Justification for the Non Substantive Change Request - 0960-0723

Justification for Non-Substantive Change to

Redetermination of Eligibility for Extra Help with Medicare Prescription Drug Plan Costs

Forms SSA-1026-REDE

(Social Security Administration Review of Your Eligibility for Extra Help)

And

SSA-1026-SCE

(Social Security Administration Reporting a Change That May Affect Your Extra Help)

20 CFR 418.3125

OMB No. 0960-0723

Background

Section 1860D-14(a)(3)(A)(iv)(I) of the Medicare Modernization Act (MMA) of 2003, as codified in Section 418.3125 of the Code of Federal Regulations, requires the Social Security Administration (SSA) to conduct low-income subsidy eligibility redeterminations for recipients of the Medicare Prescription Drug Plan (Part D) subsidy. The agency uses Forms SSA‑1026‑REDE and SSA-1026-SCE for these purposes. SSA collects information from subsidy recipients to: (1) determine if a subsidy redetermination is necessary, and (2) conduct the actual redetermination. This collection is mandatory for respondents who wish to continue their Medicare Part D subsidy.

SSA designed SSA-1026 paper application forms to allow successful scanning into the Medicare Application Processing System (MAPS) via the Wilkes-Barre Direct Operations Center (WBDOC) and field offices (FOs). Forms SSA-1026-REDE, and SSA-1026-SCE request the completion of the Medicare Claim Number field and other data fields. In accordance with the agency’s Government Paperwork Elimination Act plan, SSA created an Intranet version of SSA‑1026 forms. Currently the Medicare Claim Number field on SSA-1026 forms contain space to capture the number printed on the beneficiary’s old Medicare Card known as the Health Insurance Claim Number (HICN).

The Medicare Access and CHIP Reauthorization Act (MACRA) legislation mandates the removal of Social Security Numbers (SSNs) from Medicare cards no later than four years from enactment of the MACRA legislation. The primary goal of the MACRA is to decrease Medicare beneficiary vulnerability to identity theft. The Center for Medicare and Medicaid Services (CMS) replaced the Health Insurance Claim Number (HICN) with a new, randomly generated Medicare Beneficiary Identifier (MBI). To implement this change, CMS collaborated with SSA to address processes that affect implementation of legislative requirements.

Revision to the Information Collection

Change 1: On page 2, question 1, retitled field from “Medicare Claim Number” to “Medicare Number” and adjusted fillable boxes to accommodate the new Medicare Beneficiary Identifier (MBI).

Justification 1: The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 mandates the removal of the SSN-based Health Insurance Claim Number (HICN) from all Medicare cards. CMS replaced the SSN-based HICN with a new randomized 11 digit alpha numeric Medicare Beneficiary Identifier (MBI). We are requesting to align with the MACRA mandate by updating the title and format of the Medicare Claim Number field on SSA-1026 paper application forms to accommodate the new MBI.

Change 2: On page 2, question 2, retitled field from “Spouse’s Medicare Claim Number” to “Spouse’s Medicare Number” and adjusted fillable boxes to accommodate the new MBI.

Justification 2: The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 legislation mandates the removal of the SSN-based Health Insurance Claim Number (HICN) from all Medicare cards. CMS replaced the SSN-based HICN with a new randomized 11 digit alpha numeric Medicare Beneficiary Identifier (MBI). We are requesting to align with the MACRA mandate by updating the title and format of the Medicare Claim Number field on SSA-1026 paper application forms to accommodate the new MBI.

SSA was unable to make the proposed changes prior to the previous submission of the clearance package because the agency needed to conduct additional research to ensure the proposed changes could be systematically implemented with minimal cost and little to no downstream processing effect.

We will implement these changes upon OMB’s approval. This action does not affect the public reporting burden.

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