Re: Social Security Number Removal Initiative
Dear Administrator Verma:
The undersigned organizations are writing to express concern over the Centers for Medicare & Medicaid
Services’ (CMS) planned enactment of the Social Security Number Removal Initiative (SSNRI). As
explained below, this initiative has the potential to significantly disrupt patient care and physician
payment. Accordingly, we recommend that CMS pursue this change through the traditional notice
and comment rulemaking process so that valuable industry feedback may be considered. We
further ask that CMS develop a mechanism for providers to quickly and securely access Medicare
beneficiary identification numbers to avoid disruptions in access to care.
Background
The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 included a provision requiring
CMS to remove the Social Security Number (SSN) from Medicare cards due to concerns of identity theft.
The process CMS has developed to implement this requirement is referred to as the SSNRI. CMS
currently uses a Health Insurance Claim Number (HICN), based on an individual’s SSN, as a patient’s
Medicare beneficiary identification number. To implement the SSNRI, CMS will create new Medicare
Beneficiary Identifiers (MBIs), first for the 60 million active Medicare beneficiaries and then for 90
million deceased beneficiaries, to replace the HICN on beneficiary identification cards.
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