The Centers for Medicare & Medicaid Services (CMS) announced this week that the Social Security Number Removal Initiative (SSNRI) will now be known as “New Medicare cards.” Regardless of what the program is called, the bottom line is that the old Social Security Number based Health Insurance Claim Number (HICN) will be replaced by a new Medicare Beneficiary Identifier (MBI). This is not exactly new news as the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 required CMS to remove Social Security Numbers from all Medicare cards by April 2019 and CMS announced the upcoming transition earlier year.
How Will This Affect Mandatory Insurer Reporting?
Who is Affected?
According to an Open Door Forum in June, Medicare will “generate MBIs for all beneficiaries: Includes existing (currently active, deceased, or archived) and new beneficiaries.” All Medicare beneficiaries begin receiving the new Medicare cards with the new MBI starting April 2018. These new cards will be mailed to beneficiaries throughout the year with the expected completion by April 2019.
What does this Mean?
Medicare will generate the MBI using a Non-Intelligent Unique Identifier with 11 characters. It will be made up only of numbers and uppercase letters with no special characters, for example: 3BP5T28MD19 or 7N26PW4AK81. Medicare does have a designated format as to the positions of numbers and letters but each number is randomly generated and is “non-intelligent” meaning that there are no hidden or special connotations. The cards will not include gender or a signature line.
Why is this Happening?
Because personal identity theft affects more and more seniors and people over 65 are frequently targets for this crime, CMS believes this move will protect not only seniors, but taxpayer dollars as well. CMS Administrator Seema Verma said “We’re taking this step to protect our seniors from fraudulent use of Social Security numbers which can lead to identity theft and illegal use of Medicare benefits.”
How does this affect Mandatory Insurer Reporting (MIR)?
The transition period will run from April 2018 through December 31, 2019. CMS will be ready to accept and return the MBI by April 1, 2018. While hospitals and providers must update or modify their systems to be able to use the MBI by that date, CMS has allowed that they may use either the HICN or MBI during the transition period.
However, to minimize the impact on all Medicare Secondary Payer (MSP) stakeholders, CMS does not plan on any changes to the file formatting of any input or response files used as part of MIR. Starting in July 2017, the term “Medicare ID” will replace HICN in all processes and documentation.
Because an exception to the SSNRI has been granted for all MSP data exchanges and processes, RRE’s will still be able to use the MBI, full SSN or the HICN in their Section 111 Reporting. Also, Non-Group Health Plan (NGHP) RREs will be able to continue to submit the last 5 digits of the SSN in reporting.
Regardless of the identifier submitted by the RRE via Section 111, CMS will return the “most current” identifier. This could be the MBI if one has been generated or the HICN if the MBI has not been generated.
The CMS Portals most commonly used by NGHP RREs including the Medicare Secondary Payer Recovery Portal (MSPRP) and the Workers’ Compensation Medicare Set-aside Arrangements Portal (WCMSAP) will allow users to enter either the HICN or the MBI to access specific claim information.
Letters generated by CMS such as Conditional Payment letters (CPLs), notices, or demands will have either the HICN or the MBI based on the beneficiary identifier most recently reported to CMS that resulted in the creation of the case.
U.S. Treasury Department letters related to MSP debt will not contain either a HICN or MBI. These letters will now contain a recovery Case ID.
CMS will continue to publish updates as the transition to the MBI draws closer in April 2018.
If you have questions about how SSNRI and MBI affect your MSP Reporting or Recovery, contact us.