Tag Archives: Section 111

CMS Releases Technical Alert for Implementation of 5 Digit SSN Changes

Frank FairchokCMS has released a technical alert dated November 25, 2014, related to the implementation of changes to allow beneficiaries to be queried and reported using the last five digits of the SSN. CMS announced the change on September 10, 2014, and this technical alert has been pending since the announcement.

CMS presents the “Background” to this technical alert as follows:

“Effective January 5, 2015, where a NGHP RRE cannot obtain an individual’s HICN or full SSN, the RRE may report the last 5 digits of the individual’s SSN, first initial, surname, date of birth, and gender. NGHP RREs may continue to submit the HICN or full SSN as before without making any changes to the field and file formats. Additionally, the full HICN will continue to be returned if a distinct match to a beneficiary is found, regardless of whether a full or partial SSN was submitted.”

Some important points related to the technical details of this change are defined in the alert as follows:

  • Query Input File (Field 6 – SSN) – To report a partial SSN, fill the first 4 positions with spaces, followed by the last 5 digits of the SSN.
  • Query Response File (Field 6 – SSN) – If the RRE submitted an SSN on the Query Input File, the value returned on the response file will be the same value that was submitted (i.e., either the partial 5-digit SSN or full 9-digit SSN).
  • Query Response File (Field 8 – Disposition Code) – A new Disposition Code “DP” has been added as a value for this field. Disposition Code “DP” will be returned if multiple Medicare beneficiary records were identified based upon the partial SSN and data submitted on the Query Input File.
  • Claim Input File (Field 5 – Injured Party SSN) – To report a partial SSN, fill the first 4 positions with spaces, followed by the last 5 digits of the SSN.
  • Claim Response File (Field 5 – Submitted Injured Party SSN) – If the RRE submitted an SSN on the Claim Input File, the value returned on the response file will be the same value that was submitted (i.e. either the partial 5-digit SSN or full 9-digit SSN).
  • Claim Response File (Field 27 – Applied Disposition Code) – A new Disposition Code “DP” has been added as a value for this field. Disposition Code “DP” will be returned if multiple Medicare beneficiary records were identified based upon the partial SSN and data submitted on the Claim Input File.

The alert also notes that a new version of HEW (HIPAA Eligibility Wrapper) software, version 3.1.0, will be available on January 5, 2014, and that entities using their own X12 translator will need to obtain the revised X12 270/271 companion guide to accommodate revisions to the query input and response files.

For Helios clients, the technical changes encompassed in this alert will be handled almost entirely within MedicareConnect. All input paths for MedicareConnect, whether through file feed or manual input, allow for partial SSNs within the claim record. We encourage our clients and data sources to contact us directly with any specific concerns and to participate in the recently announced Town Hall conference call.

Of particular note to processes specific to our RRE, carrier and TPA clients, CMS has modified the model language for the collection of the SSN with wording to indicate that the last five digits may be provided if the claimant is uncomfortable providing the whole SSN. The revised model language may be obtained here.

For more information, please contact Frank Fairchok, Senior Manager of MedicareConnect at Frank.Fairchok@helioscomp.com.

CMS Announces Town Hall Conference for NGHP Section 111

Frank FairchokCMS has announced a Town Hall teleconference event for Non-Group Health Plans scheduled for December 10, 2014 from 1:00 PM to 3:00 PM Eastern time. This call will discuss both policy and technical details for Section 111 reporting, including the following topics:

  • Reporting Partial Social Security Numbers
  • Response File Naming Convention Change
  • Multi Factor Authentication for the MSPRP

The call in number for the event is (800) 837-1935 with a pass code of “Section 111.” Participants are encouraged to submit questions as soon as possible to the following e-mail address: PL110-173SEC111-comments@cms.hhs.gov

Helios will participate in the call and provide our clients with a summary of the discussion points shortly thereafter.

This announcement can be found here (PDF File).

For more information, please contact Frank Fairchok, Senior Manager of MedicareConnect at Frank.Fairchok@helioscomp.com.

