your internal process is where we're not going to be completed by that cutoff date and time period. So it really is, do you need more time for the authorized wrap or other designees or the account manager to finish that application? That's really the driver. Once it's submitted, it's considered received by the RDS Center and it's timely. How long does the validation process take? Will your user ID password expire and if so, when? How long does the validation process take? Will your user ID password expire if so, when? I guess I'll take this one. We have a service level agreement to process the application once submitted within 15 business days. And it should take far less than that. Sometimes the EFT process can take a little bit longer than a day or two. The retiree file processing should really be a couple of days turnaround for that. So we're really expecting, now of course the program hasn't been started yet so we're really expecting to turn around the applications in less than that SLA. Your password will expire every 60 days as prescribed by CMS rules. So if you haven't been out on the website and you come back and you log in with an expired password you'll be prompted immediately to change that password in order to continue on working in the secure website. If the plan year begins after January 1, 2006, for example March 1, 2006, is the deadline this year still September 30th or is it later? If the plan year begins after January 1, 2006, for example March 1, 2006, is the deadline this year still September 30th or is it later? The deadline, let's say the plan year starts March 1. The deadline to get potential retiree drug subsidy benefit for January and February of 2006 will still be September 30th, 2005 with opportunity for a 30 day extension. The deadline for the plan year that ends in 2007, that would be a run from March 1, 2006 through February 28, 2007, that would be at least 90 days before March 1 which would be backtracking 90 days, I believe by November 30, 2005. If we need to update other roles for new people assuming those positions mid-year, how is this accomplished? If we need to update other roles for new people assuming those positions mid-year, how is this accomplished? You will be able to go in and change the designees on your application after it's been submitted and approved so you could replace, for example your authorized rep, you could replace your account manager, you can replace your designees and there will be a facility or a feature on the website for you to go in and change your designees to essentially expire ones that are no longer working or associated with your application and add a new designee, for example someone who might be taking over responsibilities for uploading your file and downloading the response file. There can only be one account manager and one authorized rep at a given time authorized in the system, so as Pat said, if you needed to change those individuals there would not be two individuals active at any one point, they would be a true replace. Is information given on the call center line guaranteed? Wait to hear part B. Can we rely and act on the information? Is information given on the call center line guaranteed and can we rely and act on that information? Believe and know that you can act on that information. The RDS helpline has been given all the information through CMS guidance and we're there to only provide the information that we have gotten fairly approved. As the program evolves our information will be updated. And to add to that I definitely agree. As more decisions are made with how this program is going to be implemented we will be updating the knowledge base that our CSRs have but an important distinction needs to be understood and that is that there are questions that should be directed to CMS and there are questions that should be directed to the RDS center. I believe we touched on that today in the customer service presentation. Questions pertaining to laws, regulations or how CMS has decided to implement those from a policy perspective absolutely must go to CMS. For those routine operational questions that we've, you know, issues we've talked about here with the use of the websites, submitting an application, proposing proposed payment processes as decisions are made CSRs are trained. So to the extent that your information needs are operational and focused then the RDS center helpline should help. In reference to the subsidy applications we need guidance on what is the prescription group number. We have carved out prescription benefits for multiple carriers and we are confused what is this number since everyone has different numbers depending on medical carriers. What we're asking for is that number. I think there was some confusion that we were creating a new group number or our prescription number. We're asking for a number of different numbers depending on what is the prescription group number. We're asking for a number of different numbers depending on the medical carrier. In reference to the subsidy applications we need guidance on what is the prescription group number. Or our prescription drug group number. We intend to use the existing group numbers that you're already using. So if you have for your benefit option under a particular insurance carrier a group number that's exactly what we want you to submit on your retiree file and exactly how we want you to set up your benefit option on the application. To the extent it identifies truly a unique benefit option on your plan. We did find there were some instances where the Rx group number was not specific enough to actually identify a specific benefit option under the plan. So that was feedback we got in the paperwork reduction act notice. We are trying to leverage whenever possible existing data that's already captured in the pharmacy network processing system with respect to drug claims. So that term is something that you'll find for example on an NCPDP transaction. So that's what we meant by the Rx group number. I hope that answers the question. What will be posted on the employer's group secure section of the RDS website after CMS receives the detailed utilization data from the health plan? Will there be aggregate information regarding the employer group subsidy payment? What will be posted on the employer group's secure section of the RSD website after CMS receives the detailed utilization data from the health plan? Will there be aggregate information regarding the employer group subsidy payment? We'll