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CMS Alphabet Soup – Medicare HICN to Become MBI

CMS Alphabet Soup – Medicare HICN To Become MBI

After we just got over the implementation of ICD-10, health plans and providers are being asked to go through another major system conversion, this time to replace the Medicare Health Insurance Claim Number (HICN) with a new Medicare Beneficiary identifier (MBI).

The purpose is two-fold:

  1. Because the HICN usually includes the social security number (SSN) of an individual or a spouse, the change to a randomly generated MBI is meant to protect beneficiaries’ privacy and reduce stolen identities (which can be a very common occurrence for older Americans).
  2. Reduce Medicare fraud. Unscrupulous individuals and providers can get their hands on an SSN or HICN and use such information to file false claims.

HICNS now are used for many purposes in the Medicare healthcare world, among them:

  • A form of primary or secondary identification for Medicare beneficiaries for the Medicare system, depending on whether they are in the Medicare fee-for-service (FFS) or Medicare Advantage system.
  • Claims submission for the Medicare FFS system.
  • Submissions for various Medicare Advantage and Part D program elements, most notably Prescription Drug Events (PDEs), Risk Adjustment Payment (RAPS), and encounter data submissions.
  • By state governments to identify individuals who are dually eligible for Medicare and Medicaid.
  • By the Centers for Medicare and Medicaid Services (CMS) as the primary identifier for the Complaints Tracking Module (CTM) system and process.

The MBI will begin to be issued around April 2018, with the final issuance of initial MBIs by April 2019. The announcement calls for the dual usage of HICN and MBI to begin in April 2018 and end by December 2019. Thereafter, the MBI will be used exclusively (perhaps with limited exceptions). In the transition period, CMS will transact business using either the old HICN or the new MBI.

The MBI will be issued to 60 million active beneficiaries and up to 90 million deceased ones (whose records could still be at risk of identity theft due to activities that will continue to occur). The new MBI will look much like the HICN. It will have 11 alpha and numeric characters, but each spouse will now have his or her own unique identifier (currently, many female spouses have HICNs that include their husbands’ SSNs). Because the field length is the same, CMS will not introduce a new field for the MBI but simply repurpose the HICN field to accept both identifiers during transition and just the MBI after. Current “HICN” fields will now have the “MBI” moniker. In addition, CMS will publish a member crosswalk table showing both the HICN and MBI for beneficiaries. This should help facilitate providers and plans gathering the MBIs upon issuance. To aid in providers gathering the MBI as well, the MBI will be added to all FFS remittances beginning October 2018.

As can be imagined, the transition will be a huge undertaking, costing the federal government, state governments, private health plans, and providers tens, if not hundreds, of millions of dollars when all is said and done. Those needing to do business with CMS must be ready to transact using both identifiers beginning April 2018.

Health plans, PBMs, subcontracted entities, and clearinghouses all will need to look closely at what needs to be done to make the change and transition. Similar to the conversion to ICD-10 (although perhaps that was more complicated), we know there is a long lead time to plan and execute.

  • All systems accepting and housing the HICN, as well as interfaces and loaders, will need to be retrofitted to take in both identifiers as of April 2018. Plans and other entities need to begin now to take an inventory as there are numerous systems (e.g., claims, sales, enrollment, and member services) that are impacted.
  • Many systems will need to provide for the same or substantially similar capabilities for the MBI as they now have for HICN. That will mean adding fields to system user interfaces (UI), databases, file loaders, searches, and reporting. Engineering must be flexible enough to allow for dual use in the transition period.
  • Plans will also need to ensure that downstream entities plan for and make the same changes.
  • While CMS will be doing significant outreach to providers, plans will need to do so as well. The provider impact with Medicare Advantage plans should be significantly less than with FFS as plans generally use a unique member ID to communicate with providers in the Medicare Advantage or Part D worlds.
  • Enrollment and eligibility could be especially challenging as HICN often serves as a secondary way of correctly identifying a member. In addition, it is the primary way of identifying members right now with CMS. Ensuring that both HICN and MBI are in place to avoid duplicate member record creation will be crucial.

There, too, are still a number of unknowns:

  • Will CMS be ready given everything that we know will go on at CMS in the near term?
  • Will states have the funding and be ready? If not, how will this impact dual eligibles in FFS programs and in Medicare Advantage?
  • Will plans be ready?
  • Will the myriad of downstream contractors be ready?
  • Will providers really be ready?
  • Will the cutoff really be December 2019 or will we see multiple extension as we saw with ICD-10?
  • Will CMS dictate the purging of HICN from systems at the end of the transition or some time thereafter? This could have significant impact on maintenance and retrieval of old cases and records and impact historic reporting.

Marc Ryan

Marc S. Ryan serves as MedHOK’s Chief Strategy and Compliance Officer. During his career, Marc has served a number of health plans in executive-level regulatory, compliance, business development, and operations roles. He has launched and operated plans with Medicare, Medicaid, Commercial and Exchange lines of business. Marc was the Secretary of Policy and Management and State Budget Director of Connecticut, where he oversaw all aspects of state budgeting and management. In this role, Marc created the state’s Medicaid and SCHIP managed care programs and oversaw its state employee and retiree health plans. He also created the state’s long-term care continuum program. Marc was nominated by then HHS Secretary Tommy Thompson to serve on a panel of state program experts to advise CMS on aspects of Medicare Part D implementation. He also was nominated by Florida’s Medicaid Secretary to serve on the state’s Medicaid Reform advisory panel.

Marc graduated cum laude from the Edmund A. Walsh School of Foreign Service at Georgetown University with a Bachelor of Science in Foreign Service. He received a Master of Public Administration, specializing in local government management and managed healthcare, from the University of New Haven. He was inducted into Sigma Beta Delta, a national honor society for business, management, and administration.

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