In April 2015, Congress required the Centers for Medicare & Medicaid Services (CMS) and the Social Security Administration (SSA) to find an alternative to the existing health insurance claim numbers (HICNs). Section 501 of the Medicare Access and CHIP Reauthorization Act (MACRA) requires Medicare to replace Social Security numbers (SSNs) and health insurance claim numbers (HICNs) with a unique Medicare Beneficiary Identifier (MBI). On May 5, CMS announced further information about the program, including some details about how MBIs will be used and when they will be incorporated.
A memo from the director of the Center for Medicaid and CHIP Services explained that, “starting in early 2018, CMS will issue new Medicare cards with an MBI to approximately 60 million beneficiaries.” Notably, the announcement added that while “A HICN will still be assigned to each Medicare beneficiary and will still be used for internal data exchanges between CMS and the states, … the new MBI must be used in all interactions with the beneficiary, the provider community and all external partners.”
The HICN—along with the Social Security number—is the backbone of Medicare Secondary Payer (MSP) compliance. Conditional payments, Medicare Set-Asides (MSAs), and mandatory insurer reporting all require either the SSN or the HICN to identify a claimant as a Medicare beneficiary. The problem with the HICN is that, in most cases, it’s simply the beneficiary’s Social Security number followed by a letter (usually A). Given the obvious need to protect millions of Medicare beneficiaries from the possibility of identity theft, Congress instructed Medicare to make the change.
The key question is how CMS will incorporate the MBI into the MSP program. While use of the HICN won’t be entirely abandoned and the last five digits of an SSN will remain a critical number in MSP compliance, insurers will need to plan for the MBI. For the last seven years, insurers have invested millions of dollars in modifying claim systems to comply with mandatory MSP reporting requirements. Details on the MBI will be announced. In the meantime, here are some questions to consider: What form will the MBI take, and how will it replace the HICN? What changes, if any, will CMS incorporate into the MSP program?
Most important, when the dust settles, will CMS provide insurers with enough time to make any data collection modifications necessary to comply with MBI collection? Based on the timeline, new Medicare cards with MBIs will be reissued in less than two years. All parties need to know what changes will be made, and when, so that they may adequately collect data and report accurately. When an insurer uses a claimant’s full or partial SSN to perform an electronic query, Medicare returns an HICN. Will future queries return an MBI? And how will Medicare contractors incorporate this change into their program?
ISO Claims Partners is closely monitoring this issue, with a particular focus on how it may possibly affect insurers. We’ll issue updates as Medicare provides future guidance and outlines more specific information and timelines.