The Centers for Medicare and Medicaid Services has released an updated Non-Group Health Plan (NGHP) User Guide version 5.3.

The primary change to the User Guide involves the details of the CMS transition with its Social Security Number Removal Initiative (SSNRI) and how this transition will impact MMSEA Section 111 Reporting.

The Medicare Access and CHIP Reauthorization Act (MACRA) requires CMS to remove Social Security Numbers (SSNs) from Medicare beneficiary ID cards and issue new cards with a new 11-byte Medicare Beneficiary Identifier (MBI) to beneficiaries by April 2019.

There will be a 15-month transition period beginning October 2018. During the transition per
iod, physicians and other providers may submit a Medicare claim using either the patient’s valid and active SSN or the MBI.  Medicare will return both the SSN and the MBI on the remittance advice.

All Medicare claims submitted after January 2020 will be required to use the MBI. Those claims filed with the patient’s SSN will be rejected.

Regarding Section 111 reporting for health plans and workers’ compensation administrators, the most current Medicare ID (HICN or MBI) will be returned in the Section 111 response files in the “Medicare ID” field. Further, if an RRE submits information with a HICN and the Medicare beneficiary has received their MBI, the MBI will be returned. Otherwise, the most current HICN will be returned.

Responsible Reporting Entities (RREs) may submit subsequent Section 111 information for the Medicare beneficiary using either the HICN or MBI.

Regarding conditional payment correspondence, the Benefits Coordination and Recovery Center (BCRC) and Commercial Repayment Center (CRC) correspondence will use the Medicare identifier that RREs most recently provided when creating or updating a Medicare Secondary Payer (MSP) record.

Therefore, if the most recent information that was received used a HICN, all subsequent issued correspondence will be generated with the HICN as the Medicare ID. If the most recent information received used an MBI, all subsequent issued correspondence will be generated with the MBI as the Medicare ID.