Today, CMS hosted a Town Hall regarding the SSN removal initiative (SSNRI) and its impact to Medicare Secondary Payer processes and particularly MMSEA Section 111 Reporting; For our prior blog on this Town Hall and the SSNRI, click here.
There were two parts to the call: In the first segment, CMS explained its overall plan for SSNRI generally and how it will impact the entire stakeholder community including Medicare beneficiaries, providers, vendors, and other stakeholders. Essentially, the plan is to replace the use of SSNs and HICNs entirely with a Medicare Beneficiary Identifier (MBI). CMS explained that their primary goal is “to decrease Medicare beneficiaries’ vulnerability to identity theft by removing the SSN-based HICN from their Medicare ID cards and replacing the HICN with a new Medicare Beneficiary Identifier (MBI), which does not contain an SSN or other personal information.” The transition timeline is explained on slide 11 of CMS’ PowerPoint. For a link to CMS’ PowerPoint, click here. During April 1, 2018- December 31, 2019, there will be a transition period in which accept both HICN and MBIs. By January 2020, the plan is for CMS to only work with/exchange data with MBIs, except for limited exceptions.
In the second segment, CMS explained the SSNRI impact to Medicare Secondary Payer processes and Section 111 reporting. As the transition period begins on April 1, 2018, CMS indicated that there will be no change to the file format utilized in the Section 111 Reporting data exchange process. With regard to using the query function to determine Medicare eligibility, CMS indicated that full SSN’s and partial SSNs will still be accepted. However, CMS will retitle the field to “Medicare Identification” in its response file; CMS will respond with the most current identifier, which may be the MBI. Once CMS has responded with the MBI, CMS expects that the Responsible Reporting Entity (RRE) will use the MBI going forward when continuing to correspond with CMS. RREs should be pleased that CMS was able to implement the SSN removal without record layout changes, however MBIs will be alpha and numeric, and systems should be modified to accommodate the same.
With regard to use of all portals used for MSP functions- i.e., the MSPRP, the WCMSAP, and the CRC portal, CMS will allow for the use of the HICN or MBI; however, an SSN can still be utilized. The portal logic will recognize any of the options, SSN, HICN, MBI.
The most surprising part of the Town Hall which caused a question from a listener on the call was CMS’ announcement that with regard to Treasury letters, by some point in the calendar year 2017 (exact date to be determined), the Treasury will only provide a Recovery Case ID on correspondence. No SSN, HICN, or MBI will be listed on Treasury correspondence. Listeners on the call asked how RREs would identify which claimant the Treasury correspondence would relate to, if there was no identifying information other than claimant name and Recovery Case ID. CMS indicated that the Treasury Recovery Case ID will correspond to a previously assigned BCRC/CRC Recovery Case ID number, and therefore the primary payer would be able to identify the beneficiary through that manner if it was aware of the case ID from the BCRC/CRC.
This change with regard to Treasury correspondence demonstrates the necessity for primary payers to ensure that it is in receipt of a Case ID from the BCRC/CRC early on in the claims process for claims involving a Medicare Beneficiary, or it may not be able to identify the exact claimant if a Treasury demand is received. Therefore, the only way to timely respond to Treasury correspondence is if coordination of benefits has been initiated. With the increase in Conditional Payment Notices (CPNs), RREs should develop a process to capture the Case IDs at time of the MIR report, to be able to respond to any potential Treasury letters. As always, Franco Signor recommends a proactive approach to conditional payment management. For questions on the SSNRI or its impact to MSP processes, please contact us at email@example.com.
Heather Schwartz Sanderson, Esq., MSCC, CHPE, CLMP, CMSP
Chief Legal Officer
Franco Signor LLC