In this episode, Vinny Farina, Senior Manager in the Revenue Cycle team at BESLER, discusses the background of the Social Security Number Removal Initiative (SSNRI) and what hospitals should be doing now to prepare for this paradigm shift.
A paradigm shift is defined as a fundamental change in approach. The Centers for Medicare & Medicaid Services (CMS) has started a fundamental change that will significantly challenge all providers (hospitals, ancillaries, physicians, suppliers, etc.) and departments dealing with Medicare patients. Starting in January 2018, the Social Security Number Removal Initiative (SSNRI) will begin, revolutionize and alter the way that the Medicare eligibility process has been conducted.
Many questions will arise which at this point there are no answers for. This summary is designed to provide initial information about SSNRI and to encourage the provider community to start the process of planning for this change so that its Medicare revenue is not impacted.
The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 mandates the removal of the Social Security Number (SSN) based Health Insurance Claim Number (HICN) from Medicare cards. The SSNRI Program evolved from MACRA. The goal of SSNRI is to decrease Medicare beneficiaries’ vulnerability to identify theft by removing the SSN-based HICN from Medicare identification cards.
The HICN will be replaced with a new Medicare Beneficiary Identifier (MBI) which will not contain any SSN or patient personal information. The MBI will be unique for each individual and have the same number of characters as the current HICN (11). However, there will be absolutely no patient identifier in the MBI.
Removing SSNs might not prevent a healthcare data breach from occurring, but should a Medicare beneficiary lose their Medicare card it will ensure that SSNs will not as easily fall into unauthorized hands.
The extent of this change impacts CMS, ninety different stakeholder entities/groups, 1.5 million providers and over seventy-five systems. Most impacted are the sixty million Medicare recipients who are as critical to this process as any of the stakeholders involved. The provider community will need to interface with and collect the necessary MBI information during the eligibility process from these individuals.
There is some flexibility during the transitional period for the provider community and impacted stakeholders. The HICN or MBI will be accepted through December 31, 2019. However, CMS’ process will be designed to return a MBI on the remittance advice starting in October 2018 if the HICN was reported.
Although the HICN can be reported, steps must be in place to start capturing and reporting the MBI during the transitional period especially since it will be returned. That’s a perfect opportunity to proactively capture and record data that will be essential moving forward. Once the MBI is identified, the intent should be to start using that as the sole means to submit patient information. It is important to note that all Medicare claims submitted after January 2020 will be required to use the MBI. Those claims filed with the patient’s HICN will be rejected.
Impacted stakeholders must start taking steps to prepare for and manage the critical SSNRI transition period which begins in April 2018.
There are two critical areas that will need to be at the forefront of planning for this transition. The first is assessing and documenting the current operational processes in place for collecting, recording, capturing and confirming Medicare eligibility. The second step is understanding and evaluating how interactions with Medicare beneficiaries are handled.
Operational processes and patient interactions will provide needed insights that will help facilitate changes during the transition period.
Steps to follow could be:
- Selecting the project sponsor that will authorize and approve an internal SSNRI redesign project with an individual spearheading the initiative.
- Initiating a project charter and clearly defining the objectives and goals of the SSNRI initiative in your organization.
- Identifying the key stakeholders within the organization that will be most impacted and can contribute to the project.
- Planning and creating the management plan that will be the guide for all personnel to follow.
- Developing new policies and procedures, specifically, what occurs when a Medicare patient does not present with a new MBI.
- Determining system implications, to include all provider entities. The MBI will be clearly different than the HICN. Communicating internally and creating an outreach program to educate the stakeholders especially the Medicare recipients.
- Establishing the process group that will direct and manage the project and its execution while also taking into account the quality assurance aspect of the process changes.
- Having a monitoring and control plan to make sure that the required process changes and improvements are within the timeline dictated by CMS transition period.
- Adding KPI metrics to monitor claim processing delays if they occur and or financial impact when a Medicare beneficiary presents without an MBI.
- Closing out the internal project with an understanding of how things were improved, changed, adjusted modified.
- Using the lesson learned and information gathered during the transition period to further enhance other areas in the operation.
There is absolutely no way around the upcoming change. It will be monumental and a paradigm shift because SSNRI clearly alters the way that the Medicare provider community and its entities have handled patient identification information in the past.
There is ample time to start preparing a well thought out plan and modifying business processes to ensure a smooth transition. Seamless movement to this new standard will ensure that providers protect their Medicare revenue while delivering the best possible experience to their patients and employees.