Don't see this as a HIPAA Privacy Rule requirement.  In fact, until
there is an alternative individual identifier, each plan or provider
assigning a proprietary number to identify an individual creates even
more confusion than we currently have.  Especially in COB situations. 
But, are you in California?  California recently passed SB 168 regarding
the use of SS#'s.  However, the law does allow use of SS# for "internal
verification or administrative purposes."  This is what most plans or
providers use the SS# for anyway.  What it will require is for a plan or
provider to take a look at notifications sent or ID cards used.   Have
your counsel take a look at this bill or similar bills proposed in other
states.   Essentially, you can prepare a response that states you are
permitted to use SS# in certain limited situations, such as eligibility
and claims payment.  

>>> "Waterhouse, Melissa" <[EMAIL PROTECTED]> 02/05/02 09:33AM
>>>
Recently, we have been experiencing resistance from members when we
request
their social security number and the numbers of their dependents.
Several
letters from employees quote The Privacy Act. We are considering not
requiring dependents socials but this could negatively impact HEDIS
numbers
since SSN's are the only way to track continuous enrollment.

I am wondering if other health plans are also experiencing this and if
they
decided to not require social security numbers or have moved to using
another identifier.

Thank you,
Melissa Waterhouse
SummaCare Health Plan

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