SMART Update – CMS Issues Alert on How RREs Enter Partial SSNs
Jesse Hamby
December 1, 2014

In follow-up to its announcement on September 10, 2014, the Centers for Medicare & Medicaid Services (CMS) issued an updated alert on how Responsible Reporting Entities (RREs) may enter partial Social Security Numbers (SSNs) when preparing a query or submitting a report of a settlement, judgment, award or other payment. In response to the Strengthening Medicare and Repaying Taxpayers Act (SMART) which prohibited CMS using SSNs and Health Identification Claim Numbers (HICNs), CMS has updated its software and procedures to accept partial SSNs. This alert advises RREs what they must to do to submit partial SSNs without rejection errors.

Effective January 5, 2015, CMS will accept partial SSNs for query and claim input files by RREs. These computer files are necessary for a RREs compliance with Section 111 of the Medicare & Medicaid SCHIP Extension Act of 2007 (MMSEA). In order for a RRE to enter a partial SSN, the alert indicates that the RRE must document their attempts to obtain this information. To do this, CMS has updated their SSN Reporting Model language form, which now indicates to a claimant that they have the option of providing the RRE with the last 5 digits of their SSN. CMS will still accept the full SSN, and will always return a complete HICN (even if a partial SSN is supplied) to the RRE if there is a match. To view the updated model language click here.

The file requirements for submission of a partial SSN submission requires “spaces” be entered for the first 4 positions, otherwise it will be rejected. A rejected record is the equivalent of not reporting, and could subject the RRE to penalties under the law. Therefore, it is important you have a reporting agent that understands these new technical requirements to avoid errors.

CMS has determined that there is a potential for duplicate matches when a partial SSN (the last five digits of the SSN) is submitted. Therefore, CMS has added a new Disposition Code that will return the message “DP” if this should occur. This code should not be misinterpreted as code # 51, which is when a claimant is identified as not a Medicare beneficiary based upon the information provided. The RRE’s responsibility when they receive the “DP” code are instructed to take the following actions: 1) Verify the Big Five data points and resubmit; 2) Enter the full 9-digig SSN (if available) and re-submit; and 3) if the “DP” code is still returned call the BCRC to assist on the correct claimant to report.

RREs that use their own X12 Translator will need to update it. For more information on how to obtain this, please read the alert contained within this blog.

RREs that use the HEW software will need to obtain the most current version if they plan to submit partial SSNs. For more information on how to secure the updated HEW software and instructions read the alert contained within this blog.

For Direct Data Entry, it is important to note that leading spaces when submitting a partial SSN is not necessary. This is different from those RREs using software to report in compliance with the reporting law.

To read the full alert, click here.

We pride ourselves on prompt and accurate reporting for our clients. This alert helps liability insurers and self-insurers who have always had difficult collecting SSNs because of state privacy laws. RREs may still have challenges collecting the last 5 digits of the SSN, but CMS update of the model language form should help. RREs are encouraged to implement these model forms into their claim workflows as soon as possible. If you have any questions regarding potential errors or how to report under Section 111 MMSEA please contact us.