New Medicare cards are coming — are you ready?
Cracking the Code
Dr. Miller, who is in private practice in Yorba Linda, California, represents the American Academy of Dermatology on the AMA-CPT Advisory Committee.
By Alexander Miller, MD, February 1, 2018
Over the years we as citizens have been admonished to keep our Social Security numbers (SSNs) secure, secreted, carefully guarded, and our Social Security card segregated from our purses or wallets. “Best to lock it up and not carry it about,” we were advised, so as to avoid allowing escape of that precious personal identifier into a conniving identity theft world. Be suspicious, cautious, never divulge your Social Security numbers to anyone or any entity, especially via the internet, unless clearly necessary and safe to do so.
That is still the mantra. Astoundingly, despite near-hysterical warnings about nefarious connivers ready to exploit our Social Security numbers should they surface linked to our names, those of us enrolled in Medicare receive a Medicare Health Insurance card, which we are advised to carry with us in case we need medical care. The card is presented to medical care facilities, including our dermatology offices, to validate enrollment in the Medicare program and to facilitate billing for our services. The card features a Medicare Health Insurance Claim Number (HICN) which identifies the patient as a Medicare beneficiary and must be used to bill all claims.
What is this claim number that everyone on Medicare carries with them? Why, it’s our Social Security identifier followed by a letter. The Social Security number on the card is usually one’s own, but may be the spouse’s, if both are retired and receiving Social Security benefits. In such cases the primary wage earner upon whose wages the retirement is based will have his/her Social Security number imprinted on both spouses’ cards. The capital letter following the Social Security number identifies a benefit category, including whether one is still working or fully retired. Surely, having a capital letter following one’s Social Security number, or having one’s spouse’s number on the Medicare card, effectively disorients potential miscreants, creating an effective layer of security!
Finally, the numbers will change. The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, among all the things that it stipulated, directed the removal of SSNs from Medicare cards by April 2019. Responding to this sharp stake prod, the Centers for Medicare and Medicaid Services (CMS) announced a Social Security Number Removal Initiative. This is no small venture, as 57 million enrollees’ Medicare identifiers will need to be changed, fed into the system, correlated with the current card numbers, and then distributed to the individual enrollees. Consequently, CMS plans a gradual transition starting in April 2018.
What will happen? Individual Medicare beneficiaries will begin receiving new identifier cards in the mail, at no cost to the beneficiary, starting in April of 2018. Statute directs that the transition is to be completed by April of 2019. The new identifiers will feature an 11-character alphanumeric, randomly generated Medicare number. During the one-year transition phase both the original Medicare number and the new number may be used for identifying eligibility for Medicare and for billing for services.
What does this all mean to you, the care provider? Your practice management software, billers, outsourced billing companies, and billing clearinghouses will need to be prepared to accept and transmit the new number, called a Medicare Beneficiary Identifier (MBI). You/your staff should ensure that your practice management software will be capable of processing both the old and the new Medicare numbers by April of 2018. Keep in mind that patients new to Medicare will be arriving with only the new Medicare Beneficiary Identifier. Your system will need to be able to handle it. All steps in billing and in receiving adjudications from the MAC should be verified as functioning.

Steps to ensure a smooth transition:
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Verify that your practice management software will be adjusted to accept both the old and the new Medicare Beneficiary Identifier numbers by April 2018.
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Verify that your clearinghouse will properly transmit transactions with the new MBI.
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Alert your staff to the changes.
What could go wrong? Lots. Let’s start with the mailing of the new Medicare cards. They will be sent to the beneficiaries’ addresses of record with CMS. If such an address is incorrect, then the card may not arrive to its designated recipient. Two things may then happen: the patient will suddenly have an invalid Medicare card after April 2019, and your office would have no way of effectively billing for the services provided after 2019. Or, someone else may receive the card. Depending upon their degree of social adjustment, they may or may not be tempted to exploit this arrival in misdirected ways. How can you deal with this proactively?
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Have staff notify the patient if an address mismatch is noted between the address in your file and any you receive in electronic eligibility transactions.
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Starting in March of 2019, patients coming in with old Medicare numbers should be notified to contact Social Security to ensure arrival of a new card.
What else could happen? Consider that every step of the transaction and payment route may suffer snafus. This includes claims crossovers to secondary insurers. Your billing staff should remain vigilant to ensure that claims are submitted with proper identifiers and that they are adjudicated appropriately. Systems should be in place to identify unadjudicated claims, so that they may be resubmitted and/or any associated problem(s) rectified.
Example 1: Three patients present new Medicare cards. Although all three have 11-character alphanumeric MBIs, your staff notices that one of the cards has a number where the other two had a letter in the 11-character series. Your staff advises the outlier patient to check identifier correctness with Social Security.
Answer: Incorrect. Unlike on previous cards, no character on the new MBI will have any specific significance. Furthermore, the randomly generated alphanumeric identifiers will not all have exclusively numbers or letters in each of the 11 character positions. Some may be numbers, some letters, and some, either numbers or letters. Looking at the identifier from left to right, assign a position of 1-11 to each of the identifier characters. You will find that positions 1, 4, 7, 10 and 11 will have numbers only. Positions 2, 5, 8 and 9 will have letters only. Positions 3 and 6 will feature either numbers or letters.
Example 2: A properly identified claim featuring the new MBI was sent to the MAC. It was not paid, as the patient was not enrolled in the traditional Medicare program. What happened?
Answer: Possibly, the patient has Railroad Retirement Board Medicare. Previous to the MBI this enrollment would be identified via the patient’s card number. However, the MBI will be equally random for all, such that one will not be able to distinguish Railroad Medicare from the MBI number. Railroad Medicare insured individuals’ cards will have an RRB logo imprinted on their card. Your staff will need to stay alert to this subtlety.
Example 3: In June of 2019 staff inadvertently submit an established Medicare patient’s claim with the old, Social Security number identifier (also called HICN). As there is a grace transition period for billing with the new MBIs, no action is needed.
Answer: Correct. There will be a billing transition period through Dec. 31, 2019. During this time one may use either the Social Security number-based identifier (HICN) or the MBI for billings and appeals. However, it will be best to establish all transactions using the MBI as soon as it is available for a patient, as it will facilitate a smoother transition for both your staff and the MACs.
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