CMS Lessens Future Reporting Requirements for Social Security Numbers



On September 10, 2014, the Centers for Medicare & Medicaid Services (“CMS”) issued an alert which modifies the current requirement that the Responsible Reporting Entity (“RRE”) must receive the complete Social Security Number (“SSN”) or Medicare Health Insurance Claim Number (“HICN”) in order to determine the Medicare enrollment status of a claimant. As required by Section 204 of the Strengthening Medicare and Repaying Tax Payers Act of 2012 (“SMART Act”) CMS has lessened this requirement.

As of January 5, 2015, Responsible Reporting Entities (“RRE”) of Non-Group Health Plans (“NGHP”) will have the ability to query for enrollment status by providing the following:

  • Last five digits of SSN,
  • First Initial,
  • Surname,
  • Date of Birth, and
  • Gender.

However, CMS still highly recommends that the full SSN be provided to increase the accuracy of the search.

If the RRE is unable to obtain the SSN, HICN or the above information, it must continue to document its efforts to obtain the information and may request that the claimant complete the form with the model language, previously provided by CMS, describing the reason for not being able to provide this information.

CMS will issue another alert prior to January 5, 2015 with specific instructions on the implementation of this change.

CMS’ alert is likely to lead to greater settlement efficiencies by utilizing a familiar method of obtaining key identifying information (such as asking for partial SSN data), while minimizing the risks of identity theft and other concerns for the settling parties.

The Garretson Resolution Group continues to monitor developments at the CMS and will report future developments to the settlement community. For more information about this announcement and other MSP compliance services, including conditional payment reimbursement, MSA services and MMSEA Section 111 reporting, please see

To view the Alert as posted by the CMS on its website, please follow the link here.

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