CMS finds insurers requests for SSN’s appropriate for Section 111 MMSEA purposes: http://www.cms.gov/MandatoryInsRep/Downloads/RevisedCollectionSSNEINs.pdf
In order for CMS to accurately coordinate payments made by Medicare to ensure appropriate payment, Medicare requires the HICN (Health Insurance Claim Number) or the SSN and the EIN (Employer Identification Number). Medicare has collected this information from beneficiaries since the inception of the Medicare program. This information is used for the administration of the Medicare program, the beneficiaries personal information is protected by the Privacy Act of 1974 and the Health Insurance Portability and Accountability Act Privacy Rule.
CMS’ clarification of the appropriateness of request/release of this information arises from overwhelming concerns of the plaintiff and plaintiff attorneys. What will the defense do with this information once it has been provided? Section 111 requires the SSN if the HICN is unavailable if the insurers are unable to report to the COBC (Coordination of Benefits Contractor). Could the “plaintiff” be found non compliant under Section 111 for not providing the requested information for accurate reporting of claims? This is yet to be determined.
As stated by CMS the, “collection of HICN’s, SSN’s, and EIN’s for purposes of compliance with the reporting requirements under Section 111 of Public Law 100-173 is appropriate.”
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