CMS has released an updated Non-Group Health Plan (NGHP) User Guide version 5.3. It can be found here. The primary change to the User Guide involves detailing CMS’ transition with its Social Security Number Removal Initiative (SSNRI) and how this transition will impact MMSEA Section 111 Reporting. The SSNRI initiative mandates CMS to replace all SSN-based Medicare identifiers and distribute a new 11-byte Medicare Beneficiary Identifier (MBI) to beneficiaries by April 2019. The changes detailed are consistent with the changes indicated in CMS’ Town Hall teleconference from January this year. For our prior blog on this teleconference, click here.
In summary, regarding Section 111 reporting, the most current Medicare ID (HICN or MBI) will be returned in the Section 111 response files in the “Medicare ID” field. Further, if an RRE submits information with a HICN and the Medicare beneficiary has received their MBI, the MBI will be returned. Otherwise, the most current HICN will be returned. Responsible Reporting Entities (RREs) may submit subsequent Section 111 information for the Medicare beneficiary using either the HICN or MBI. Interestingly, the changes in the User Guide state that RREs are permitted to continue to still use the full SSN, HICN, or MBI. We believe that CMS mistakenly omitted that an RRE may also use the last four digits of the SSN if the full SSN is not available, and we are reaching out to CMS to clarify.
Regarding conditional payment correspondence, the Benefits Coordination and Recovery Center (BCRC) and Commercial Repayment Center (CRC) correspondence will use the Medicare identifier that RREs most recently provided when creating or updating a Medicare Secondary Payer (MSP) record. Therefore, if the most recent information that was received used a HICN, all subsequent issued correspondence will be generated with the HICN as the Medicare ID. If the most recent information received used an MBI, all subsequent issued correspondence will be generated with the MBI as the Medicare ID.
We will continue to provide updates on the User Guide and MMSEA Section 111 updates as they arise.