be talking about this more specifically tomorrow when we have our payment, our proposed payment methodology presentation and Q's and A's. So it may be best to save the answer until then but we are anticipating to have information about payments that we make to your bank account, summaries of those payments or payment notices on the account for the appropriate personnel who have been authorized by the account manager or the authorized rep to view payment-related information. So there will be those receipts out there in terms of specific retiree data. At this point, my guesses are still being defined. My guess is it probably will not be out there specific retiree data. So those will only be passed back and forth with reconciliation data files again. I'd like to table the rest of this answer until tomorrow. On a self-fund plan, if we do not have a group number, must our prescription carrier provide one? On a self-fund plan, if we do not have a group number, must our prescription carrier provide one? We're actually allowing you the flexibility to make up your own group number. We're calling it now the unique benefit option identifier. So as you're filling out your application for that particular benefit option, you may make up your own identifier that is meaningful to you as long as you use that same number on your application and your retiree list that you submit for each of your retirees. We need a unique benefit option identifier associated with every single retiree for the purposes of knowing and being able to track or in having knowledge in our database that this particular retiree on this day during your benefit year was covered under this specific benefit option under your plans. If that changes throughout the course of the year, the purpose of the retiree list data sharing and update files is so that we have the most recent information about that retiree and you have the most recent information about our feedback about that retiree. At reconciliation, it becomes very important for us to be able to know which what we're calling benefit option administrator would need to submit information on that retiree's drug costs. So if a retiree moves across plans or moves, excuse me, moves across benefit options throughout the course of the year, we'll have that audit trail and at reconciliation, we'll be able to marry the two, both the drug costs that were paid and that eligibility period to the benefit option. So that unique identifier is very important to make sure that that link happens in the appropriate way at reconciliation. We have concerns that we have correct social security numbers for spouses. What impact will incorrect social security numbers have on our subsidy application? If there is not a valid social security number, in other words, you provide to us a social security number and then we, in our batch file query that we do against our Medicare beneficiary database, if we do not get a hit, then that retiree will be rejected and the spouse will be rejected for the purposes of claiming safety. So if we do not get a hit, then that retiree will be rejected and the spouse will be rejected for the purposes of claiming safety and for the purposes of claiming subsidy. And just to give John Albert a chance to speak up here, the VDSA process works that same way, but you do have the ability to query individuals. If you are... Right, you have to have a valid number, but that's another process for which you can check. Yeah, I mean, if you want to... I mean, if you want to just find out if they have Medicare and you submit that as a query even through, like, basis, for example, I mean, if they're not found, it's, you know, most likely, you know, they just don't have Medicare or the social security number provided didn't match up to those personal identifying characteristics of the name, date of birth, and sex, et cetera. We do take it one step further and that is that Medicare maintains a cross-reference file of social security numbers to health insurance claim numbers, the Medicare number. And it is possible over the course of time that someone's social security number could change or their health insurance claim number could change. If you send in a valid name social security number combination and we search our records to make sure that there wasn't... It's not just not the latest and greatest version of that number. So we have that historical cross-reference. So even if you don't have the most current social security number or the most current health insurance claim number, we should get a match on our system through that cross-reference. How can we verify that an actuary is a AAA member in good standing? How can we verify that an actuary is a AAA member in good standing? As I indicated this morning, CMS was working with the American Academy of Actuaries to assign membership numbers to the actuaries who are going to be participating in the RDS application process. And it's my understanding that the American Academy of Actuaries will have a list of the actuaries along with their membership numbers on their website. And you can certainly validate that by going to the American Academy of Actuaries website or you can even call the American Academy of Actuaries directly and get the verification of their membership. What is an HIC number and who would have this number? What is an HIC number and who would have this number? The health insurance claim number is the number that Medicare assigns to individuals to uniquely identify them to our systems. I mean, just to kind of, this kind of relates to the, not the previous but the one before that question where you may not have a correct social security number, but if you do have both a HICN or health insurance claim number and an SSN, I would assume under RDS you would encourage them to submit both just in case one of them is incorrect. That's correct. Okay, because that's the same with the VDSA process. Sometimes to a key stroke error or whatnot, the social security number may be off a digit. And if that's the only number we get, we're not going to find them. But if you happen to have a health insurance claim number, we encourage you to submit that as well because we will find them through one of those two numbers if one of them is correct. It just increases your odds of having a match. And is it true under the VDSA process though that if they submit just a social security number on their record that they will get a valid health insurance claim number returned to them? Yeah, that's