March 7, 2018
In an effort to “prevent fraud, fight identity theft, and keep taxpayer dollars safe,” the Centers for Medicare and Medicaid Services (CMS) is issuing new Medicare cards to Medicare enrollees beginning in April 2018. This legal alert details what the new Medicare cards will mean for providers and how providers can prepare for this change to best ensure a seamless transition.
The Medicare Access and CHIP Reauthorization Act of 2015 requires CMS to remove Social Security numbers (SSN) from all Medicare cards by April 2019. CMS will replace the SSN-based Health Insurance Claim Number (HICN) with a new, unique, randomly assigned number called a Medicare Beneficiary Identifier (MBI). Congress believed that replacing the SSN-based HICN would better protect private healthcare and financial information, as well as federal healthcare benefit and service payments, from fraud. This change from the SSN-based HICN to the MBI will not change enrollees’ Medicare benefits, and the effective date of the new cards remains the date that each beneficiary was or is eligible for Medicare. CMS will issue these new Medicare cards to enrollees through the mail beginning in April 2018, and the mailings will occur in phases based on geographic location, as set forth in the sequence outlined by CMS. Additional details on timing will become available as the mailings progress.
To ease the transition, CMS is developing capabilities whereby providers can look up the MBI of a patient through a secure tool at the point of service. Additionally, although providers’ practice management and billing systems must be able to accept the new MBI format by April 2018, CMS is providing a 21-month transition period, beginning in April 2018 through Dec. 31, 2019, during which time, providers can continue to bill using the existing HICN, even if the patient has received a new card with their MBI. After this transition period and beginning on Jan. 1, 2020, providers will be required to use the MBI, absent limited circumstances.
Providers should take the following steps to prepare their facilities and patients for the new Medicare card changes:
Lastly, providers should be aware of potential scams related to the debut of the new Medicare cards. CMS has made clear that it will never ask enrollees for personal or private information or charge a fee to obtain the new card. In fact, enrollees need not take any action to obtain these new Medicare cards.
For more information or to discuss potential implications of CMS’s issuance of new Medicare cards, please consult one of the authors.