Lepton has experience performing Actuarial
Equivalence Tests and preparing Actuarial
Attestation on behalf of retiree healthcare
plan sponsors


Our team consists of actuaries who are members of the American Academy of Actuaries. qualified to prepare, a Retiree Drug Subsidy (RDS) Actuarial Attestation on your behalf. We have over 5 credentialed actuaries, many of whom have been filing and reviewing Medicare bids for several years.

On your behalf, our actuaries can complete the two-part Actuarial Equivalence Test and prepare Actuarial Attestation required for your application to be approved.

We will help determined if each of the Benefit Option(s) listed in your Plan Sponsor Application meet Gross Value Test requirements and Net Value Test requirements set forth in

  • CMS regulation 42 C.F.R. §423 884(d)

  • relevant actuarial guidelines issued by CMS,

  • generally accepted actuarial principles,

  • appropriate actuarial standards of practice.

If you have multiple Benefit Options, our actuaries can help determine the best combinations and configurations to pass the Actuarial Equivalence Net Test.

Click here to request our services

About the Program

The Retiree Drug Subsidy (RDS) Program is designed to reimburse Plan
Sponsors for a portion of their Qualifying Covered Retirees’ costs for
prescription drugs. To qualify for the subsidy, a Plan Sponsor must show
that its coverage is “actuarially equivalent” to, or at least as generous as,
the defined standard Medicare Part D coverage.


CMS’ RDS Center requires a qualified Actuary to complete a two-part Actuarial Equivalence Test before an application can be submitted. The two-part Actuarial Equivalence Test includes a Gross Value Test and a Net Value Test. The Gross Value Test confirms that the total value of benefits provided to Medicare Part D eligible individuals under the Plan Sponsor’s plan is at least as generous as what they could receive under standard Medicare Part D coverage. The Net Value Test takes into account the extent of the employer financing of the drug coverage so that the net value of the employer plan to those individuals is at least equal to the net value of what they would receive under standard Medicare Part D coverage.

The Actuary determines if multiple Benefit Options will be combined to pass the Actuarial Equivalence Net Test. If Benefit Options are combined, the Actuary will attest to the gross value of each Benefit Option and to the net value of the combined Benefit Options. If Benefit Options are not combined, the Actuary will attest to both the gross and net values of each Benefit Option. For purposes of the actuarial equivalence net test, only Benefit Options listed within a single application may be combined.

Creditable Coverage

The Medicare Modernization Act (MMA) requires entities (whose policies include prescription drug coverage) to notify Medicare eligible policyholders whether their prescription drug coverage is creditable coverage, which means that the coverage is expected to pay on average as much as the standard Medicare prescription drug coverage. Learn more.

References & Articles