This story was updated June 23.
The government's plan to remove Social Security numbers from Medicare identification cards rolls out in nine months, but the CMS has yet to give providers clear guidance on their responsibilities to ensure that billing privileges aren't affected.
Since the beginning of the Medicare program, Social Security numbers have been used as the beneficiary identifier for administering services. The Medicare Access and CHIP Reauthorization Act required the CMS to remove the numbers from Medicare cards because of identity theft and fraud risks.
Starting in April 2018, the CMS will begin to issue Medicare cards with new ID numbers. Approximately 60 million beneficiaries will receive the new cards by April 2019.
Without clear instructions on how to prepare for the change, physicians risk losing their ability to bill Medicare. Claims with the old numbers won't be accepted starting in 2020. Practices also need to update their electronic health record systems to accept the new ID numbers.
Doctors know the changes are coming, but many have done nothing to prepare.
Dr. Charles Rothberg, an ophthalmologist who is president of the Medical Society of the State of New York, said the CMS could do more to educate providers about the change, given the impact it could have on physician practices.
"We don't have much information as to how they plan to roll this out," he said.
A CMS spokesman disagreed that guidance has been lacking. He said the agency has been listening to concerns raised in recent weeks outlined by the provider community and has amped up messages, tactics, guidance and other provider outreach.
On June 15 the agency did release a five-point bulletin on steps that practices should take to prepare for the change. The advice included going to the CMS' website for updates, attending quarterly calls and testing current billing systems to be sure they can handle the new format.
But physicians still need more guidance, Rothberg said. The CMS bulletin didn't clarify how long-term-care facilities should help patients who come in for treatment but don't know their new ID numbers. Nursing home providers may not keep track of new patient ID numbers, since Medicaid pays for most low-income seniors' care, he said.
Providers had been pushing the CMS to make the change via a rulemaking process, giving the agency a chance to lay out a substantive rollout plan and letting clinicians weigh in.
While dealing with ICD-10, the rollout of the Merit-based Incentive Payment System and alternative payment models under MACRA, as well as ongoing EHR meaningful-use activities, vendors may not be able to address this latest change in a timely way, according to Robert Tennant, director of health information technology policy at the Medical Group Management Association.
Even without a formal comment period, Tennant has seen the CMS attempt to address some provider concerns.
The CMS originally had no plans to create a database that would allow providers to look up the new numbers if a patient lost their card or didn't bring it in for an appointment. The agency reversed course last month, announcing that it will create a secure database for both providers and beneficiaries.
"That's a big change we saw," Tennant said. "It's critical that practices be able to look up these numbers."