Posted In: Health Care
By Laura F. Fryan & Nicole M. Thorn on October 29, 2019
I’d like to introduce you to my colleague, Nicole Thorn. She brings a wealth of experience to the Brouse Health Care Practice Group from working in administration for several hospitals and most recently as the compliance officer for a physician practice group. You’ll love her practical approach to any issue in your practice!
If you have been working in health care long enough, you know the standard Medicare policy number, known as HICN by the Centers for Medicare & Medicaid Services (CMS), for billing purposes has traditionally been the beneficiary’s social security number followed by an alpha character, usually an A or a B and once in a while a D. Registering and updating Medicare patients’ insurance information has been smooth sailing for a long time.
But with the rise in security and privacy awareness and risks, Congress recognized the vulnerability of continuing to use Medicare beneficiaries’ social security numbers on their ID cards. In 2015, the Medicare Access and CHIP Reauthorization Act (MACRA) required CMS to remove social security numbers from all Medicare cards by April 2019. This requirement also affected Railroad Medicare beneficiary cards. (See MLN Matters Number SE18006, New Medicare Beneficiary Identifier (MBI), Get It, Use It.)
For most of 2018, CMS re-issued new Medicare ID cards to its beneficiaries with new ID numbers, now called MBIs — Medicare Beneficiary Identifiers. These are randomly generated IDs that include numbers 0-9 and all uppercase letters except S, L, O, I, B, and Z to avoid confusion with numbers similar in appearance. The ID contains hyphens between segments, but CMS cautions not to use these hyphens when submitting claims or verifying eligibility.
Most importantly, effective January 1, 2020 claims using the old ID format (HICN) will be denied with few exceptions. Regardless of the service date of your claims, your practice must be using the new MBI format for all Medicare and Railroad Medicare patients to avoid denials. The few exceptions when the old HICN format can be used are in appeals, claim status inquiry on claim dates of service prior to 1/1/2020, and span date claims when the start date of the services is prior to 1/1/2020 (e.g., home health claims covering a 30-day span beginning in December 2019 that continues into January 2020). Claims that are denied for the incorrect ID number will contain an A7 Claims Status Category Code, 164 Claim Status Code, and an IL Entity Code on your remittance advice.
If your practice does not typically verify a Medicare patient’s ID card at check-in because it has been so reliable, you may want to start now so you are certain you will have the latest MBI in your practice management or billing system. If you do not have access to a Medicare beneficiary’s card, or they do not bring it with them, you can verify the MBI on your Medicare Administrative Contractor’s (“MAC’s”) MBI Look-Up Tool available on their website, such as mycgs.com. You will need your patient’s social security number to search for the MBI. For best results, CMS suggests searching for individuals with name suffixes including Jr. or III without those extensions as part of the last name.
Finally, your claims clearinghouse and practice management vendors should be ready for this change too, but you may want to follow up and ensure that they too are able to process the MBI without the HICN in all transactions, including eligibility, claims submission and remittance advice processing.
Avoid delays in revenue collection by ensuring your health care business is prepared for this major update.
Brouse McDowell’s Health Care Practice Group has experience on many levels of health care operations of all facility types including revenue cycle management and reimbursement issues. If you have questions or concerns about this topic or any other, please reach out to our team so you can focus on running your health care business.
This blog is intended to provide information generally and to identify general legal requirements. It is not intended as a form of, or as a substitute for legal advice. Such advice should always come from in-house or retained counsel. Moreover, if this Blog in any way seems to contradict advice of counsel, counsel's opinion should control over anything written herein. No attorney client relationship is created or implied by this Blog. © 2019 Brouse McDowell. All rights reserved.