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New Requirement Mandates Collection of Social Security Numbers

The Centers for Medicare & Medicaid Services (CMS) now requires that insurers and TPAs for fully-insured and self-funded group health plans report certain information about individuals covered under its group health plan for the purpose of coordinating benefits with Medicare under the Medicare Secondary Payer Rules. The information required to be reported includes both the subscriber’s and covered dependent’s Social Security Numbers (SSNs) and employers’ Tax Identification Numbers (TINs.)

We understand that some employer groups or individuals may be hesitant to provide SSNs since they are considered Protected Health Information (PHI) and are protected under the Health Insurance Portability and Accountability Act (HIPAA.) However, collection of SSNs for the purpose of coordinating benefits is necessary and required under Federal law (which supersedes any conflicting state laws.)

ConnectiCare will be responsible for collecting the data and providing it to CMS for the purpose of compliance with the Medicare Secondary Payer rules. Here are a few changes that we have made to support collecting this data:

  • Manual Enrollment Forms – We have added a section to include dependent’s SSNs. This will now be a required field.
  • Electronic Enrollment – We will require that you populate the data field for dependent SSNs.
  • Online Updates – When adding dependents to existing contracts online via "My Accounts,” we will require that you populate the dependent’s SSNs.

ConnectiCare will also routinely collect employer TINs and group size (i.e. actual count of employees) during your renewal process. If this data is missing, we will contact you to provide us this information.

For more information click the attached CMS hyperlinks to learn about the new mandate.

August 1, 2008 - MMSEA111 - Supporting Statement
June 23, 2008 - MMSEA111 - Collection of Social Security Numbers (SSNs), Medicare Health Insurance Claim Numbers (HICNs) and Employer Identification Numbers (EINs)(Tax Identification Numbers) - ALERT