one of the data elements that we do provide back on the VDSA response where we do find Medicare entitlement. We actually provide you with that Medicare health insurance claim number so that on future submissions to update those records that you provide that HIC number, or HIC number back to us, which basically speeds up our ability to find that person when processing the file. For the monthly reporting of retirees, how do we count retirees who come back to work for us from one to 11 months during a planned year? Recognizing that they will be primary with Medicare for some months and employer primary for others. For the monthly reporting of retirees, how do we count retirees who come back to work for us from one to 11 months during a planned year? Recognizing that they will be primary with Medicare for some months and employer primary for others. Well, I mean, those would be submitted as unique records. Essentially through a VDSA process just like with the RDS process we're kind of building unique periods of, you know, for either subsidy or for Medicare secondary payer purposes. So, for example, somebody wanted to submit historical data over a period of a year on a VDSA file. You know, they're new to the program and want to basically get us caught up to where that person is. They would submit two separate records. One would be on the MSP file for that 11 months where they were working and it would have a start date of 2004 and a stop date of November 2004 and then would submit a second record probably claiming subsidy if they're now retired. They would submit an S record with that period reflected when they were not working. Right. I think, correct me if I'm wrong, Pat, but if you're not using a VDSA process under the RDS secure website file transmission method you would initially have that person on your retiree list at the beginning assuming that they were on that in that plan at the beginning of the year and then transition say in February so if it was a calendar year. That would come in on the initial retiree list with the application and then we would expect an update record showing a termination date that that person is no longer covered as a retiree under that plan. I guess that's assuming that there's not a shift in or there is a shift in plans. No, and then if they fall if they return to a retirement status then I would recommend you send an ad record for that new period of, you know, subsidy coverage. On the eligibility file submitted to CMS is it necessary to state what plan option the eligible member has? On the eligibility file submitted to CMS is it necessary to state what plan option the eligible member has? I think we've already answered that question. The answer is yes. Regarding actuarial attestation is it required? Previous documents had indicated that an organization could perform certain criteria without use of an actuary. In regards to actuarial attestation is it required? Previous documents had indicated that an organization could perform certain criteria without the use of an actuary. I'll take a crack at that. I'll break for a second. The short answer is if you're applying for the subsidy you must have a qualified actuary that signs off on the attestation. Now we have provided some guidance that enables actuaries to use some simplified methods that may simplify their calculations and their processes for arriving at their decision. But the actuary still signs off on the attestation as a condition of it being submitted to us and that's something that the statute essentially requires and it's not something that we would have the ability to change even if we wish to do it. All I can think of is that there may have been the question may be getting at situations where employers are not applying for the subsidy and the question is what must they do in determining whether their coverage is creditable or not. And we did provide some separate guidance that said that there isn't a statutory obligation that you have a qualified actuary sign off and attest to the value of your coverage and we gave guidance that tried to describe situations in which you may not need any actuary at all and other places you may be able to use an actuary but we don't have the same attestation obligation. In the context of the subsidy which is obviously what we're talking about here actuarial attestation is required in all cases and that actuary would need to come to the RDS website to do that attestation submission. Can the AR and the AM see each other's personal information for example social security number, date of birth etc or designees? Can the AR and the AM see each other's personal information for example social security number, date of birth etc or designees? No absolutely not. Only that particular individual may see his own personal information. In fact we're talking about not even allowing a change in certain personal information that should really never change such as date of birth and so on once you've been authenticated but it's not a bad process. Certainly mailing address and that but you will as an authorized rep be able to see enough information to identify the individuals who are working on your application but you will not be able to see their social security number, date of birth. Please clarify the benefit option administrator confused about the need for this user and role. Please clarify the benefit option administrator and user and role. We'll likely talk a little bit about this tomorrow when we begin discussing our proposed payment processes. The thinking at this point is that and again I'll qualify my answer by saying it's still an open issue because we're still building payment modules for the system and we'll be doing that for a couple months at this point. But the benefit option administrator is would be an individual that would be sending information primarily about the costs for the qualified cover of retirees. And again as I mentioned earlier it's not clear at this point to us because we're still building that specific functionality in the system if that individual would just be another type of designee with a separate set of authorities versus this benefit option administrator role. So we realize that's a little bit confusing and we will be clarifying this in the coming month or two. So stay tuned for a little bit more on that. We will touch a little bit more on what the information would be submitted by that individual whatever their title tomorrow when we talk about payment. When we called the VDSA COB