Risk Adjustment

MRA Organizations and the SSNRI

The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, among many changes, mandated that CMS remove beneficiaries’ social security numbers from usage as part of their Medicare beneficiary identification numbers by April 2019.  Medicare Risk Adjustment (MRA) organizations know this number as the Health Insurance Claim Number, or HICN.  It has long been a standard element of data submission to the Risk Adjustment Processing System (RAPS) and Encounter Data Processing System (EDPS), serving as the unique patient identifier upon which all diagnostic data is indexed.  The modification of this system of identifiers has been monikered the Social Security Number Removal Initiative (SSNRI) by CMS.

The HICN today is generally formed from the social security number of one beneficiary, with one or two trailing characters.  For many patients, this number consisted of their own social security number followed by the letter A.  The spouse, child, or divorced spouse of the primary beneficiary might have the primary beneficiary’s SSN followed by a B, C1 (C2, etc.), or D1 (D2, etc.).  Lastly, railroad retirees have a unique number formed instead by a preceding letter or letters, followed by the SSN.

Regardless of the specific form, this common public usage of the social security number has long been considered a privacy risk and an invitation to theft of Medicare beneficiaries’ identifying information.   For this reason, all HICNs will be changed to a new Medicare Beneficiary Identifier (MBI).  A transition period will run from April 1, 2018 through December 31, 2019, during which both numbers can be utilized, according to CMS (https://www.cms.gov/medicare/ssnri/index.html).   The MBI will be eleven characters in length, like the majority of current HICNs, but will be completely unrelated to the patient’s social security number.  The MBI will contain only numbers and upper-case letters, like the current HICN.

MRA organizations will need to prepare for this change.  In particular, both the HICN and MBI may need to be stored and/or cross-referenced in order to correctly index and correlate past patient data with newer information.  As year-over-year diagnostic information is a key data point for MRA organizations, preserving the ability to make these correlations across and beyond the transition period will be an important step.  The new MBI will be required, beginning in 2020, on risk adjustment data submissions to CMS.


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