MSP Stakeholders Exempt from CMS Beneficiary Identifier Changes: Everything You Need to Know About New MBIs

CMS, Medicare Set-Aside Blog, Medicare Set-Asides, Social Security on February 26, 2018 | Posted by Katharine Rupp, JD

Earlier this month, CMS held an open-door forum regarding the impending initiative to remove Social Security numbers (SSN) from all Medicare cards. As we previously reported, this plan aims to generate a new Medicare Beneficiary Identifier (MBI) for over 150 million Medicare beneficiaries; both active and deceased beneficiaries. The MBI will replace all SSN based HICN numbers with a unique 11 digit MBI made up of both numbers and uppercase letters.

In many applications, HICN or SSN fields will be renamed as MBI fields, but no additional changes with respect to file formats will be made. During the transition period of April 1st, 2018 to December 31st, 2019, MSP stakeholders will still be able to still utilize the previously issued HICN, SSN, or the newly issued MBI to share data with CMS. After December 31st, 2019, HICNs may still be used for the following:

• Appeals;
• Reports (Incoming to CMS (quality reporting, Disproportionate Share Hospital data requests, etc. and Outgoing from CMS (Provider Statistical & Reimbursement Report, Accountable Care Organization Reports, etc.);
• Retroactive enrollment;
• Span-date claims;
• Adjustments on a claim (Prescription Drug Event, Risk Adjustment and Encounter data, etc.) Incoming information requests (inquiries, Medicare Secondary Payer information requests, Requests for Medical Documentation, etc.); and
• Incoming premium payments (Part A premiums, Part B premiums, Part D income related monthly adjustment amounts, etc.).

By January 2020, HICNs will no longer be exchanged with beneficiaries, providers, plans or other third parties. However, per an exception granted for all MSP data exchanges and processes, Responsible Reporting Entities (RREs) will still be able to use the MBI, the SSN, or the HICN for MSP reporting.

CMS will respond to all correspondence from RREs using the most current corresponding identifier in the existing HICN field. Meaning that while MSP providers can use either the MBI, SSN, or HICN in correspondence to CMS, starting in April CMS will respond using a beneficiary’s newly assigned MBI.

More information about the SSN removal initiative can be found on CMS’ website here. CMS has also indicated that they will continue to provide extensive education and outreach through April 2019 to assist with the transition period.