CMS Issues Subsequent Alert on Reporting HICNs and SSNs

CMS issued a subsequent Alert on November 25, 2014 to provide additional instructions for entry of partial Social Security Numbers (SSN) as specified in the original Alert issued on September 10, 2014. As provided in that Alert, where a NGHP RRE cannot obtain an individual’s full SSN or Medicare Health Insurance Claim Number (HICN), the RRE may report the last five digits of the individual’s SSN, first initial, surname, date of birth, and gender. If the RRE cannot obtain the partial or full SSN or the HICN, the attempts to do so must be documented. The Model Language has been revised to reflect an RRE’s efforts to obtain the partial SSN. This revised language can be found here.

The subsequent Alert provides technical guidance regarding partial SSN submission as well as steps for remaining in compliance with Section 111 following the receipt of a response.  For RREs planning to submit using partial SSNs, the following technical requirements apply:

• For RREs using HEW software, a new version must be downloaded to accommodate the revisions. This software will be available on January 5, 2015.
• For RREs using their own X12 translator, a revised X12 270/271 Companion Guide must be obtained. This guide is currently available for download here.

*These technical changes do not apply to RREs who do not plan to submit using partial SSNs.

In order to remain in compliance with Section 111, it is critical to understand the response messages received when an RRE submits a partial SSN.  A new Disposition Code “DP” and new Beneficiary Not Found page have been added and indicate there were multiple Medicare beneficiary records identified based upon the partial SSN and data submitted.  When this message is received, it is not to be treated as a Disposition Code “51" which indicates that the individual is not identified as a beneficiary based on the information provided.  Where an RRE receives Disposition Code “DP” or a message indicating multiple matching records exist, the following steps must be taken to remain in compliance with the Section 111 reporting requirements:

• Verify the the SSN, name, gender and date of birth were entered accurately and resubmit;
• Enter the full SSN (if available) and resubmit;
• If the system is still unable to locae a distinct match after resubmission, contact BCRC at 1-855-798-2627. The RRE should provide the claim information to the customer service representative to file a self-report.

The full technical Alert can be found at by clicking here.