contractor we were told no new applications will be taken for the VDSA until November is this correct? When we called the VDSA COB contractor we were told no new applications will be taken for VDSA until November is this correct? No, that's not correct. The new agreements will be out on the street August 1st of this year. That's also when we will begin testing the new processes. I think the November date is the date of actual full production of the VDSA process including non-MSP files. We will, as I mentioned earlier, be accepting the subsidy records September 1st of this year. But the actual live production date for the VDSA is November but we are signing new agreements starting August 1st. Regarding the uploading of data, does the CMS system use IBM MQ series? Does the secure file upload use 128 or 256 encryptions? Regarding the uploading of data, does the CMS system use IBM MQ series? And does the secure file upload use 128 or 256 encryptions? We do in fact use IBM MQ series. It's one of the CMS architectural standards that we have to adhere to along with a lot of other protocols and processes. How do we create the encryption for the file upload process? With all the employers in the country and the number of appropriate ARs, AMs, designes, and actuaries that will utilize the website, are you prepared for the inevitable volume of phone calls, emails, and overall website volume? Many of the instructions, file formats, etc. are just now available and there will be confusion since some deadlines are tight and unyielding. Employers and insurers have not had 100 business days thus far to deliver everything and time constraints will create extra pressure, thus more questions. Will the employers in the country and with all the employers in the country and the number of appropriate ARs, AMs, designes, and actuaries that will utilize the website, are you prepared for the inevitable volume of phone calls, emails, and overall website volume? Many of the instructions, file formats, etc. are just now available and there will be confusion since deadlines are tight and unyielding. Employers and insurers have not had 100 business days thus far to deliver through everything and time constraints will create extra pressure, thus more questions. Before anyone else answers I think I'll just jump in and then they'll all answer consistently with what I'm about to say. The answer to that is yes, we are prepared because success is the only option and we will be successful in implementing and we will have whatever resources are necessary to answer everybody's questions so that everybody will be prepared to successfully apply for the subsidy. With that said I'll let others chime in with whatever else they want to say. Where's that hard hat? I couldn't agree with you more Mike. Just to add to that in building the system part of establishing the data center and planning for the various permutations of what could happen with respect to how a plan sponsor will interact with our secure website. We did go through analysis about what we paid in terms of website hits things like that. We have considered that and in terms of from a customer service perspective we do have some internal contingency planning with the RDS center to shift resources as necessary at our customer service department to accommodate more phone calls if possible if there is a surge. We have thought about those things and I'm told resources are available so. Comment here and in fact we are continually training and bringing new staff to be ready for all the calls that we expect to get starting on this first. This has been a valuable session. What arrangements have been made for other sessions for those that were not able to attend? This has been a valuable session. What arrangements have been made for others who have not been on video cameras running the whole time here today? I know I'm very aware of it. We will be making the materials available on digital media in the coming weeks and I'm not sure if I know the exact details of one that's supposed to be available. A member of our staff has that information and hopefully we can maybe get that information for tomorrow and share that. We are planning on making that available and I think it is, I'm not sure if it's for purchase. We'll double check on that but it should have been mentioned in the conference materials if not we'll clarify tomorrow. It was discussed earlier today and I know they're trying to find the date. Kathy is working on it. Right, just to supplement that we are going to make that information available as quickly as we can. We do not have plans at this time but we do have plans. We do have plans like this although I'm sure that we will continue to engage in the other types of outreach events that we've been engaging in and as many of you have heard a number of us speak repeatedly about this over the past 8, 10, 12 months. So we'll continue our outreach in that way and of course many of you know how to reach us for individual questions as they come up but at this point I don't expect given where we are and the fact that the application is going to go live August 1 and where we are in July I don't expect any more conferences like this of course before then especially but any more the rest of this year. Outreach events are still evolving through the late summer and fall time periods so we're still working to find those. Another plug for the website go to the website look at the outreach event calendar that's the sole source for you being notified it's the best and most accurate also on the IVR it's not the sole source so on the IVR we also have an option for you to hear upcoming outreach events so I encourage you to visit often. What type of organizations are considered plan sponsors? What types of organizations are considered plan sponsors? Plan sponsors generally can be employers both profit employers non profit employers churches unions governmental plan so really basically any organization that sponsors employment based retirement benefit. Can multiple designees submit retiree list files for one plan? If not how do you expect sponsors with multiple vendors to submit the retiree list? Can multiple designees submit retiree list files for one plan? If not how do you expect sponsors with multiple vendors to submit the retiree list? The answer is we need to have at this point in time one file per application for your retiree list if that is coming from separate vendors you will have to find a way to roll up those files into one