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CMS’s new Section 111 alert addresses MBI reporting

The Centers for Medicare and Medicaid Services (CMS) has issued an updated Section 111 Alert pertaining to non-group health claims (NGHP) regarding the Medicare Beneficiary Identifier (MBI) reporting.   

Through CMS’s new alert, the agency is reminding Responsible Reporting Entities (RREs) that they are not required to resubmit Claim Input records with a MBI on those claims previously reported with a Health Insurance Claim Number (HICN). If RREs wish to resubmit those files with the MBI, CMS instructs the RRE to do so by sending an update record with the MBI as the Injured Party Medicare ID, and not by deleting and re-adding a previously submitted record.

The full text of CMS’s new alert states as follows:

Section 111 Medicare, Medicaid and SCHIP Extension Act (MMSEA) NGHP RREs are not required to resubmit Section 111 Claim Input records with an MBI previously reported with a Health Insurance Claim Number (HICN). RREs wishing to update their Section 111 Claim Input records with an MBI should do so by sending an update record with the MBI as the Injured Party Medicare ID. RREs should not delete and re-add a previously submitted record to update to the MBI. Any questions should be directed to the RREs’ assigned Electronic Data Interchange (EDI) Representative at the Benefits Coordination & Recovery Center (BCRC). (Emphasis Added).

From a more global view, the MBI is the new Medicare identifier assigned to each Medicare beneficiary. As part of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015[1] CMS was required to discontinue all SSN-based Health Insurance Claim Number (HICN) Medicare identifiers and reissue new Medicare cards to all Medicare beneficiaries containing a new unique 11-byte MBI number. While CMS was given until April 2019 to reissue the new cards, the agency reportedly competed this task by January 2019.[2] The main goal behind this initiative is “to help prevent fraud, combat identify theft, and safeguard taxpayer dollars.”[3] Click here to view a replica of the new Medicare card with MBI number.

Although mandatory use of the new MBI number will be required in the vast majority of situations starting January 2020,[4] the MACRA provides a specific exception for Medicare Secondary Payer (MSP) data exchanges and related processes.[5] Specifically, CMS has advised that after January 1, 2020 RREs may provide any one of the following to Medicare's Benefits Coordination & Recovery Center (BCRC) as the beneficiary identifier for MSP reporting purposes: Medicare Beneficiary Identifier (MBI), full SSN, last 5 digits of the SSN, HICN, or RRB Medicare number.[6] In this regard, CMS’s new Alert can be viewed as falling in line with the noted MSP exception. 

Servicing note: MSP Navigator/ClaimSearch CMS 111 customers

For our MSP Navigator and ClaimSearch CMS 111 reporting customers, this new Alert does not have any impact on your existing Section 111 reporting process. You can continue to complete Section 111 reporting using either the full 9 digits or last 5 digits of the Social Security Number (SSN), and/or the Health Insurance Claim Number (HICN) or Medicare Beneficiary Identifier (MBI). In this case, CMS is simply issuing a reminder that claims do not need to be re-reported solely based on the receipt of an MBI, where only a HICN was previously available. Both systems will continue to determine the appropriate ‘action type’ to be submitted to CMS based on the claims information that is being provided to the system, so CMS’s above noted concern of ‘deleting and re-adding a previously submitted record’ based on receipt of an MBI will not be an issue.


Please do not hesitate to contact the authors if you have any questions regarding CMS’ new alert or general Section 111 questions.

[1] Public Law 114–10, 114th Congress, April 16, 2015, 129 Stat 87.

[2]  CMS Press release CMS finalizes New Medicare Card distribution ahead of deadline, accelerating fight against Medicare fraud and abuse, January 16, 2019.

[3] CMS Administrator Seema Verma, CMS Press Release, September 14, 2017.

[4] See e.g.,

[5] Centers for Medicare and Medicaid Services webinar held on January 17, 2017 entitled: Social Security Number Removal Initiative (SSNRI): SSNRI Impacts Upon CMS’s Medicare Secondary Payer Stakeholders, Brian R. Pabst, MPA, Technical Advisor, power point slide no. 3.

[6]  Id. at slide nos. 3 and 4.

Mark Popolizio, J.D.

Mark Popolizio, J.D., is vice president of MSP compliance, Casualty Solutions at Verisk. You can contact Mark at

Mike Gibbon

Mike Gibbon is the assistant director of product operations at ISO Claims Partners, a Verisk business. You can contact Mike at

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