CMS Releases Alert to Add Recovery Agent Fields to TIN File Layout

CMS has released a technical alert dated November 10, 2014 related to changes in the TIN file layout and associated TIN response record that will allow an RRE to include a third party administrator (TPA) as a “recovery agent” in the reporting process. CMS had previously allowed a workaround to allow for TPA addresses in the RRE address fields and provided specific guidance to how that data should be submitted.

This alert modifies the workaround process by adding recovery agent name and address fields to the TIN file layout. Corresponding fields have also been added to the TIN response layout and error codes have been created to communicate issues with data submitted in the new fields.

Some important points related to this change are defined as follows in the alert:

  • The submission of recovery agent information will remain optional, and the current workaround for submission of a “Third Party Administrator (TPA) Address” should no longer be used. RREs are encouraged to use the new reporting methodology as both the RRE and recovery agent will be copied on recovery correspondence.
  • These fields should not be used to submit information for a reporting agent who only assists the RRE with their Claim Input File submissions. These fields should only be used to provide the name and address for an agent assisting the RRE with the recovery process.
  • If Recovery Agent Information is included on the RRE’s submission, all recovery correspondence associated with Section 111 claim reports with the same RRE ID, TIN and Office Code/Site ID combination as that submitted on the matching TIN Reference File Record will be issued to the RRE using the address provided and a copy shall be sent to the Recovery Agent using the address provided in the new fields.
  • If Recovery Agent Information is not included on the RRE’s submission, all recovery correspondence associated with Section 111 claim reports with the same RRE ID, TIN and Office Code/Site ID combination as that submitted on the matching TIN Reference File Record will be issued to the RRE using the address provided.
  • For purposes of MMSEA Section 111 NGHP submission of Recovery Agent information only, CMS will utilize the designation of an agent and submission of that agent’s name and address on the TIN Reference File/DDE Submission, as an authorization by the RRE for the agent to resolve any recovery correspondence related to claim submissions with a matching RRE ID, TIN and Office Code/Site ID combination. CMS will consider the RRE bound by the agent’s actions on such matters. The RRE still retains ultimate responsibility for adhering to Section 111 mandatory reporting requirements and all other MSP obligations and requirements.
  • RREs are advised to submit updated TIN Reference File Records after the implementation of the new Recovery Agent fields in July 2015 in order to replace records previously submitted using the “TPA workaround.”

CMS has scheduled this change to be effective in production on July 13, 2015.

Helios believes this change will enhance our capability to provide seamless MSP compliance solutions to our clients, and we will be providing further updates to clients and Section 111 data sources as modifications to MedicareConnect are developed to support this alert.

This alert can be found at the following address: http://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Mandatory-Insurer-Reporting-For-Non-Group-Health-Plans/Downloads/New-Downloads/Technical-Alert-Option-for-RREs-to-Submit-Recovery-Agent-Information-for-MSP-Recovery-Related-Correspondence-.pdf

For more information, please contact Frank Fairchok, Senior Manager of MedicareConnect at Frank.Fairchok@helioscomp.com.

CMS Releases Alert for Changes to Response File Naming Convention

CMS has released an alert dated October 27, 2014 detailing changes to the naming convention for claim, TIN and query response files that will take effect April 6, 2015. In order to ensure that filenames remain unique, CMS is modifying the time, or “T,” node of the filename convention. Instead of four digits representing seconds and centiseconds, a number from 0000 to 9999 will be inserted in the filename.

CMS had recently enabled this change in their production systems and it was detected by the Helios Section 111 reporting platform, MedicareConnect. After Helios brought the matter to CMS’s attention, and reminding them that the response file specification was published in the User Guide, CMS agreed to revert back to the previous coding and publish an alert to provide the normal six months of advance notice.

The full alert can be found at the following address: http://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Mandatory-Insurer-Reporting-For-Non-Group-Health-Plans/Downloads/New-Downloads/Response-File-Naming-Convention-for-Liability-Insurance.pdf

For more information, please contact Frank Fairchok, Senior Manager of MedicareConnect at Frank.Fairchok@Helioscomp.com.