Since the transition to the new MBI on April 2, 2018, can MAOs and other entities submit deletions for dates of service (DOS) before April 2, 2018 using the HICN?

Yes. For both the Encounter Data System (EDS) and Risk Adjustment Processing System (RAPS), MAOs and other entities will be able to submit the Health Insurance Claim Number (HICN) on deletes during and after the Medicare Beneficiary Identifier (MBI) transition period. For EDS this can be done for encounter data records and chart review records that were originally submitted using either the HICN or MBI. Effective January 8, 2019, RAPS will accept either the MBI, HICN, or RRB where applicable on delete transactions regardless of which beneficiary identifier was submitted on the original add transaction. For further information, please see the December 22, 2017 CMS Health Plan Management System (HPMS) memo, “Updates to the Encounter Data System and Risk Adjustment Suite of Systems to Accommodate the New Medicare Card Project” and the December 10, 2018 CMS HPMS memo titled, “Updates to the Risk Adjustment Suite of Systems (RASS) for Delete Transactions using a Beneficiary Identifier”.