CMS10156CrosswalkOfChanges

Information Collection 0938-0957
CMS form 10156
Crosswalk of Changes Made
NOTE: All Part numbers refer to part numbers in the revised collection instrument.
General Changes Made Throughout the Document
The following four changes are insignificant editorial changes made only for purposes of
clarity. There is no additional or reduced burden associated with them.
•

Required fields are designated with an asterisk (instead of not-required fields
being designated “optional”).

•

The term “organization” has been added, or substituted for other words such as
“sponsor,” for purposes of clarity.

•

When an Account Manager’s, Authorized Representative’s, Designee’s, or
Actuary’s name is requested, they are given more explicit instructions to provide
their first name, middle initial, and last name.

•

When an Account Manager’s, Authorized Representative’s, Designee’s, or
Actuary’s date of birth is requested, they are given more explicit instructions to
provide the month, day and year.

The above changes neither increase nor decrease burden.

When an individual accesses the application, they must read and accept the User
Agreement and Privacy Policy that appears. The text is found in Part 1.G. of the
collection instrument. This feature is necessary so that users understand their rights and
obligations associated with using the RDS Secure Web Site. The reading and accepting of
this material is a standard practice of the Federal government. This feature nominally
increases burden.

Specific Changes Made to the Document
Part I.B.
This section collects nominal information that the Account Manager must provide, in
order to assign an Authorized Representative. This feature is necessary in order to collect
necessary information from the Authorized Representative, and is supported by 42 CFR
§423.884(c)(2)(viii). This feature nominally increases burden.

Part 1.C.
The feature in Part 1.C.(1) requires the Authorized Representative, when first registering
to perform that role, to check a box confirming that the Account Manager that invited
him to register is associated with the Plan Sponsor. This feature is necessary to verify
participants in order to prevent unauthorized access to the Secure on-line application that
is adapted from this collection instrument, and is supported by §1860D-22 of the Social
Security Act, CMS’ RDS implementing regulations at 42 C.F.R. §423 Subpart R, as well
as the Debt Collection Improvement Act of 1996 at 31 U.S.C. §7701(c) and the Federal
Privacy Act at 5 U.S.C. §552a. This feature nominally increases burden.

The feature in Part 1.C.(11) requires an Authorized Representative to provide his Login
ID, password, and answers to security questions, to access the on-line application. This
feature is necessary to verify participants in order to prevent unauthorized access to the
Secure on-line application that is adapted from this collection instrument, and is
supported by §1860D-22 of the Social Security Act, CMS’ RDS implementing
regulations at 42 C.F.R. §423 Subpart R, as well as the Debt Collection Improvement Act
of 1996 at 31 U.S.C. §7701(c) and the Federal Privacy Act at 5 U.S.C. §552a. This
feature nominally increases burden.

Part 1.D.
The feature in Part 1.D.(10) requires the Account Manager to provide his Login ID,
password, and answers to security questions, to access the on-line application. This
feature is necessary to verify participants in order to prevent unauthorized access to the
Secure on-line application that is adapted from this collection instrument, and is
supported by §1860D-22 of the Social Security Act, CMS’ RDS implementing
regulations at 42 C.F.R. §423 Subpart R, as well as the Debt Collection Improvement Act
of 1996 at 31 U.S.C. §7701(c) and the Federal Privacy Act at 5 U.S.C. §552a. This
feature nominally increases burden.
Part 1.E.
At the request of the Plan Sponsor community, Plan Sponsors are given the flexibility to
assign Designees to perform different functions within the RDS application. To
accommodate that request, this section collects nominal information that the Account
Manager or Authorized Representative must provide, in order to assign a Designee. This
change is necessary in order to collect necessary information from the Designee, and is
supported by 42 CFR §423.884(c)(2)(viii). This feature nominally increases burden.

Part 1.F.
At the request of the Plan Sponsor community, Plan Sponsors are given the flexibility to
assign Designees to perform different functions within the RDS application. To
accommodate that request, the feature in Part 1.F.(11) requires a Designee to provide his
Login ID, password, and answers to security questions, to access the on-line application.
This feature is necessary to verify participants in order to prevent unauthorized access to

the Secure on-line application that is adapted from this collection instrument, and is
supported by §1860D-22 of the Social Security Act, CMS’ RDS implementing
regulations at 42 C.F.R. §423 Subpart R, as well as the Debt Collection Improvement Act
of 1996 at 31 U.S.C. §7701(c) and the Federal Privacy Act at 5 U.S.C. §552a. This
feature nominally increases burden.
Part 1.G.
As discussed above, the text of the User Agreement and Privacy Policy appear in this
Part, as discussed in the General Changes section of this paper.

