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CMS Clarifies MBI Directions This Week

CMS Clarifies MBI Directions This Week

MedHOK has been in communication with the Centers for Medicare and Medicaid Services (CMS) as well as a number of health plan clients who have assisted us in clarifying some ambiguity surrounding the rollout of the Medicare Beneficiary Identifier (MBI) beginning April 1, 2018.

As we advised in mid-February and early March 2018, CMS issued two Health Plan Management System (HPMS) memos that indicated the following:

  • If plans have used the HICN as opposed to another Medicare number on redetermination and reconsideration notices, plans should use a truncated HICN on those letters during the transition period from April 1, 2018, through December 31, 2019.
  • Plans would have to continue to use the full HICN for IRE case submissions.
  • While both the MBI and HICN could be used in CTM transactions, the HICN would primarily be relied on during the transition period.

When those notices were issued, MedHOK immediately contacted CMS (and worked with a number of clients to ask them to do the same) regarding the following:

  • Use of HICN only, or the predominant use of HICN, during the transition period contradicts earlier announcements that indicated that the identifiers could be used interchangeably during transition.
  • Urging CMS to allow the use of the identifiers interchangeably.
  • Asking for clarification on how to handle Medicare beneficiaries new to Medicare as of April 1 who would only have an MBI.

This week CMS did clarify that HICN and MBI could be used interchangeably. CMS updated its main MBI web page with the following on March 28, 2018:

*Updated* The HICN is now used on many standardized forms and letters. We’ll be revising these materials just for MBI use, but until they’re ready, plans should keeping (sic) using the forms they have with either the HICN or MBI as appropriate.”

Click Here to review the statement in context on this CMS page.

While this has been a moving target for the past several weeks, based on the final communication from CMS above, MedHOK believes that the following would meet CMS compliance requirements throughout the transition period:

  • Use of the HICN, MBI or another member identifier on redetermination and reconsideration letters is acceptable. For members new to Medicare with only an MBI, the MBI or another member identifier should be used. The HICN would have to be truncated. CMS has not yet clarified whether MBI should be truncated during the transition period; however, based on the CMS directive that MBI should be truncated after the transition period, it is MedHOK’s position that plans should truncate the MBI during the transition period as well.
  • Use of either the full HICN or MBI is acceptable on the IRE case submission packet or through the Maximus DDE portal, with MBI used for MBI-only members.
  • Use of either the HICN or MBI is acceptable for CTM case retrieval and submission.

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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