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Regulatory Compliance – MBI and what it means to HIT

February 13, 2017
From the January 2017 issue of HealthCare Business News magazine

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.

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