By: TROY ABRUZZO
Everyone in healthcare knows that data is quickly transforming not only how care is delivered but also how the business side of the industry works. It seems each year brings new regulatory challenges surrounding data – from the ICD-10 and Meaningful Use changes we experienced the past several years to new reporting standards introduced by the government to start in April 2018.
The upcoming Centers for Medicare & Medicaid Services (CMS) Social Security Number Removal Initiative (SSNRI) requires that by April next year, states, beneficiaries, health plans, and especially providers be prepared to support a new beneficiary policy number format in working with their single largest payer: Medicare.
Why are they doing this?
First some background. Historically, CMS has used a Social Security-based patient identifier – the Health Insurance Claim Number (HICN) – on Medicare cards and for transactional data. The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 called for the removal of the HICN from Medicare cards and business transactions with CMS business partners as a measure to protect against medical identity theft.
In other words, as a result of MACRA, a Medicare patient’s unique Social Security number will begin to be replaced as their patient identifier starting as early as April next year.
As CMS continues to standardize a more secure format for patient data, the upcoming SSNRI regulation mandates the use of a new policy number – the Medicare Beneficiary Identifier (MBI) – in place of the HICN. Starting in April 2018, the MBI transition will begin with updated beneficiary cards being re-issued through April 2019. By January 2020, only the MBI will be used for all Medicare transactions.
Why should providers care about changes that Medicare is making to their identifier numbers, and how should they prepare?
As far as regulatory changes go, this one is relatively administrative in nature. Nonetheless, providers must be ready for a rapid transition to the MBI, with an anticipated 150 million identifiers to be issued over the next three years.1 And given that Medicare represents the largest patient population for the majority of healthcare providers, providers can’t afford not to be prepared.
When preparing for the SSNRI impact, it is important to first understand how and where HICNs are currently in use. Providers should assess both patient experience and business operations, including processes, personnel, and software across hospitals, physician practices, other treatment providers, and in the back office.
To start, providers should consider the following questions:
- Where and how does my organization currently use the HICN?
- Do we understand our revenue exposure in how the HICN and MBI are stored?
- What is our current exception process for patients who do not know their HICN?
- How much time do we need to identify changes and develop a plan of attack?
- Do we currently communicate with patients about billing or ID changes?
- How will we prepare staff, patients, and families to be ready for this change?
- Do we have a back-up plan if CMS experiences issues with the transition?
- How will we know we have been successful?
After careful consideration, the following steps represent general best practices that should be included in a change management focused approach:
- Conduct systems analysis to identify where the HICN is in use.
- Confirm scope and timing of patient account conversions and develop approach.
- Define your change management approach for training, communication, and readiness.
- Establish a process to identify any billing issues that might result from the conversion.
- Execute the plan and support the implementation.
Long-term, the scope of change brought by the SSNRI will likely go beyond the public sector. The growing prevalence of identity theft accompanies the consensus that secure patient identification makes sense. With Medicare representing the largest payer and patient population for most providers, the industry finds itself on the cusp of a critical change that will only grow in impact as other private sector payers follow suit.
1 Social Security Number Removal Initiative (SSNRI) [PowerPoint slides] (November 1, 2016). Retrieved January 9, 2017 from https://www.cms.gov/Medicare/SSNRI/index.html