and submit one file to the RDS center if you have any other options in the future but again when I was going through the presentation I mentioned that it's difficult for us to know if you had multiple files coming in I'm not sure when I should process your retiree list I won't know when I have the entire file without the plan sponsors interaction or intervention so at this point in time concatenate all of those files or collect all those files together and submit them in one file submission to the RDS center Plan sponsors need to submit the retiree list prior to September 30th, 2005 however it is not effective until January 1, 2006 what function does the list serve if it is not reflective of the actual 2006 data? I guess there's a couple pieces to that question and perhaps Mark you could chime in a little bit more in support here but I think what I think I think I think I think I think I think what the original intent was to provide as much feedback as soon as possible to plan sponsors so that they could begin planning for what will be coming up in coming months with respect to file submission and potentially planning for how they track on there and payment information per retiree that's one particular reason I guess also we Medicare have the need to get our databases updated before the Medicare Part D open enrollment season begins so that again we can prevent if possible the unnecessary Part D enrollment for someone who already has a very robust retiree coverage so those are two reasons is there anything else I would like to add to that? just a supplement what Dave was saying the beneficiary angle is really one of the critical reasons for doing that so this way we know before the open enrollment period for beneficiaries who might be in a plan for which their employer is claiming a subsidy payment and I can't recall if it's already been discussed today or not but we have a system in place to try to provide these checks for an employer that is claiming a subsidy if an individual who retirees is going to be signing up for Part D who want to be able to notify the sponsors so that they can either make system changes to reflect that fact or communicate with retiree to let them know that you know maybe you shouldn't be doing this or you may want to consider not doing that that you can't prevent them from doing that but you could if you wish to do this speak with them but that needs to be done far enough in advance of the open enrollment period which starts in November 15th so that was one of the prime motivations for trying to get all the employer activity done in advance of the November 15th date and again that's with the acknowledgement that there will be changes and to the extent that there are changes reflecting for the next open enrollment period then you'll submit those but I think from my perspective that's one of the critical reasons why we chose the September 30th date in the proposed rag and ended up sticking with it in the final rule and just one last thing the retiree population clearly is not one that's extremely transient from option to option so I think our assumption there is that the data may not be perfect but it should be pretty good Is VDSA available for all employers regardless of size Is VDS available for all employers regardless of size The answer to that is yes but is it necessarily economical for a very very small company to do VDS say that's something they would have to look at internally and decide for themselves I mean as we mentioned earlier there is no charge whatsoever to do a VDS say but I will mention again that there are other companies out there that actually offer to administer the VDS say on their behalf and I've seen a lot of smaller companies making the decision to utilize some of these private consulting companies to provide that information as a service just because it's easier the VDS say file process it's a little bit more complicated in terms of the amount of data that goes back and forth in the two different file formats but based on the specifications in the agreement I would ask you to look at that and make that decision for yourself but again there are other options out there we have received a lot of contact from more and more of these like healthcare data management type consulting companies that already you know take part in administering many smaller employers especially their benefit programs and this is an option for you all to consider as well and then finally I will mention that if the employer feels they cannot do it they can also try to see if their insurer would enter into a VDS directly with CMS to provide that data to us via that and that's again we have about 50 agreements you know pretty much most almost all of the Blue Cross Blue Shield plans as well as a lot of other large insurers such as UHC Yetness, Cigna, Kaiser, etc. How large a file or number of records can be handled by the HTTP upload file transfer method How large a file or number of records can be handled by the HTTP upload file transfer method We aren't setting any specific limits so retiree file records each individual record is rather small so we're not currently imposing any limitation on you it will of course the larger the file the longer it will take to upload but we don't really think that any of you are going to create a file too large for us to handle I guess we'll find out Will the group uploading the retiree lists be able to test the file transfer and file layout with CMS prior to live date Will the group uploading the retiree lists be able to test the file transfer and file layout with CMS prior to the live date We're actually testing with the VDSA plan sponsors of course and the mainframe to mainframe file option we will not be testing with the upload to the secure website so in a sense your test is your production submission and if you have a problem with that you'll be contacted either through your notification I would presume it would just be through your response file Please reiterate what date should be used on the date of file titled coverage effective date is it really necessary to use an old date when retiree originally enrolled or is the first day of the first plan year where a subsidy is claimed okay Please reiterate what date should be used on the data file titled coverage effective date is it really necessary to use an old date when retiree originally enrolled or is it the first day of the first plan year where a subsidy is claimed okay There are two two ways that field should be