Healthcare regulations and policies are very complex and ever-evolving. It’s important for managers of health plans and state Medicaid agencies to understand what new legislation means and how it affects their programs. Standards Perspectives brings you the latest details on new policies and standards so you can quickly and clearly learn what’s important to make the right decisions.
The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 (PL 114-10 s.501) required CMS to remove Social Security Numbers (SSNs) from all Medicare cards in order to reduce identify theft. While the legislation is not new, significant deadlines are approaching.
The new identifier displayed on Medicare cards will be the Medicare Billing Identifier (MBI). It is the same length as today’s Medicare ID (HICN), but has a different format. The gender marker is also being removed from the card along with the signature. CMS has published information on the Social Security Number Remediation Initiative (SSNRI) here.
SSNRI affects all CMS business partners and will require coordination across federal, state and private sector stakeholders. Though primarily a Medicare exercise, it will impact state Medicaid agencies (SMAs) around the country due to Medicare/Medicaid dual eligible populations.
Many Social Security Administration (SSA)-provided interfaces such as Buy-In will continue to process transactions based on the HICN. Medicaid systems will need to process both the HICN and the MBI as appropriate on an ongoing basis.
- Entities must be ready to process MBI: April 1, 2018
- Card Issuance: April 2018 – April 2019
- Implementation date required by law: April 16, 2019
- Interface updates to remove HICN (SSN-based): through Dec 31, 2019
CMS is holding bi-weekly SSNRI conference calls for states and making 90/10 funding available.
CMS will distribute around 60 million new Medicare cards. CMS has not yet identified how they will roll out cards (i.e., region vs. alphabetical, etc.). In total, around 150 million MBIs will be assigned to cover all active and deceased/archive beneficiaries.
CMS will also be modifying external Medicare-related data exchanges to no longer use the HICN – except in limited circumstances – after December 31, 2019. There will be a transition period where both the HICN and MBI may be exchanged with CMS. The transition period should begin in April 2018. Testing with state Medicaid agencies is scheduled to begin in October, 2017.
While state agencies will get access to MBI information for their beneficiaries from CMS, healthcare providers will need to obtain the MBI from their patients. This is consistent with the intent of the legislation to help prevent beneficiary identity theft.
States will need to ensure their MCOs and their contractors are prepared for the transition. Depending on the state’s arrangements with its contractors, both their eligibility and claims processing systems could be impacted. The continued use of the HICN for some purposes will lead to the need to retain both the HICN and MBI in many systems.
What This Means for Medicaid
Lack of readiness could lead to significant claims processing issues in state Medicaid programs. Claims for those eligible for both Medicare and Medicare are processed by both – beginning with Medicare. These claims are typically referred to as “crossover” claims when they arrive at Medicaid systems for processing. CMS has a Coordination of Benefits Contractor (COBC) that keeps track of what state Medicaid programs should receive which claims and forwards them.
Starting in April of 2018, states that do not have their COBC eligibility and claims processes prepared for the MBI will face a loss of electronic automation for processing Medicare crossover claims in their Medicaid systems. Either electronic crossover claims will not arrive or those that do may suspend or deny. Providers will experience a loss or delay in capturing revenue and state call centers will experience elevated call volumes. Manual workarounds may be impractical to implement or insufficient to deal with large volumes of issues.
States that are not already engaged on a project to prepare their systems are at risk for significant issues that would be visible to their provider community. High volumes of calls and paper calls could result. If your state is not on track to be ready, we recommend immediate engagement with your vendors and CMS to ensure success.
You can read more Conduent insights about healthcare regulations in previous editions of Standards Perspectives.