CMS issues reminder related to Medicare Beneficiary Identifier (MBI) and NGHP Reporting

On November 18, 2019, CMS released an alert titled, “Important Reminder for Non-Group Health Plan (NGHP) Responsible Reporting Entities (RREs) Regarding Medicare Beneficiary Identifier (MBI) Reporting.” A copy of the alert can be found here.

The alert conveys no substantive changes to MMSEA Section 111 Reporting. Rather, this alert simply provides clarification on how RREs are to handle reporting updated MBIs to CMS. Guidance provided by CMS includes the following reminders:

  • RREs are not required to resubmit claims due to a change in MBI
  • RREs can choose to voluntarily resubmit claims due to a change in MBI
  • RREs choosing to resubmit records should not send Delete/Add Records
  • RREs choosing to resubmit records should submit MBI updates as Update Records

If ExamWorks is your assigned Reporting Agent, we long-ago deployed logic to address the conversion from HICNs to MBIs.  Our Section 111 logic comports with the updates outline by CMS, and no action on your part is needed.  RREs reporting on their own, or reporting with another vendor should take care to ensure that Delete / Add Records are reserved for situations as previously outlined in the Section 111 User Guide and not simply to convert a properly reported HICN into an MBI.  

If you are interested in additional details related to this alert, or other reporting related matters, please reach out to our dedicated team of Section 111 reporting experts at

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