Audit and Compliance



A&C July

The Medicare's Recover Audit Contractor (RA) program continues to ramp up, and both providers and audit contractors are not reporting any major issues with audit requests and responses. One of the main reasons for this is under the new RA, the volume of ADRs is much lower and more tolerable for providers. The contractors are still working their way through historical data from the Centers for Medicare & Medicaid (CMS) and currently focused on DRG coding reviews with a handful of other audit types sprinkled into the mix. We will continue to monitor this rollout and provide updates accordingly.

In this month's message we also want to focus on the conversion of the Medicare Beneficiary Health Insurance Claim Number (HICN) away from Social Security Numbers (SSNs). The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 requires CMS to remove SSNs from all Medicare cards by April 2019. A new Medicare Beneficiary Identifier (MBI) will replace the SSN-based Health Insurance Claim Number on the new Medicare cards for Medicare transactions such as billing, eligibility status, and claim status.

This massive change to the SSN-based HICN number, which has been in place since the inception of the Medicare program in 1966, is a fraud prevention initiative to help combat identity theft and safeguard taxpayer dollars. CMS will begin mailing new cards in April 2018 and will meet the congressional deadline for replacing all Medicare cards by April 2019.

This change will impact all providers. The new MBI will need to be stored in provider's patient master files, replacing the current HICN. Both providers and beneficiaries will be able to use secure look-up tools for quick access to MBIs when needed.

Providers will have a 21-month transition period during which time they will be able to use either the MBI or the HICN, easing the transition on all transactions. State Medicaid programs that historically stored the HICN on dual-eligible Medicaid recipients will also need to convert their systems to the new MBI number.

Providers should start to analyze their internal systems to prepare for the new MBIs. In addition, starting in April 2018, providers should ask Medicare beneficiaries if they have received their new Medicare ID cards.

To prepare, review information on the CMS website and prepare handouts for their patients to help them understand why they are getting new Medicare cards in the mail. Sample cards are on the CMS site. While specific costs for converting to the MBI are not yet known, what is certain is that providers will incur costs. It is advisable to check with your software vendor to determine how much of the cost of including the MBI in the patient data base will be covered under your contract as a mandated governmental upgrade.