In less than 45 days, the long-awaited CMS transition to the new Medicare Beneficiary Identifier (MBI) will be effective. As of January 1, 2020, the transition period will end and all claims, regardless of the date of service must include the new MBI. Claims containing the outdated Health Insurance Claim Number (HICN) will be denied and no payment will be received.

So, what does this mean for you and your organization? Below we’ve outlined what you can (and should) do next.

Background
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) required CMS to remove Social Security Numbers (SSN) from all Medicare cards by April 2019. CMS replaced the SSN-based HICN with a new, randomly generated MBI, which is noticeably different than the HICN. Just like with the HICN, the MBI hyphens on beneficiary cards are for illustration purposes and don’t need to be included on transactions. The MBI uses numbers 0-9 and all uppercase letters except for S, L, O, I, B, and Z.

What should we do to make sure we are ready?
During the transition period, providers have had the opportunity to use MBI numbers for newly admitted residents and to get and use MBI numbers for current residents. Updated cards were mailed to all Medicare beneficiaries and remittance advices have included the HICN and MBI for many months. If your admissions and billing departments have not yet begun using MBI numbers, it is essential that they now obtain and enter the MBI numbers in your EMR/billing system for all residents that will have claims submitted on or after January 1, 2020.

How can we get the new MBI?
Follow these steps:

  • Ask residents/families for a copy of the new card
  • Review previously received remittance advices to obtain the MBI
  • Access the NGS MBI look up tool at: connex.ngsmedicare.com
  • For dual eligible residents: check the ePACES eligibility screen
  • For Medicare Advantage residents: check payer websites to see if they have the MBI on file

What if claims don’t include the MBI?
After January 1, 2020, claims submitted with HICNs (with a few exceptions) will be rejected. Electronic claim rejection codes will include: Claims Status Category Code of A7 (acknowledgment rejected for invalid information), a Claims Status Code of 164 (entity’s contract/member number), and an Entity Code of IL (subscriber).

Paper claim rejections will include: Claim Adjustment Reason Code (CARC) 16 “Claim/service lacks information or has submission/billing error(s)” and Remittance Advice Remark Code (RARC) N382 “Missing/incomplete/invalid patient.”

What are the exceptions?
There are a few exceptions to keep in mind:

  • Appeals: You can use either HICNs or MBIs for claim appeals and related forms.
  • Claim status query: You can use the HICN or MBI to check the status of a claim (276 transactions) if the earliest date of service on the claim is before January 1, 2020. If you are checking the status of a claim with a date of service on or after January 1, 2020, you must use the MBI.
  • Span-date claims: You can use HICNs or MBIs for 11X-Inpatient Hospital, 32X- Home Health (home health claims and Request for Anticipated Payments [RAPs]) and 41X-Religious Non-Medical Health Care Institution claims if the “From Date” is before the end of the transition period (December 31, 2019). If a patient starts getting services in an inpatient hospital, home health, or religious non-medical health care institution before December 31, 2019, but stops getting those services after December 31, 2019, you may submit a claim using either the HICN or the MBI, even if you submit it after December 31, 2019. Since you submit home health claims for a 60-day payment episode, you can send in the episode’s RAP with either the HICN or the MBI, but after the transition period ends on December 31, 2019, you have to use the MBI when you send in the final claim that goes with it.

Don’t hesitate to reach out to our experts to learn more about the critical things to be aware of ahead of the CMS transition.

This material has been prepared for general, informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. Should you require any such advice, please contact us directly. The information contained herein does not create, and your review or use of the information does not constitute, an accountant-client relationship.


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