By Donielle Tigay Stutland, J.D.
OIG audit recommends that CMS improve controls to ensure enrollees are not assigned duplicate MBIs, deceased beneficiaries are not mailed new Medicare cards, and payments are not made on behalf of deceased beneficiaries.
In a small percentage of cases, CMS controls did not prevent multiple Medicare Beneficiary Identifiers (MBIs) from being assigned to the same beneficiaries, or new cards being sent to deceased beneficiaries, an HHS Office of Inspector General audit revealed. The purpose of the audit was to evaluate internal controls over the implementation of assigning new MBIs and mailing new Medicare cards to beneficiaries. Specifically, OIG sought to determine whether CMS’s controls were effective in ensuring that (1) beneficiaries were properly assigned MBIs, (2) deceased beneficiaries were not mailed new Medicare cards, and (3) payments were not made on behalf of deceased beneficiaries. In addition to revealing that CMS controls did not prevent multiple MBIs, the OIG found that CMS made $2.3 million in improper payments on claims for deceased beneficiaries (OIG Report, A-09-19-03003, January 13, 2020).
Background. With the passing of the Medicare Access and CHIP Reauthorization Act in April 2015, CMS began implementing the Social Security Number Removal Initiative. To meet these requirements, CMS generated new randomized insurance numbers, MBIs, assigned the MBIs to beneficiaries beginning in May 2017, and mailed new Medicare cards to beneficiaries beginning in April 2018. The goal of this change was to reduce identify theft, however, OIG wanted to determine if the new procedures resulted in any deficiencies in assigning MBIs and mailing new cards that resulted in unintended consequences, such as claim processing errors. OIG conducted its audit to assess CMS’s internal controls over assigning MBIs and mailing new Medicare cards to beneficiaries.
Findings. The audit showed that CMS’s controls were generally effective. However, the findings did show a small percentage of cases where CMS’s controls did not prevent multiple MBIs from being assigned to beneficiaries, or prevent the mailing of new cards to deceased beneficiaries. This resulted in improper payments of $2.3 million on claims for deceased beneficiaries.
The results showed CMS assigned 22,662 beneficiaries two or more MBIs associated with multiple enrollment records that contained the same SSN and date of birth. Additionally, CMS mailed 58,420 new Medicare cards after the beneficiaries’ dates of death (of those 2,222 were mailed after the enrollment data base (EDB) had already updated the date of death). Finally, CMS made $2.3 million in improper payments for 3,756 Medicare Part A and Part B claims with dates of service after the beneficiaries’ dates of death.
Recommendations. The OIG recommends that CMS improve its system controls by checking the EDB’s date-of-death information as close as reasonably possible to the date that card mailing data are sent to the print/mail contractor to ensure that Medicare cards are not mailed to deceased beneficiaries.
Additionally, OIG recommends that CMS instruct Medicare contractors to:
- review deductible amounts that may have been incorrectly collected from beneficiaries or from someone on their behalf and take appropriate actions to resolve these amounts; and
- review the $2,263,465 in improper payments for claims with dates of service after the beneficiaries’ dates of death and initiate recoupment for the amounts identified as improper payments.
CMS concurred with all of the OIG recommendations. With respect to the mailing of Medicare cards, CMS noted that a previous mass mailing effort of new cards has now concluded, so it believes that in the future it will be easier to apply the recommendations, including checking the date of death for new mailing efforts. CMS will also be implementing procedure to ensure a second check for date of death prior to the mailing of new cards.
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