NGHP Mandatory Insurer Reporting Alert: Final Five Digits of SSN is the New Minimum Requirement for Reporting, Effective 01/05/2015
CMS has issued an Alert that effective 01/05/15, if an individual’s HICN or full SSN cannot be obtained, reporting can still occur as long as the individual’s last five digits of SSN, first and last name, date of birth and gender are produced. Nevertheless, reporting with a HICN or full SSN continues to be highly recommended. This change is pursuant to Section 204 of the SMART Act, which required CMS to discontinue the current requirement that full social security numbers be utilized by Non-Group Health Plan (NGHP) Responsible Reporting Entities (RREs) in Section 111 Mandatory Insurer Reporting. Another Alert with technical instructions for entering this data is pending, to be published prior to the 01/05/15 implementation date.
A link to the alert can be found here.