We are having a bit of a dispute with one of our partners regarding 
elements NM108 and NM109 in the 2100A Loop (Member Name) of the 834. 
They are insisting that the Social Security Number is required. Now 
I have a colleague telling me that there has to be something in 
NM108 and NM109 (although they aren't clear on what should be there 
if a member is lacking an SSN).

I need a reality check.

The standards indicate that these elements are situational. In fact, 
there is a note that the SSN may not be used in Federally 
administered programs, such as Medicare. Even the example that is 
given has no NM108 or NM109 in it.

Comments from HIPAA transaction experts and non-experts would be 
greatly appreciated. Maybe I missed something that was agreed upon 
outside of the standards.

Thanks,
Joe Suarez



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