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CMS Throws Last-Minute Curve Ball on MBI Migration

CMS Throws Last-Minute Curve Ball On MBI Migration

Health plans have been busy changing internal systems to plan for the arrival of the first Medicare Beneficiary Identifier (MBI) numbers on April 1, 2018. In an effort to reduce fraud and stolen identities in the Medicare beneficiary population, the Centers for Medicare and Medicaid Services (CMS) will begin issuing an MBI to those newly eligible for Medicare beginning April 1, 2018. Between April 1, 2018 and December 31, 2019 (the transition period), existing beneficiaries will be issued their MBIs to replace the Health Insurance Claim Number (HICN), which includes the Social Security Number of the individual or spouse. As of January 1, 2020, HICNs should be a thing of the past.

Over the past year’s education process, CMS seemed to indicate that, beginning April 1, 2018, the MBI or HICN could be used during the transition period. Because the HICN and MBI character length remain the same, many plans and plan vendors have simply coded to accept the MBI in existing HICN fields and many are moving the HICN to a legacy field that can later be expunged as necessary. However, despite the consistent prior CMS messaging on the interchangeable nature of HICNs and MBIs during the transition period, CMS notices over the past month are throwing a curve ball to plans. CMS is now telling plans that the HICN will remain necessary, even if a member has an MBI issued. This now means that plans and vendors must revert back and preserve the HICN in system User Interfaces (UIs), reports, and coding.

In a Health Plan Management Systems (HPMS) memo to plans dated February 16, 2018, CMS issued the following notifications:

  • Plans may use either an HICN or plan identification number on Part D re-determination and Part C reconsideration letters. It was assumed that plans could now substitute the MBI, if known, for the member. CMS is now stating that the HICN (not MBI) would have to be on the letter through the transition period. It also must be truncated. MedHOK has inquired of CMS why the MBI cannot be used and what plans will do for members new to Medicare as of April 1 who will only have an MBI issued. As of yet, we have not received word back from CMS. We will keep you posted.
  • Similarly on IRE case submittals for both Part C and Part D, the full HICN must continue to be used on the case submittal. This is interesting as the Maximus’ Direct Data Entry (DDE) portal does have the ability to accept both MBI and HICN input.

In an HPMS memo to plans dated March 9, 2018, CMS issued the following notification:

  • The HPMS Complaint Tracking Module (CTM) file and system will be modified to capture either an MBI or HICN; however, CMS will primarily record the HICN in the CTM until shortly after all new Medicare cards have been mailed. This means plans that have assumed they could retire an HICN for a member with an MBI must now maintain both to ensure a proper match in their manual processes or workflow systems.

With apologies to Scottish Poet Robert Burns and his poem “To a Mouse,” but plans are quickly learning that the best-laid plans of mice and men often go awry.

NEW UPDATE AS OF MARCH 30, 2018

On March 28, 2018, CMS clarified HICN and MBI can be used interchangeably during the MBI transition period for both letters and IRE case submissions. CMS updated its main MBI page to state:

  • “*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 see this statement in context on CMS’s website.

    For our latest blog post on this topic, click here.

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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