The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires the Centers for Medicare & Medicaid Services (CMS) to remove Social Security numbers (SSNs) from Medicare cards before the end of the decade. To comply with MACRA, CMS created the Social Security Number Removal Initiative (SSNRI). On Tuesday, January 17, CMS held an open door forum designed to highlight the impact of the SSNRI on the Medicare Secondary Payer (MSP) community. The key highlights and takeaways from the call are as follows:
- What is the SSNRI? The SSNRI is also known as the SSN Replacement Initiative. As mandated by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the goal of SSNRI is to remove all SSNs from Medicare cards to prevent fraud and identity theft.
- What is the timeline for the SSNRI? CMS’s goal is for the Medicare Beneficiary Identifier (MBI) to replace the HICN (Health Insurance Claim Number) for most transactions by January 2020. CMS will begin issuing MBIs in April 2018. During the transition period from the HICN to the MBI, CMS will accept both MBIs and HICNs for all transactions. Because CMS will begin processing, transmitting, and using MBIs as the key identifier for some beneficiaries as early as April 2018, all stakeholders must be able to submit and accept MBIs by that date.
- How will the SSNRI affect Medicare Secondary Payer (MSP) processes? Despite the fact that CMS has secured a special waiver for the MSP program in which CMS will accept both MBI and HICN for MSP purposes indefinitely, insurers will still need to know claimants’ MBIs. The reason is that all areas of Medicare Secondary Payer will provide either an HICN or an MBI depending on the particular communication provided. So, for example, a conditional payment notice (CPN) from the Commercial Repayment Center (CRC) will identify the claimant and could contain either an HICN or an MBI. The only way to know if it’s an HICN or the MBI is the numerical format as identified by CMS. Correspondence from the Benefits Coordination & Recovery Center (BCRC), CRC, and Workers’ Compensation Review Contractor (WCRC) could contain either an MBI or an HICN and generally will have the most recently created number. By January 2020, it’s anticipated that the only number provided in response will be an MBI, although HICNs will be permitted indefinitely in MSP-related correspondence directed to Medicare and its contractors.
- When will this start? Beginning April 2018, CMS will initiate a transition period when it will accept either an HICN or an MBI for all transactions (including MSP-related transactions). During the transition period, the NGHP (non-group health plans) data exchange will provide either the HICN or the MBI, whichever is more recently generated. (This basically means that if the MBI has been generated, information will be returned in a query file; if the MBI has not been generated, then CMS will return an HICN.)
- What are the basic differences between an MBI and an HICN? Most HICNs contain only 10 characters (a 9-digit SSN plus a letter), but it’s possible they can have as many as 11. The MBI will be 11 characters, and it will have very specific alphanumeric requirements depending on the specific positions within the 11-character identifier. The MBI will be in a format that will ensure there are no duplicate MBIs and HICNs.
- What are the key deadlines and dates? CMS has 150 million MBIs to generate, and it will do so over an extended time frame. Sixty million will be generated for living beneficiaries, and 90 million will be generated for deceased beneficiaries. Despite the fact that the MBI will replace the HICN over time, parties will need to be able to accept, store, and process MBIs starting in April 2018. CMS indicated that it would have a significant amount of outreach, education, and training to follow.
- Are there any primary resources available? Yes. CMS has established a web page describing the SSNRI, which can be accessed here. On that page you can find specific format instructions and other information describing the initiative. In addition to the January 17 Open Door Forum, it’s anticipated that CMS will provide other resources for stakeholders throughout the year and into next year.
Additional announcement from CMS regarding update to Treasury letters
In addition to the major news about SSNRI, CMS had a somewhat surprising announcement regarding changes to the U.S. Treasury Department’s Medicare Secondary Payer program. Beginning later this year, all communications from the Treasury Department will contain a recovery case identification number as the key identifier. The Treasury Department will provide no other identifier. It will be important for primary payers to capture this information to identify Treasury recovery claims properly and act promptly.
As we continue to counsel, our suggested best practice to help avoid a Treasury recovery scenario is to properly identify, mitigate, and resolve conditional payment claims as soon as is practicable and certainly within the deadlines outlined by CMS’s contractor in the appropriate recovery correspondence. We will continue to provide updates on this change as CMS and/or Treasury provide more information.
We will help with the MBI transition
We will be ready to accept and provide MBIs and will continue to offer additional updates as they become available. We anticipate updates from CMS and will work with our clients and CMS to address any issues that may arise. In the meantime, our team of Medicare experts remains willing and able to assist in answering any questions about this important project and how your process may be affected.