Part II.A.
The question of whether the Plan Sponsor is combining two or more benefit options for
purposes of the actuarial equivalence net test has been removed. (A revised version of
this question is instead asked of the attesting Actuary, in Part III. A. of the collection
instrument). The question had been asked of the Account Manager. But based on
feedback from the Plan Sponsor community, we have learned that the attesting Actuary is
the more appropriate individual to whom the question should be asked. This change
neither increases nor decreases burden.
Part II.B.
Information to be provided about the attesting Actuary has been removed from this Part,
and moved to Part II.C. This change neither increases nor decreases burden.
Part II.D.
A feature in Part II.D.(12) requires the attesting Actuary to provide his Login ID,
password, and answers to security questions, to access the on-line application. This
change is necessary to verify participants in order to prevent unauthorized access to the
Secure on-line application that is adapted from this collection instrument, and is
supported by §1860D-22 of the Social Security Act, CMS’ RDS implementing
regulations at 42 C.F.R. §423 Subpart R, as well as the Debt Collection Improvement Act
of 1996 at 31 U.S.C. §7701(c) and the Federal Privacy Act at 5 U.S.C. §552a. This
change nominally increases burden.
In response to requests from the The Actuary community, we will be permitting attesting
Actuaries to also serve as Designees within a Plan Sponsor’s application. In order to
accommodate this request, a feature has been added in Part II.D.(4) and (5) that requires
the attesting Actuary to provide his SSN, date of birth, and job title (as would any other
Designee). This change is necessary to verify participants in order to prevent
unauthorized access to the Secure on-line application that is adapted from this collection
instrument, and is supported by §1860D-22 of the Social Security Act, CMS’ RDS
implementing regulations at 42 C.F.R. §423 Subpart R, as well as the Debt Collection
Improvement Act of 1996 at 31 U.S.C. §7701(c) and the Federal Privacy Act at 5 U.S.C.
§552a. This feature nominally increases burden.

Part III.A.
This question of whether the attesting Actuary is combining two or more benefit options
for purposes of the actuarial equivalence net test is now asked of the attesting Actuary. It
used to be asked of the Account Manager, in the previously approved version of the
collection instrument. However, it has come to our attention that the attesting Actuary is
the party who possesses the requisite knowledge to answer this question. The requirement
to provide a response to this question is supported by 42 CFR §423.884(c)(2)(viii) and
(d). This change neither increases nor decreases burden.
Part III.B.
The attesting Actuary makes one attestation that covers both the gross value and net value
actuarial attestation tests. In the previously approved version of the collection instrument,
the attesting Actuary was required to make two separate attestations. Some relatively
insignificant verbiage in the attestations has been modified, for clarity. These changes
have been made to streamline the attestation process, and are supported by 42 CFR
§423.884(c)(2)(viii) and (d).This change neither increases no decreases burden.
Parts IV. and V.
The only changes made to these two sections is the removal of the section name, as
discussed in the General Changes section of this paper. This change neither increases
nor decreases burden.
Part VI.A.
The Plan Sponsor community has requested that they be able to specify those parties that
can submit retiree lists on their behalf. To accommodate this request, a feature in Part
VI.A.(3) allows the Plan Sponsor to specify, by benefit option, the party that is permitted
to submit retiree lists on behalf of the Plan Sponsor. A new feature in Part VI.A. (9)
permits the Plan Sponsor to specify how it wishes to receive notification files, and gives
Plan Sponsors the flexibility to receive them via HTTPS from the RDS Center, even if
the Plan Sponsor submits its retiree list some other way. These changes are supported by
42 CFR §423.884(c)(2)(v). These changes nominally increase burden.

Part VI B
This section makes clear that the Plan Sponsor, for each retiree for whom it wishes to
collect RDS, must provide that retiree’s SSN and/or HICN. The previous collection
instrument required the Plan Sponsor to provide both. This change is supported by 42
CFR §423.884(c)(2)(v)(B). This change nominally decreases burden.
Part VII and Part VIII
Minor editorial changes were made to these two parts of the collection instrument. These
changes neither increase nor decrease burden.