Summary of the SSN Removal Initiative Open Door Forum; One Key Field Name Change On January 17, 2017, the Centers for Medicare and Medicaid Services conducted a Special Open Door Forum to discuss the proposed changes in accordance with the Social Security Number Removal Initiative (SSNRI) of Section 501 of the Medicare Access and CHIP Reauthorization Act (MACRA).
Beginning April 1, 2018 and continuing through December 31, 2019, CMS will begin issuing Medicare Beneficiary Identifiers (MBI) to replace the Social Security Number based Health Insurance Claim Number currently in use today. Important details regarding the MBI rollout are as follows:
- CMS will engage in a robust outreach effort to work with beneficiaries and stakeholders to publicize the changeover from HICNs to MBIs.
- It is estimated that 150 million Americans will be assigned MBI numbers, which includes 60 million active beneficiaries as well as 90 million deceased and archived beneficiaries. That means CMS will issue new Medicare cards to the active beneficiaries during the rollout period.
- MBI values will be unique to each beneficiary, meaning a husband and wife will not have similar MBI values.
- The MBI will be formatted as 11 alphanumeric characters (containing both letters and numbers).
- Positions 2, 5, 8 and 9 in all MBI values will always contain letters.
- Certain letters will be excluded from the MBI values to avoid common confusion between certain letters and numbers that can be (and often are) mistaken for one another.
- Alphanumeric combinations that may be considered offensive will be eliminated from the MBI values.
As the SSNRI pertains to Medicare Secondary Payer compliance and Section 111 Mandatory Insurer Reporting, the changes are minimal because the SSNRI includes an exception for all Medicare Secondary Payer data exchanges and processes. The results of this exception are:
- Social Security Numbers (SSN) will still be permitted on all correspondence with CMS.
- SSN values will still be permitted for Section 111 Queries and Claim reporting.
- Partial SSN values will still be permitted for Section 111 reporting.
- Fields in Section 111 file specifications that reference “Health Insurance Claim Number” will be updated to reflect “Medicare Identifier.”
- Fields on the Medicare Secondary Payer Recovery Portal (MSPRP), Commercial Repayment Center Portal (CRCP) and Workers’ Compensation Medicare Set-Aside Arrangements Portal (WCMSAP) that reference “Health Insurance Claim Number” will be updated to reflect “Medicare Identifier.”
- The Medicare Identifier fields on the portals will recognize the difference between SSN, HICN and MBI based on the configuration of the value entered.
- SSN may still be used in all three portals if the HICN or MBI is not available.
- The HIPAA Eligibility Wrapper (HEW) process will not change, allowing SSN to be provided for the Medicare Query process.
In Section 111 reporting, CMS will return the “most current Medicare Identifier” in response files. In other words, prior to the April 2018 rollout of the new MBI, response files from CMS will contain the HICN, as they do today. Then, as more and more beneficiaries are assigned MBIs on or after April 2018, the MBI will be returned in response files from CMS. The MBI will be populated in the existing HICN field, which will be renamed the Medicare Identifier. For this reason, NGHP entities may need to update their systems to accept the new 11-character MBI values.
Outgoing correspondence and letters from CMS will be returned with the HICN or MBI value that was most recently reported to CMS in the creation of the MSP record and recovery case. In other words, if the HICN is provided, the HICN will be returned on CMS correspondence. However, if the HICN was provided in a prior report to CMS, and a subsequent update contains the MBI, then the MBI will be returned on all correspondence from that point forward.
The Department of Treasury letters are an exception. All correspondence to and from the Department of Treasury will no longer contain the HICN (nor MBI) and will instead contain only the Recovery Case ID number. The rollout of this modification is not yet determined, but it is expected to occur prior to the end of this calendar year.
ExamWorks Clinical Solutions will continue to monitor the Social Security Number Removal Initiative and inform you of any additional changes or effects to the services we provide.