Removing patients' Social Security numbers from their Medicare ID cards is needed to protect their privacy, TMA and other medical societies say, but the way it's being handled will cause unnecessary confusion and delays in care.
In a letter to the Centers for Medicare & Medicaid Services (CMS), TMA, the American Medical Association, and other organizations also complained that CMS is implementing the change without valuable feedback from physicians and providers.
The Social Security Number Removal Initiative (SSNRI) is part of the Medicare Access and CHIP Reauthorization Act (MACRA) and requires CMS to remove the Social Security number from Medicare cards out of concerns over identity theft.
"In an age of increased identity theft and fraud, the Medicare patient population deserves the improved security that will be achieved with the SSNRI," the letter said. "This protection should not, however, come at the expense of prompt patient care or provider payment."
Currently, Medicare patients are identified by a health insurance claim number (HICN) that is based on their Social Security number. Under the SSNRI, that number will be replaced by Medicare beneficiary identifiers (MBIs). New identification cards will be sent out in phases over 12 months beginning in April 2018, with outreach and education beginning in January.
Although CMS will accept both HICNs and MBIs during the transition period — from April 1, 2018, to Dec. 31, 2019 — physicians' and providers' systems must be ready to accept the MBI by April 2018 and must use the MBI exclusively starting Jan. 1, 2020.
"We are concerned about a provider’s inability to access a patient's MBI both during and following the transition," the letter says. "If a patient does not bring his or her MBI to his or her appointment [after Jan. 1, 2020], significant delays in patient care or provider reimbursement could result due to the lack of a mechanism for the provider to look-up the patient’s MBI."
The organizations are calling for a contingency system that will allow medical practices to obtain the MBI of a patient who arrives at an appointment without a card. The providers have offered a range of possible solutions, including look-up databases, providing MBIs in electronic eligibility responses, and secure phone systems.
The organizations also have taken issue with being left out of discussions on implementing the change, which CMS has characterized as being "operational in nature," according to the letter.
"We respectfully note that this change will impact all Medicare beneficiaries and that all systems and business processes will need to be able to accept and process the new MBI," the organizations said. "We therefore urge CMS to work with stakeholders to avoid significant problems and again recommend that CMS instead pursue this change through the traditional notice and comment rulemaking process."
Action, May 15, 2017