The Social Security Number Removal Initiative (SSNRI) is coming to a Claim near You:

Medicare has generally used a beneficiary’s social security number as a part of the beneficiary’s Health Insurance Claim Number (HICN). The HICN is used to match medical bills and records with a particular beneficiary and is located on a beneficiary’s Medicare card. In light of the privacy and security issues this creates, the Centers for Medicare and Medicaid Services (CMS) will be phasing out its use of a Medicare beneficiary’s social security number/HICN in its outgoing correspondences and transition to a randomly generated Medicare Beneficiary Identifier (MBI). This process is expected to be completed by CMS by December 21, 2019. Beginning in July 2017, Medicare will be replacing the term “HICN” with “Medicare ID” in its correspondence.

In January of 2018, Medicare states it will begin to assign a randomly generated MBI to Medicare beneficiaries nationwide.  From April 2018 to April 2019, CMS will mail an updated Medicare card with the MBI to beneficiaries. This means that a MBI may be used by Medicare in its correspondence related to conditional payment recovery, section 111 reporting and WCMSA determinations beginning April 2018.

With respect to Section 111 reporting, the SSNRI continues to allow Responsible Reporting Entities (RRE) to report their Non-Group Health Plan claims using partial social security number, full social security number, HICN number or Railroad Retirement Board Number.  After January 2020, however, the Section 111 reporter will also be able to provide a MBI as a means to identify a particular beneficiary.  Further, employers will still be able to use the Social Security Number to obtain the most current Medicare identifier. If an RRE updates its section 111 reporting and updates the HICN to the MBI, all future recovery correspondence from CMS will reflect the MBI.

However, correspondence related to a WCMSA proposal will reflect whatever beneficiary identifier was submitted in the WCMSA and a social security number will still be useable with the Medicare web portals of MSPRP, CRCP, WCMSAP if the MBI or HICN/RRB is not available. Additionally, U.S. Treasury Department correspondence will no longer contain HICN or MBI and use a recovery case ID. The changes with the U.S. Treasury correspondences are expected to occur before the end of 2017.

The change from using HICN to MBI is an enormous undertaking and will require CMS to assign 150 million MBIs.  CMS has issued some benchmark dates:

  • January 2018 – Activate MBI and Translation Services
  • April 2018 – April 2019 – Issue new Medicare cards to beneficiaries
  • April 2018 – December 2019 – CMS will accept and process both HICN and MBI
  • January 2020 – HICNs will no longer be exchanged (except in limited circumstances)

This change will require the MBI to be used by medical providers, group health carriers and many other stakeholders by January /2020.  Although RREs may not need to obtain an MBI in order to report a Non-Group Health Plan claim, stakeholders in Medicare and the Medicare compliance community will need to adapt their systems to accept this additional identifier by April 2018 and also recognize that soon a U.S. Treasury collection correspondence will no longer have the claimant’s HICN or MBI listed. This likely will require extra training, oversight and analysis by the employer, beneficiary or insurer when such correspondence is received.

We will keep you updated as this historic change by CMS unfolds.

CMS Posts Updated MMSEA Section 111 NGHP User Guide

CMS posted Version 5.1 of the MMSEA Section 111 Medicare Secondary Payer Mandatory NGHP Reporting User Guide on October 10, 2016. The updates simply clarified the available reference material that may be accessed through the online Section 111 Coordination of Benefits Secure Website (COBSW) Reference Materials menu post-log in by RRE. These clarifications appear in Chapters I, II and IV. No changes were made to Chapters III and V.

We will keep you advised of further updates.

CMS Continues Implementation of the SMART Act Provisions

The passage of the Strengthening Medicare and Repaying Taxpayers Act of 2012 (SMART Act) was expected to provide settling parties with easier access to conditional payment information. Although the implementation of the provisions has been an arduous process, CMS has made great strides towards this in 2015. CMS not only established a formal conditional payment appeal process for applicable plans, it also plans to transition a portion of the non-group health plan recovery workload to the Commercial Repayment Center in order to expedite conditional payment claims processing. This transition should occur in October of 2015.

CMS’ most recent accomplishment was announced on July 21, 2015 when CMS rolled out its Multi-factor Authentication (MFA) services for use on the Medicare Secondary Payer Recovery Portal (MSPRP). This service will now allow non-beneficiary users to access conditional payment information that was previously unavailable through the portal. Non-beneficiary users of the portal will need to complete the Identity Proofing and MFA process prior to viewing the more comprehensive conditional payment information.

Details regarding the new MFA process are outlined in CMS’ User Guides. We will continue to keep you advised of further developments as they arise.

Town Hall Teleconference for Non-Group Health Plan Arrangements scheduled

CMS will be hosting a NGHP Policy and Technical Support related teleconference event on July 28, 2015. Topic: Upcoming transition of a portion of the NGHP recovery workload to the Commercial Repayment Center and policy and technical questions regarding Section 111 reporting.

Date: July 28, 2015
Call-in time: 1:00 PM – 2:00 PM EST
Call-in line: (800)603-1774
Pass Code: Section 111
Submit Questions:

Begin dialing in approximately 20 minutes before the call start time.