Avoiding The Potholes In The Road To MBI

By Crystal Ewing, Manager of Data Integrity, ZirMed

One of the positive changes brought on by the Medicare Access and CHIP Reauthorization Act (MACRA) is replacing the current Health Insurance Claim Number (HICN) on Medicare cards with a new Medicare Beneficiary Identification (MBI) code.

This change is being made for the best of intentions. The current HICN uses a member’s Social Security Number, plus a couple of additional characters, to generate the Medicare ID numbers. Replacing them with a randomly generated combination of letters and numbers helps protect the vulnerable, elderly population from medical and financial fraud. This will affect 60 million Medicare beneficiaries who are currently active, along with another 90 million who are deceased/archived (and whose records are still at risk).

While the Centers for Medicare and Medicaid Services (CMS) has been very specific in saying what it wants to do and when it wants to do it, it has been far less specific in saying how. That means the road to MBI likely won’t be smooth; there will be some potholes along the way. And with only 20 months between the start of the transition period (April 2018) and the end (December 31, 2019 — so far), it’s important for providers to begin planning for the MBI conversion today.

Obtaining The New Number

The greatest uncertainty for providers is how to obtain the new MBI. Under the current HICN system, if beneficiaries don’t bring their Medicare cards with them, providers can retrieve the information from an eligibility-verification transaction.

That is not the way the MBI will work. CMS has advised it will not be sending MBIs directly to providers so records can be updated in order to protect against identity theft. Providers are being told instead to obtain the information directly from patients by asking for their new Medicare cards.

But what if they lose their cards or leave them at home? At that point, the only way to update the MBI is when the provider receives the remittance advice. This is a less-than-ideal approach since it will unnecessarily delay updates to the information, and the information can be easily missed.

A better method is for records to be updated during the eligibility verification process. Providers will be examining the eligibility document closely to ensure the patient has the proper coverage for the services about to be rendered, and to validate the type of coverage as well as the payer. Including the new MBI here fits very well into this workflow. This is what many in the industry are pushing for.

It isn’t much of an issue during the transition period, as providers will be able to file using both the HICN and MBI, much as they did with ICD codes during the move to ICD-10. CMS has said it will pay on either. Once the December 2019 deadline passes, however, using the HICN could result in a denial or a delay in payment until it the claim is updated with the MBI.

Clearly, it is critical for providers to begin using the MBI for that beneficiary as soon as it becomes available. If CMS waits until the remittance advice to provide it, the entire process will be made exponentially more difficult.

Concerns Abound

When the MBI should be returned is not the only concern surrounding the transition to MBIs. Another revolves around how updated Medicare cards will be distributed so providers know to ask patients or their caregivers for them. We don’t know if they will be rolled out all at once, in waves, by geography, jurisdiction, etc. CMS says it will notify providers it has mailed a new Medicare card in the message field as part of the eligibility verification process to alert providers to ask for them. Again, the better solution would be to include the MBI itself.

What will happen with new Medicare beneficiary applicants is another concern. CMS says once the rollout begins, new members will only be assigned an MBI. So if a member applies before April 1, 2018 but is approved after that date there is a gray area as to which type of identification he/she will receive — dependent completely on the rollout date. There are also concerns about how Medicare Advantage plans will be affected through all of this.

Finally, with any program this large there is the question of whether the December 2019 deadline will remain firm or if there will be an extension as happened with past initiatives.        

Getting Ready

Regardless of the final end-date, from a technical and IT systems point of view, CMS says providers must be ready to accept MBIs by April 2018. This is the deadline providers should use as they make their health IT plans. Among the questions providers should ask their vendors to ensure they are prepared are:

• How much time will be needed to have my systems ready for the new cards?
• What software development and infrastructure changes are needed, and what business logic/workflows need to change?
• What is the magnitude and time needed to map the process through its entire lifecycle?
• How much will all of this cost?
• Will my system be functional and able to accept dual processing of HICN and MBI?
• What editing will be involved to ensure the system adjusts accurately and quickly?
• If new cards are distributed to my Medicare patients gradually, will that be better for my system’s capacity v if they are all distributed at once?
• Will my system be able to accommodate both the card number change and the volume of card number changes?
• How will this change impact my revenue integrity?

Obtaining answers to these questions will help ensure providers avoid potential potholes no matter how the program is ultimately structured.

The Road Ahead

While the way forward is murky, the destination is clear. Providers will be best-served by ensuring they do all they can to prepare for the MBI transition no matter what form it ultimately takes.

About The Author
Crystal Ewing is ZirMed’s Manager of Data Integrity. She has over 19 years of experience in the healthcare industry, and brings a blend of business and technical expertise to her current role where she focuses on revenue cycle as well as population health data integrity solution development and compliance. She can be reached at crystal.ewing@zirmed.com.