Identifiers To Be Stricken From Medicare Standard Paper Remit
The use of Social Security Numbers (SSNs) for identification and record-keeping purposes is an outdated practice, and it will soon be a violation on the Standard Paper Remit (SPR) generated by Medicare Administrative Contractors (MACs).
The Centers for Medicare & Medicaid Services (CMS) has instructed MACs, in CR 11289, to update the SPR to ensure that no SPR is mailed out after Oct. 7, 2019, with a Medicare beneficiary’s Health Insurance Claim Number (HICN) or SSN.
The Social Security Number Fraud Prevention Act of 2017 restricts the use of SSNs on documents sent by mail no later than Sept. 15, 2022.
Is SSN use impermissible by everyone?
The Social Security Number Fraud Prevention Act provides that no agency of the federal government may include SSNs on documents sent by mail unless the head of the agency determines inclusion of the number is necessary.
According to 32 CFR sec 806b.12:
When asking an individual for his or her Social Security Number, always give a Privacy Act Statement that tells the person: The legal authority for requesting it; the uses that will be made of the Social Security Number; and whether providing the Social Security Number is voluntary or mandatory. Do not deny anyone a legal right, benefit, or privilege for refusing to give their Social Security Number unless the law requires disclosure, or a law or regulation adopted before January 1, 1975 required the Social Security Number and the Air Force uses it to verify a person’s identity in a system of records established before that date.
Refer to your state’s law regarding further regulations of SSNs that may be applicable to healthcare providers.
What identifiers will be used in place of the HICN or SSN?
MACs will mask the HICN or SSN on any print file used to create an SPR for mailing by replacing five digits with Xs in the Patient Control Number field or the Patient Account Number field.
MLN Matters MM11289 provides the following examples:
RRB HICN Examples:
Does this regulation affect the Medicare Beneficiary Identifier?
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) required the Centers for Medicare & Medicaid Services (CMS) to replace HICNs with Medicare Beneficiary Identifiers (MBIs) on member identification cards by April 2019. The new cards are in compliance with the law and do not require further modification.
Cornell Law School. https://www.law.cornell.edu/cfr/text/32/806b.12
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