CMS Issues Alert on Reporting HICNs and SSNs

On September 10, 2014, CMS issued an Alert providing that, beginning January 5, 2015, CMS will no longer require Medicare Health Insurance Claim Numbers (HICNs) or Social Security Numbers for Section 111 reporting if the RRE reports certain data allowing CMS to identify Medicare beneficiaries. This Alert implements the SMART Act requirement that CMS revise its Section 111 reporting requirements to allow RREs to report claims without providing the claimant's HICN or SSN.

The Alert provides as follows:
In accordance with Section 204 of the Strengthening Medicare and Repaying Taxpayers Act of 2012 (SMART Act), the Centers for Medicare and Medicaid Services (CMS) is modifying the existing requirements related to the submission of HICNs and SSNs when NGHP RREs report settlements, judgments, awards, or other payments. CMS highly recommends, but does not require, that NGHP RREs submit the HICN or full SSN as part of their reports, as it significantly increases CMS’ ability to accurately identify an individual as a Medicare beneficiary. However, effective January 5, 2015, where a NGHP RRE cannot obtain an individual’s HICN or full SSN, RREs may report the following data elements that will enable CMS to properly identify a Medicare beneficiary:

•Last five digits of SSN
•First Initial
•Surname
•Date of Birth
•Gender

If NGHP RREs are unable to obtain or do not provide the HICN, full SSN, or any of the above listed data elements, they must document their attempts to obtain this information.
(RRE’s may use the model language provided by CMS located in the Downloads section of the Mandatory
Insurer Reporting (MIR) for NGHP page at http://go.cms.gov/mirnghp.)
A subsequent Alert will be published prior to the January 5, 2015 implementation, which will include additional instructions for entry of the partial SSN into the Claim Input File or Query Input File. Please continue to visit the MIR NGHP section of the CMS.gov web site at http://go.cms.gov/mirnghp for the most current information.

Fortunately, this change in reporting requirements will help RREs in cases involving Medicare beneficiaries who refuse to disclose their HICN and full SSN due to privacy concerns. It is still recommended, however, to obtain SSNs and HICNs if possible.

We will provide you with an update once CMS issues a subsequent Alert. If you have any questions, please do not hesitate to let us know.