The Centers for Medicare and Medicaid Services (CMS) is required by law to remove all Social Security Numbers from Medicare beneficiary identification cards by April of 2019. CMS Administrator, Seema Verma, has stated that the goal of this initiative is "to help prevent fraud, combat identity theft, and safeguard taxpayer dollars." CMS will begin mailing replacement identification cards to Medicare beneficiaries in April of 2018, along with instructions for beneficiaries to safely and securely destroy their current Medicare card and keep their new Medicare number confidential. Each beneficiary will be assigned a random, unique eleven-digit number containing a combination of numbers and uppercase letters, called the "Medicare Beneficiary Identifier" or "MBI".
In an effort to prepare for this upcoming change, healthcare providers should ensure that their system and business processes are ready to accept the new MBI by April of 2018 for transactions with the Medicare Administrative Contractor, such as billing, claim status, and eligibility status. CMS has stated that there will be a transition period from April 1, 2018 through December 31, 2019 where providers will be able to use either the old Health Insurance Claim Number ("HICN") or the new MBI to exchange data and information. However, CMS has specifically stated in guidance that a healthcare provider's system must be ready to accept the new MBI by April 1, 2018. If you use vendors to bill Medicare, it is strongly recommended that you contact them to ensure that their systems will be ready for the transition.
In addition, if providers have patients who qualify for Medicare under the Railroad Retirement Board (RRB), they will no longer be able to distinguish these patients by the new number on the Medicare identification card. Rather, these patients will have a logo on their new card and a message will be returned on the eligibility transaction response showing that the beneficiary is a Railroad Retirement beneficiary. As a result, those providers who solely rely on the beneficiary number for identification of RRB patients will need to implement a new identification process. Lastly, CMS has advised providers to update their practice management system's patient numbers to automatically accept the new MBI from the remittance advice transaction.
There is concern that healthcare providers will experience difficulty in ascertaining the new Medicare Beneficiary Identifier due to beneficiaries being issued new Medicare cards over the period of a year, beneficiaries who have not updated their address information with CMS and, as a result, do not receive their new card, or beneficiaries who come into the provider's facility and forget their new card and number. CMS has offered the following advice to providers:
- Beginning in April of 2018, when the provider uses the beneficiary's HICN to check eligibility through the HIPAA Eligibility Transaction System, CMS will return a message notifying the provider that the particular beneficiary has been issued an MBI. As a result, it would be prudent to then ask the patient for their new MBI and save it in your system.
- Beginning in June of 2018, providers will be able to use a secure look-up tool through their Medicare Administrative Contractor to identify the newly assigned Medicare Beneficiary Identifier. The provider will need the beneficiary's first and last name, date of birth, and Social Security Number.
- Beginning in October of 2018, when the provider submits a claim using a beneficiary's HICN, CMS will return both the HICN and MBI on every remittance advice.
As of January 1, 2020, providers will be required to use the new Medicare Beneficiary Identifier for all transactions except for a few carve-outs specified by CMS (such as appeals and claim status query for dates of service prior to January 1, 2020). As a result, providers should begin preparing, and ensure that their third-party billing companies are preparing, for this upcoming transition.
Nicholas Gachassin, III, J.D., LL.M. and Lanzi Meyers, J.D. are attorneys at Gachassin Law Firm, L.L.C., which is dedicated to the representation and counseling of healthcare providers.
This article is offered only for general informational and educational purposes. It is not intended to be offered as and does not constitute legal advice or legal opinions.