Crystal Ewing

Regulatory Compliance – MBI and what it means to HIT

February 13, 2017
By Crystal Ewing

With identity theft on the rise, especially among the vulnerable elderly population, the Centers for Medicare and Medicaid Services (CMS) recently announced plans for an important change to the Medicare program. It replaces the current health insurance claim number (HICN) on Medicare cards with a new Medicare beneficiary identification (MBI) code as dictated by the Medicare Access and CHIP Reauthorization Act (MACRA). The current HICN violates every best practice by using a member’s Social Security number plus a couple of additional characters to create the ID. Which means a lost or stolen Medicare card could become a window into that member’s medical and financial information.

Yet making the change is no small task, since it affects 60 million active Medicare beneficiaries as well as 90 million who are deceased/archived, but whose records are still at risk. That’s a problem for providers and health IT professionals because while CMS has been very specific on the “what” and “when,” it has been less so regarding the “how.” The ambiguity adds to the challenge, especially considering the transition period is scheduled to begin in April 2018 and conclude Dec. 31, 2019. The following are some of the key considerations.

How the new MBI will be obtained.
This is the one most likely to keep providers and their HIT teams up at night. With the HICN, providers can retrieve information from an eligibility-verification transaction if beneficiaries don’t bring their cards to the office visit. That will not be the case with MBIs. Providers are being told to obtain them directly from patients by asking for their new Medicare cards. CMS won’t be sending the MBIs straight to providers out of concerns for identity theft. If beneficiaries
don’t bring their Medicare cards, or don’t know their MBI, the only way to update their records is after the fact — referring to the new MBI by checking the remittance advice.

This seems convoluted since it will create delays in updating the information, and extra work. It will also make the MBI easy to miss since the timing doesn’t match normal workflows. A better approach would be for the new number to be provided during the eligibility verification process. That is when providers are closely examining the eligibility document to ensure the patient has the proper coverage for the services about to be rendered, and validating the type of coverage as well as the payer. This second option is what many in the industry are advocating.

It won’t matter much during the transition period, as CMS says it will pay on either. But once the deadline passes in 2019, using the HICN could result in a denial or delayed payment until the claim is updated with the MBI. Regardless, HIT must be prepared to help providers make the transition as quickly as possible to minimize avoidable denials.

Card distribution. Another uncertainty is how the new Medicare cards will be distributed. Providers need this information so they know when to ask patients (or their caregivers) for the cards. Distribution could occur all at once, in waves, by geography, jurisdiction and so forth. CMS does say it will alert providers to ask for the new card in the message field as part of the eligibility process once they have been mailed. Still, why not just send the new MBI then?

New Medicare beneficiary applicants. According to CMS, once the rollout begins new members will only be assigned an MBI. But what about those who apply before April 1, 2018, but are approved afterward? The possibility of a phased rollout leaves a gray area regarding whether those members will receive an HICN that must be changed to an MBI shortly afterward. There are also concerns about how Medicare Advantage plans will be affected.

Final deadline. What if, even demonstrating the best of intentions, some providers aren’t ready by the Dec. 31, 2019, deadline? Will they have at least a bare bones workaround option, or will they simply be unable to file Medicare claims, period?

Readiness checklist
Despite these concerns, CMS remains committed to the April 2018 start date. Providers must be ready to accept MBIs by then. Here is a partial checklist of considerations HIT can use to ensure the organization is prepared:

• How much time is needed to have systems ready for the new cards?
• What software development, infrastructure and business logic/workflow changes are needed?
• What is the magnitude and time needed to map the process through its entire life cycle?
• How much will all of this cost?
• Will the system be functional and able to accept dual processing of HICNs and MBIs?
• What editing will be involved to ensure the system adjusts accurately and quickly?
• Will distributing new cards to Medicare patients gradually be better for the system’s capacity versus all at once?
• Will the system be able to accommodate both the card number change and the volume of card number changes?
• How will this change impact revenue integrity?

Moving forward
While there are still key decisions to be made, the time to begin moving forward is now. The sooner providers and health care IT teams can prepare the organization for the transition to MBI, the less disruptive it will be — 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 health care industry.