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Back  RFI # 367: Government entity receives SSN

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Submitter

Robert Huffman

Description

A federal government entity has received a 270 request that contains the Social Security Number of the subscriber. The IG states on page 76 that the use of an SY identifier in a REF segment in the 2100C loop is not allowed if the receiver is ... Medicare. What is the proper response mechanism to reject the transaction? The transaction is X12 compliant and therefore it seems that using a 997 is not proper. There is no identifer in the AAA segment in the 271 loop 2100C that would identify that an SSN was received and the SSN is not allowed.

Response

The IG actually states “The social security number may not be used for any Federally administered programs such as Medicare.” The key word would be “used”. For example, if the receiver were Medicare, while a provider might inadvertently send the SSN in a REF segment in addition to the HICN in the NM1 segment, Medicare may not “use” the SSN. In this case, Medicare can chose to ignore the existence of the SSN in the 270 (since in all likelihood it would not be mapped for processing) and process the 270 in the interest of serving the patient since the needed identifier was sent and used (and by not mapping the SSN, it would not be used).

If the information source requires another ID but the only identifier that is sent for the subscriber is the SSN the transaction should be rejected using the 271 2100C AAA segment with AAA01 = "N", AAA03 = “72” (Invalid/Missing Subscriber/Insured ID) indicating that the problem is with the subscriber/insured ID (missing the HICN in this example) and AAA04 = “C”.

Recommendation

If a federally administered program wishes to reject transactions that contain valid identifiers and an SSN, an X12 code maintenance request should be submitted to request a code for data element 901 for “Social Security Number may not be used”.
Submission 11/30/2005
Status Date 2/14/2006
Status F - Final
Primary References
Document 004010X092A1
Section271
Page207
Set ID271