populated the first is the retiree was actually has been in this plan and a new benefit year is starting so option number one is that effective date would be day one of that particular plan year the second way it could be populated is if a person retiree was not in that plan at the beginning of the plan year and then in a subsequent month enrolls into that that plan and that would be the effective date on that new ad record so we are not asking for you to report the date way back in time however many years ago it was that retiree first selected that benefit it's only for this particular plan year mapped to this particular application and account I think it's important to remember that your application is for one plan year so the plan year in question or the effective date should reflect that particular plan year for that particular application and it will be resubmitted then next year when the plan year starts again just another corollary to that for those plans that plan on plans that plan we're going to submit an application for a plan year that ends in 2006 and the transition period applies we're not asking you to do us a favor and put January 1 in there we know when the program is starting with respect to when payments begin but we're asking that the effective date for those retirees that are in the plan perhaps starting in 2005 which then ends in 2006 or 2005 effective date again it's either the first day of that plan or for that benefit year or the first date in which that specific retiree is enrolled under that plan even if it isn't 2005 we'll do the math this is the plan that operates on a fiscal year basis other than a calendar year can an employer group who successfully applied for RDS change mid-plan year to an MA part D plan can an employer group who successfully applied for RDS change mid-plan year to an MA part D plan the answer to that question is yes you can have a sponsor successfully apply for the subsidy and then part way through the plan year decide that for whatever reason they want to put to another option they would just stop filing data for the subsidy notify the RDS center that they're no longer going to participate in the subsidy program and then they would be free to pursue another option for employers such as sponsoring a PDP plan part D plan for the retirees or supplementing part D and in that notification to the RDS center we would expect to have a specific date when that would become effective and that would be the last day basically that employees retirees could be covered under that plan for RDS purposes now that employer would still have to go through the reconciliation process at the end of the plan year to reconcile the interim payment that they did receive to really participate in the RDS program would not be final until that reconciliation so I assume in that situation Pat correct me if I'm wrong but if I received that notification we would be sending a subsidy update record file to them so indicating that term date or I'm not sure what you thought about can you give me the scenario again if a plan decides that they are going to become an MA plan in other words they're not going to be seeking retiree drug subsidy in the middle of their plan year they would have to notify the RDS center what the date is when they're going to transition to be an MA plan so as long as we have the date and we know when that plan is going to be not seeking subsidy payments anymore would we send them a file indicating that the subsidy term date with this updated subsidy term dates for all the retirees that they've been claiming for RDS I'm not sure we've thought this all the way through I'm not sure either I was expecting that I would get an update retiree file from the plan sponsor with termination dates for all of the retirees affected that would certainly be more in line with our processes so sounds like another JADS session coming up well that's how we do NBDSA what format will the response file from CMS be send how often will there be discrepancy reports from CMS what format will the response file from CMS be sent in how often will there be discrepancy reports from CMS I'll take this question you the could I actually hold that question for a minute just to make sure that I see the actual file formats I discussed the data elements earlier today so they're in your presentation materials however we will post the file layouts on Friday that will be more specific they're the file layouts that you will submit for your retiree file and then also the response file layout that you'll receive back you every time you send us a file if you send us a monthly retiree list you will get a response back one response file back we will also be on that file error messages codes the reason codes to explain why the record might have been rejected by the RDS center or not so the frequency of your response file is as you send it to us okay great thank you will the VDSA process help with getting members, spouse, beneficiary, so security numbers employees are having a difficult time getting this information will the VDSA process help with getting members, spouse, beneficiary, so security numbers employers are having a difficult time getting this information unfortunately unless you have an HIC number you're not going to be able to develop for the SSN and that's to guard beneficiary's privacy because we can't just simply take in a name, date of birth and sex of an individual and find a social security there's how many John Smiths out there we need to that's part of the validation process to make sure that you're telling us about who you think you're telling us about and that's what the SSN is used with those personal characteristics to validate that data and I don't think any of these processes will work so Okay, this is a two-part question and I'm going to take it part by part for you I think if one of our retirees attempts to enroll in a Medicare Part D plan but is not reported on our retiree drug subsidy eligibility list will the retiree be rejected for the PDP until they disenroll in our retiree medical plan if one of our retirees attempts to enroll in a Medicare Part D plan but is reported on our retiree drug subsidy eligibility list will the retiree be rejected for the PDP until they disenroll in our retiree medical plan I'll take that question as Mark indicated earlier we have set up a sort of a different system for those Medicare beneficiary that have been flagged for the retiree drug subsidy and they attempt to enroll in Part D