By Crystal Ewing, Manager of Data Integrity, ZirMed
Twitter: @Zirmed
By now you’ve probably heard that one of the outcomes of the passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is that the Centers for Medicare and Medicaid Services (CMS) will be replacing the old Health Insurance Claim Number (HICN) on Medicare cards with a new, randomly generated Medicare Beneficiary Identification (MBI) code. Officially, the change is known as the Social Security Number Removal Initiative.
The intention is altruistic. HICN uses Social Security numbers, plus a couple of additional characters, to create the current ID numbers. That practice poses a huge threat of identity theft (medical and financial) among one of our most vulnerable populations, the elderly. A Medicare card that is lost, copied, or even left in view in a public area or in the home could lead to a host of problems, as Social Security numbers provide access to all sorts of private information. There’s no question that removing them in favor of a randomly generated combination of letters and numbers (similar to the recommended best practices for passwords) is the right thing to do.
Yet there’s a difference between doing the right thing and doing things right. CMS has been very specific in saying what it wants to do, but has been far less specific in saying how it plans to go about it. At this point, the transition to the MBI is a road filled with unknown twists and turns that make it potentially difficult for providers to navigate. And with only 20 months to make the transition, which begins in April 2018 and ends on December 31, 2019 (at least, as of today), providers need to begin preparing for the change now.
Scope of the project
To understand the challenges that will be involved, it helps to look at the scope of what will be affected. 60 million Medicare beneficiaries are currently active, while another 90 million are deceased/archived. Each will have to be converted from an HICN to an MBI. Beginning in April 2018, it is likely new Medicare members will receive MBIs only, as will anyone whose identity is compromised post-implementation.
Like the HICN, the MBI will consist of 11 characters. (See Fig. 1.) The difference is that each character in the MBI will be randomly assigned following a formula rather than being tied to any beneficiary-specific information. (See Fig. 2.) Staying with 11 characters should help ease the transition at least somewhat, since the field and rules around it will be similar.
Receiving updated information
Where it becomes difficult is when beneficiaries actually go to their providers for care. Currently, if beneficiaries don’t bring their Medicare cards with them, the provider knows how to retrieve the information. A simple eligibility verification request provides the HICN, making it easy for providers to file claims accurately.
With the new MBI, so far that is not the case. CMS has advised that it will not be sending MBIs directly to providers so they can update their records. The stated reason is to protect Medicare beneficiaries against identity theft. Instead, providers are instructed to obtain the information from their patients by asking for their new Medicare cards when they come for an office visit.
That is all well and good if the Medicare beneficiary (or their caregiver) brings the card with them. But what if they don’t?
At that point the only way for providers to receive the updated MBI from CMS is when the provider receives the remittance advice, which will include the MBI if the provider filed the claim using the patient’s HICN. In feedback provided directly to CMS, both ZirMed and The National Clearinghouse Association have pointed out that this approach may not be ideal given that it unnecessarily delays the information being updated.
The ideal time to update records is during the eligibility verification process. Providers will be examining the eligibility document to ensure the patient has the proper coverage for the services about to be administered and validating the type (standard Medicare, Medicare Advantage, etc.) and the payer.
Making updates is part of the normal workflow at that point, so an advisory that the old HICN has now been replaced with this new MBI makes sense. Receiving the information only on the remittance advice means it could easily be overlooked.
From a revenue cycle standpoint, during the transition period CMS will pay on either number. Providers will actually be able to file using both, similar to what happened during the transition to ICD-10. Using the old HICN when filing a claim after December 31, 2019, however, could mean a denial or a delay in payment until it is updated with the proper MBI. So it becomes extremely important for providers to ensure they’re using the MBI for that beneficiary as soon as it becomes available. Doing so is made significantly more difficult if CMS waits until the remittance advice to provide it.
More uncertainties
While the question of when the MBI should be returned is generally considered the most pressing issue, it’s not the only one.
So far, the distribution plan for the updated Medicare cards is vague, making it difficult for providers to know when they should coach their patients to be on the lookout for new cards. Will the new cards be rolled out all at once, or in waves based on geography, or jurisdiction, or some other criteria? Given that the easiest way to obtain the new MBI is from patients, knowing when they have received their cards simplifies that process and avoids any undue stress, especially on the elderly or those in non-home living arrangements (skilled nursing facility, assisted living, rehabilitation facility, etc.). As mentioned above, CMS says it will notify providers that it has mailed a new Medicare card in the message field as part of the eligibility verification process—meaning your eligibility-verification vendor can help alert you to when an individual patient has been sent a new card. Receiving the MBI on the remit is better than not receiving it at all, but still may not be ideal in terms of avoiding revenue delays or workflow bottlenecks.
Another question is what will happen with new Medicare beneficiary applicants. Will they be assigned a new Medicare ID card if the application is filed before April 1, 2018 but approved after that date? CMS says once it begins mailing the new Medicare cards members will only be assigned an MBI. So part of the answer depends on when CMS actually starts mailing new cards. The agency also states that despite the fact it will be accepting both numbers during the transition period, providers must be ready to accept the MBI by April 2018 since that is the only number new members will have. That’s the hard deadline to have provider systems ready.
Even the process of using both the HICN and MBI raises questions. While it makes sense, exactly how it will work and what will be required of providers during that period still contains a lot of gray areas. Not the least of which is how Medicare Advantage plans will be affected.
Then there is the big question: what if the transition period proves to be too short for all providers to prepare their systems and make adjustments to include both numbers initially, attach all their records to the MBI, and then eliminate the HICN completely? Will there be a grace period as with past initiatives? Or will CMS hold fast to the December 31, 2019 date?
The answers to these and other questions will have a profound effect on the success of the transition and how successfully providers will be able to serve Medicare beneficiaries during this period.
Preparing for the transition
The only thing that is certain is that the migration to MBI will happen. With that in mind, here are some questions providers need to ask in order to ensure they’re prepared:
- How long will my vendor need in order to have my systems ready for the new cards?
- What software development and infrastructure changes are needed, and what business logic and workflows need to change?
- What effort and time are needed to map the process through its entire lifecycle?
- How much will all this cost?
- Will my system be functional and able to accept a dual processing of the HCIN and MBI?
- What editing will be involved to ensure the system adjusts accurately and quickly during the short CMS-designated transition period? Longer term?
- If new cards are distributed to my Medicare patients gradually, will that be better for my system’s capacity vs. if they are all distributed at the same time?
- Will the system be able to accommodate both the card -umber change and the volume of card-number changes?
- Will my system coincide with CMS’ eligibility verification process and its authorization process for old and new card numbers?
- How will this change to new Medicare cards impact patient care? Can we avoid claims denials?
- How will this change to new Medicare cards impact provider and revenue integrity?
Thinking through the technical process ahead of the transition will help ensure providers are prepared no matter how the program is ultimately structured. (For more detail on what the change means for providers, check out CMS’ FAQs.)
Smooth route
It remains to be seen whether CMS will take the concerns expressed in comments from the industry into consideration as it makes its final decisions. In the meantime, providers will be best served by ensuring they do all they can to prepare for the transition no matter what form it takes. The key to this is is getting out ahead of it instead of waiting until the last minute. Taking that route will help avoid or minimize potential pitfalls along the way.
This article was originally published on ZirMed and is republished here with permission.