Tag Archives: SSN

Modification of Query Matching Criteria for Partial SSNs

Post by Frank Fairchok MedicareConnect℠ Senior Manager

Post by
Frank Fairchok
MedicareConnect℠ Senior Manager

CMS has released an alert to notify all users that they have modified the matching criteria for queries where the full Social Security Number could not be obtained and a five-digit SSN was provided. This change, which is effective immediately, fixes an issue where false beneficiary matches were made when the partial SSN and only three of the other four query fields were matched with the existing full SSN logic. CMS will now utilize the partial SSN and the other four query elements as detailed here:

  • First initial of the first name
  • First 6 characters of the last name
  • Date of birth (DOB)
  • Gender

Per CMS, when an exact match on the partial SSN is found, then all of the other four remaining data elements must be matched to the individual exactly. However the matching criteria for HICNs and full SSNs will remain the same.

It is important to note that CMS encourages RREs to submit the HICN or full SSN when it is available to ensure the most accurate match is obtained. CMS reminds RREs in this alert that failure to match to a Medicare beneficiary with the full or partial SSN does not negate the RRE’s Section 111 mandatory reporting requirement when a reportable claim exists.

This alert, dated and released on June 18, 2015, can be found at the following address: https://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Mandatory-Insurer-Reporting-For-Non-Group-Health-Plans/Downloads/New-Downloads/Technical-Alert-Modification-of-Matching-Criteria-Used-When-Reporting-Partial-Social-Security-Numbers-for-Liability-Insurance.pdf

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

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 Issues Alert Regarding Change in Reporting SSNs/HICNs Pursuant to the SMART Act

Just yesterday, September 10, 2014, CMS issued an alert which modifies the requirements relating to the reporting of HICNs and SSNs by NGHP RREs. The alert can be found here.

Pursuant to the SMART Act, CMS was required to do the following: “not later than 18 months after the date of enactment of this bill, the Secretary of HHS shall permit but not require to access or report the beneficiary’s social security account numbers or health identification claim numbers.”

As a result, CMS has issued this alert which provides that effective January 5, 2015, where an NGHP RRE cannot obtain an individual’s HICN or full SSN, RREs may report the following data elements that will enable CMS to properly identify a Medicare beneficiary: 1) last five digits of SSN, 2) first initial, 3) surname, 4) date of birth, and 5) gender.

If NGHP RREs are unable to obtain or do not provide the HICN, full SSN, or any of the above listed data elements, they must document their attempts to obtain this information (RREs may use the model language provided by CMS located in the Downloads section of the MIR for NGHP page at http://go.cms.gov/mirnghp).

CMS states within the alert that a subsequent alert will be published prior to the January 5, 2015 implementation, which will include additional instructions for entry of the partial SSN into the Claim Input File or Query Input File.

While Helios Settlement Solutions applauds CMS for taking action on this requirement of the SMART Act, some questions remain:

1) Within the alert, CMS states that they currently highly recommend, but do not require, that NGHP RREs submit the HICN or full SSN as part of their reports. However, CMS does currently require the HICN/full SSN to obtain a match in their system when reporting, so this statement seems to contradict current requirements. We assume that this is a scrivener error and that CMS meant to say that full SSNs/HICNs will be recommended but not required come January 5, 2015.

2) While it is helpful that an RRE will no longer have to obtain a full SSN come January 5, 2015, it is unclear that if a claimant is unwilling to provide a full SSN, whether they would then be willing to still provide the last 5 digits of the SSN. On a good note, however, and as mentioned above, if the RRE still cannot obtain the last 5 digits of the SSN, the RRE can document its attempts to obtain this information.

Helios will keep our subscribers updated on any additional developments. For questions, please contact asktheexperts@medicareinsights.com.

CMS to Extend Deadline for Reporting SSNs?

Pursuant to section 204 of the SMART Act, within 18 months of the enactment of the SMART Act (which is July 10, 2014), CMS was required to modify MMSEA Section 111 Reporting Requirements so that an RRE was no longer required to report social security numbers (SSNs) or health insurance  claim numbers (HICNs).  However, within section 204, CMS was provided with the ability to extend this deadline for 1 year periods if the Secretary notifies Congress that without the extension, it would threaten patient privacy or the integrity of the Medicare Secondary Payer (MSP) program.

Now that July 10th has came and CMS has not implemented this change, it is expected that CMS will soon file for the 1 year extension; however, we remain hopeful that CMS will soon implement this provision of the SMART Act.

In the meantime, RREs that are unable to obtain a beneficiary’s SSN have a few options to remain compliant. CMS has provided the industry with a method to document and demonstrate good faith efforts to obtain SSNs from Medicare beneficiaries through the use of a form that has model language created by CMS to request the information required for reporting under MMSEA Section 111. This document can be found here.

Additionally, there is case law precedent in which a carrier refused to tender a settlement due to the beneficiary not providing their SSN (See Seger v. Tank Connection, LLC and Hackley v. Garofano). In these cases, the courts sided with the RREs and required the beneficiaries to provide their SSN so that the RRE could be in compliance with the MMSEA and not subject to fines.

Therefore, if needed, RREs can document their good faith efforts to obtain SSNs and/or bring the matter to court if the beneficiary refuses to provide their SSN. We will keep our subscribers updated on any developments on the SMART Act and any filings by CMS with respect to this particular provision.