August 20, 2016
The Honorable Andrew Slavitt
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244
Re: Social Security Number Removal Initiative
Dear Acting Administrator Slavitt:
The undersigned provider organizations are writing to urge the Centers for Medicare & Medicaid Services (CMS) to seek public input regarding the implementation of the Social Security Number Removal Initiative (SSNRI). Industry reports suggest that CMS may soon release the SSNRI regulation via an Interim Final Rule. Because the SSNRI transition has the potential to significantly disrupt patient care and physician payment, we recommend that CMS instead pursue this change through the traditional Notice of Proposed Rulemaking (NPRM) process so that valuable industry feedback on SSNRI implementation may be obtained and considered.
Although protecting patient security and reducing the risk of identity theft and fraudulent Social Security Number (SSN) usage are of vital importance, we believe that soliciting the input of industry stakeholders is essential to ensuring a smooth SSNRI transition process for patients, physicians, and CMS. In recent years, numerous commercial health plans have shifted from using SSNs to new member ID numbers in administrative transactions and for general patient identification purposes. As a result, health plans and providers have already undergone a transition similar to that which CMS is currently facing, and they could provide valuable insight on best practices that would help CMS effectively and efficiently introduce the Medicare Beneficiary Identifier without negatively impacting patient care or physician payment. Such perspective is particularly important when considering the characteristics of the vulnerable Medicare patient population, who may require additional education and outreach during the conversion period.
In an age of increased identity theft and fraud, the Medicare patient population deserves the improved security that will be achieved with the SSNRI. This protection should not, however, come at the expense of prompt patient care or provider payment. We therefore urge CMS to solicit and utilize the feedback of industry stakeholders by releasing the SSNRI regulations via an NPRM.
We appreciate your attention to this matter. Should you have any questions, please contact Laura Hoffman, Assistant Director, AMA Federal Affairs, at (202) 789-7414 or firstname.lastname@example.org.
American Medical Association
American Society of Anesthesiologists
Colorado Medical Society
Johns Hopkins Health System
Medical Group Management Association
Physicians Advocacy Institute