and that is if they sign up with the PDP plan and they've already been counted for the subsidy with another employer when that PDP or MAPD plan the retiree or the beneficiary's name back to CMS to check against the database that person would have been flagged for the subsidy and that enrollment into the PDP will be nullified and then the RDS center will be notified who in turn would notify the employer the sponsor of the plan with the beneficiary to enroll and the employer would have an opportunity to contact the beneficiary and make sure that they know what the ramifications are that the and it would be up to the employer to decide what would happen if the beneficiary enrolled in Part D would be in accordance with the plan document either the employer could allow their plan to go secondary or they could terminate their coverage in Part D and then after the employer contact the beneficiary subsequently contact the PDP and say that they still want to enroll in Part D even despite getting all that information then the enrollment will go through and then that person will be enrolled in Part D and then again it would be up to the employer's plan document what would happen to the employer's plan at that point and the second part to that but I believe you answered is if not will our retiree medical plan be allowed to pay as secondary to PDP as we do for Medicare Part A and B if not will our retiree medical plan be allowed to pay as secondary to PDP as we do for Medicare Part A and B absolutely if the employer chooses to supplement for those people who enroll in Part D that's certainly their option they can choose to do that or they could choose to terminate the coverage and just to supplement that a little bit more we have been working extremely hard with stakeholders involved in the process claims payers secondary payers pharmacists and so on and ensuring that effective 1106 there is in fact going to be a coordination of benefits system in place that will allow both Medicare Part D plan secondary payers like employers to coordinate in real time point a sale at the pharmacy so that the claims are appropriately paid and the primary payer the Part D plan pays appropriately and the employer plan the secondary payer pays appropriately so we believe that employers that choose to take this option and I'm hopeful subsidy if you do have somebody who signs up for Part D you do choose to agree to be a secondary payer if you take this approach there is going to be a very workable coordination of benefits system in place to allow that to take place can different designees have different methods for communicating monthly retire list submission updates or does the retiree list submission always come from the account manager can different designees have different methods for communicating monthly retiree list submission updates or does the retiree list submission always come from the account manager the retiree list does not have to come from the account manager however the submission method is based on what you've chosen on your application so there's one file transfer method per application and that's what's important so if you have multiple designees who might be able to upload files for you at different times they must for one particular application they must use the same file transfer method at this time is plan description referring to the actual carrier for example blue cross health plan is plan description referring to the actual carrier or for example blue cross blue cross health plan I think again we've given the flexibility for you to define what it is you put in that field it has to be a meaningful description for you again if you're an account manager and you're involved with helping multiple plan sponsors manage their interactions with the RDS center that would be a much more meaningful data element if you're presented a list of plan sponsors or applications on the screen you'll be able to see which one series of application numbers or plan sponsor IDs that field is meant to be a more easy qualifying sorry a more easy descriptor for you to understand as you're interacting with the RDS website how is an account manager or authorized representative or designee to be terminated how is an account manager or authorized representative or designee to be terminated there is a feature a secure website where the authorized rep can go in and actually terminate so to speak added an expiration date to the account manager to remove them from their account if they're not valid for any other plan sponsor accounts actually their ID will be revoked in that case the same goes there is an update feature where an account manager can change their authorized rep on a particular plan sponsor account and then application by application you can go in and fill in or complete the expiration date for a designee I didn't show you that functionality today but it will exist on the secure website so you'll have control over those designees and account manager and authorized reps associated with your account I heard that we can send our entire enrollment file to check Medicare eligibility for example to find disabled Medicare allegibles on the retiree list is that true I heard that we can send our entire enrollment file to check Medicare eligibility for example to find disabled Medicare eligibility on the retiree list is that true that sounds like a BDSA question And the answer is yes. We pass back entitlement information, including reason for entitlement. So disability is one of them. So, I don't know. Well, if the plan sponsor submits a list of ad records at the point when they're submitting their application, we will give a response. But we will not be identifying, through the regular secure RDS website file transfer process. We will not be passing back to you information that would allow you to know that that person was entitled to Medicare because of disability. We are passing back the minimum amount of information as is necessary to determine a subsidy period for that person, whether or not it's qualifying covered retiree. Yeah, I mean, I think the difference is, through VDSA, you will get entitlement dates and information back and the health insurance claim number that we were discussing before. If you are submitting retiree files directly to RDS and not through VDSA, the only response that you will get is whether your retiree is eligible for the subsidy. By default, they must be entitled or eligible for Medicare. However, we will not pass you back the health insurance claim number unless you gave it to us, and we won't pass back any entitlement or eligibility dates through that process. Is the mailing address for the AM personal information, the business address, or the home address? Is the mailing address for the AM personal information, the business address, or the home address? We're expecting a business address. Will you release the scripts and Q&As that your call center uses on RDS and COB? For the RDS website, we are planning on loading a number of frequently asked questions, questions that have been submitted here today and tomorrow during this conference and at other times over recent months. We have a long list of questions right now that we're putting the finishing touches on. So hopefully on our FAQ page on the RDS website, we'll be able to do that in a couple of weeks. On our FAQ page on the RDS center website, you'll be seeing a pretty robust list of FAQs very soon. How about COB? Yeah, I mean, whatever we want to be able to put as much on the web as possible, rather than provide things like scripts because again, those are subject to change and the websites always are updated. So, same thing, we would refer people to the COB website as well for information for employers and insurers about the various processes that we handle. You refer to part A entitled and part B enrolled. Can you please clarify the definitions of entitled, enrolled and eligible? You refer to part A entitled and part B enrolled. Can you please clarify the definitions of entitled, enrolled and eligible? I'll take a crack at that. For Medicare part A under the statute, entitlement means somebody who is actually in part A. And I think one of the reasons perhaps they don't use the phrase enrolled is that for many people, when you sign up for Social Security, you're automatically put into Medicare part A. So there isn't really, while you're signing up for your Social Security benefits, there really isn't a second act that's needed to get your Medicare part A benefit. But in the part A world, entitlement means you're actually getting the part A benefit. Enrolled is a phrase they use in part B. And part B, you pay for the benefit and you actually have to physically enroll in it. Eligible is something I think we typically use in the Medicare part D world, which is somebody who is either entitled to part A or enrolled in part B. And if you're entitled to part A or enrolled in part B, then you are eligible to pick part D. If you enroll, thank you. And if you pick, so if you pick part D, I'm on a roll now, if you actually enroll in part D, then you're enrolled in part D, if you don't. So you're still eligible for it, then your sponsor can choose the subsidy payment. Thank you and good night. This is John. I can add a little words of wisdom that someone told me years ago. And then I mean, people don't always use the words correctly, but generally think of it alphabetically. You're eligible, you enroll, you become entitled. That's kind of what's passed around often at CMS. But yeah, I mean, the B and the D, I guess you become enrolled in it. But the Medicare part A is an entitlement, as Mark said, but for in some cases though, I mean, you actually become eligible for part A three months prior to when you can become entitled to it. So it's eligible enroll, which is automatic for part A, and you become entitled. Entitlement is when you're actually taking the benefit. And our last question for the day, wait, wait, in writing, is are people in the Commonwealth of Puerto Rico and the territories eligible for subsidy? Are the people in the Commonwealth of Puerto Rico and the territories eligible for subsidy? Good question. Tempta plus. Yes. The part of the United States, the answer is yes. Yeah, they're entitled to Medicare benefits, oh, entitled, whatever. They're in Medicare, so yes, the same rules apply there. Okay, first of all, thank you to this panel. You did an exceptionally good job, and thank you. And to all of you, those questions were wonderful. As you can see, we have lots of them. Tomorrow we will address the questions from tomorrow's session at the end of the day. Some closing announcements. If you are a speaker tomorrow, please meet in the speaker ready room no later than eight o'clock tomorrow morning so that you can have your morning briefing and we can get you hooked up to microphones, et cetera. There have been several requests for informal regional meetings, and we have tried to determine whether that is possible so that you can have some networking time. As of the break, we are still waiting to see if all of the regional people will be here because the recommendation is that if you want to take the time to network, that we do it between seven and eight in the morning. And what we would do is set up sections of the room and we would have them posted. Unfortunately, they have not confirmed this back to me, but I probably had close to 100 of you asking if that's possible. So I do not know the answer. The best that I can tell you is that if it's going to happen, look for a sign outside this door sometime between tonight and tomorrow morning, and we will let you know if it's going to happen. It won't happen before 7 a.m., but what we would do is we have six regions. We would put five regions, one per section, and one out in the common area. So look for that posting. That's all I can tell you at the moment. We have had questions about checkout tomorrow for those of you that may be leaving on flights after the end of the day. We encourage you to use Express Checkout. We are not the only conference here in the hotel. The other thing is can you bring luggage into this room? I would discourage you from doing that. Number one, there's just not enough room. And number two, when we go out for breaks and things, this is not a secure area. So I would discourage you. I would say take it to the bell stand and do it there. The other thing was, are there organized dinners tonight? Only if you organize them. And with that, I thank all of you, particularly our signers, who have done an incredibly good job. And I see a hand, yes. Yeah, this is John. Unfortunately, those of us from the COB team are leaving early tomorrow morning, and I said I would stick around if people have any additional questions they want to ask me at the end of the presentation, which is now. So I'll just remain up here for anybody who has additional questions or whatnot. Excellent. Thank you very much. We are adjourned until 8 30 tomorrow morning.