CMS Guidance: Reporting T-MSIS Eligible file record segment end dates when valid DATE-OF-DEATH is reported

Brief Issue Description

This guidance outlines the challenges states have faced when populating the end dates of record segments in the Transformed Medicaid Statistical Information System (T-MSIS) Eligible file on records for people who are deceased, and recommends best practices for states’ reporting. When an individual enrolled in Medicaid or the Children’s Health Insurance Program (CHIP) and reported in a state’s T-MSIS Eligible file dies, he or she will have a valid DATE-OF-DEATH (ELG025) reported on the PRIMARY-DEMOGRAPHICS-ELIGIBILITY-ELG00002 record segment. States have encountered some confusion on how to populate record segment end dates in the Eligible file to ensure that the record is reported correctly and appropriately included or excluded for data analysis. This guidance provides instruction to states on how to report DATE-OF-DEATH and Eligible file record segment end dates when an individual in the file dies.

Background Discussion

DATE-OF-DEATH (ELG025) resides on the PRIMARY-DEMOGRAPHICS-ELIGIBILITY-ELG00002 record segment. This is the main parent record segment in the Eligible file  and all other Eligible file¹ record segments are subordinate to it². All effective and end dates of children record segments should fall within the effective and end date time span of the parent record segment; front-end data validation rules support this expectation.

Challenges

Most people who are reported in a state’s T-MSIS Eligible file are alive and do not have DATE-OF-DEATH (ELG025) populated with a valid date. The Eligible file record segments for such an individual might be open-ended (that is, left blank or populated with “99991231”) or might have end dates populated (that is, a valid date if the particular record segment is no longer active), depending on the individual’s eligibility and enrollment experience. However, when an individual dies while enrolled in Medicaid or CHIP, then his or her record in the T-MSIS Eligible file should have a valid date populated on the DATE-OF-DEATH data element. States have been unsure of how to update the reported DATE-OF-DEATH when an incorrect date is initially reported and subsequently has to be corrected.

States have also faced challenges in reporting because they are not sure whether all Eligible file record segments for the deceased individual should be populated with end dates the same as the individual’s date of death. States have reported in a variety of different scenarios when an individual in the Eligible file dies:

1. The record segment end dates for all previously active record segments in the Eligible file are populated with the individual’s DATE-OF-DEATH.
2. The record segment end dates for all previously active record segments in the Eligible file are left as is and only the individual’s DATE-OF-DEATH is populated.
3. The record segment end dates for previously active Eligible file record segments pertaining to an individual’s enrollment or participation (for example, WAIVER-PARTICIPATION-ELG00012 or ENROLLMENT-TIME-SPAN-SEGMENT-ELG00021) are populated with an end date equivalent to the individual’s DATE-OF-DEATH, but the record segment end dates for previously active Eligible file record segments pertaining to an individual’s demographics (for example, VARIABLE-DEMOGRAPHICS-ELIGIBILITY-ELG00003 or RACE-INFORMATION-ELG00016) are left as is and not populated with the individual’s DATE-OF-DEATH.

CMS Guidance

When an individual reported in the T-MSIS Eligible file dies, the date he or she died should be populated in the DATE-OF-DEATH data element on the PRIMARY-DEMOGRAPHICS-ELG00002 record segment. DATE-OF-DEATH should remain fixed in relation to that specific individual and generally should not be updated. The individual’s DATE-OF-DEATH should change only if the original value reported was incorrect. If a change is required because DATE-OF-DEATH is populated with incorrect information, then a new segment is not required. Instead, the data element on the segment with the incorrect information should be updated with the correct information. Table 1 shows an example of modifying an incorrectly reported DATE-OF-DEATH.

Table 1. Reporting a correction to DATE-OF-DEATH on PRIMARY-DEMOGRAPHICS-ELIGIBILITY-ELG00002 record segment

A state can submit an Update File with the corrected segment in it. They can also include the corrected segment in the next monthly Create File³.   If the segment key field values on the corrected PRIMARY-DEMOGRAPHICS-ELIGIBILITY-ELG00002 record segment are different from the values on the incorrect segment, the state will need to submit a separate PRIMARY-DEMOGRAPHICS-ELIGIBILITY-ELG00002 segment to delete the incorrect segment in addition to the corrected segment. The key fields of the PRIMARY-DEMOGRAPHICS-ELIGIBILITY-ELG00002 record segment are: SUBMITTING-STATE (ELG017), MSIS-IDENTIFICATION-NUM (ELG019) and PRIMARY-DEMOGRAPHIC-ELEMENT-EFF-DATE (ELG026).

For all Eligible file records segments except ENROLLMENT-TIME-SPAN-SEGMENT-ELG00021, when an individual dies and has a valid date of death reported the Eligible file record segment end dates for any active record segments for the individual do not have to be populated with the same date as is reported for the individual’s DATE-OF-DEATH or otherwise end dated with another date. The Eligible file record segment ENROLLMENT-TIME-SPAN-SEGMENT-ELG00021 end date (ENROLLMENT-END-DATE (ELG254)) should be populated with the individual’s date of death because this data element should represent the last day of enrollment in a Medicaid program or CHIP. For all other record segments, the presence of a valid date in the DATE-OF-DEATH data element is sufficient to signal that the record for the individual is no longer active due to the individual being deceased. For example, if an individual died on November 18, 2017 (that is, 20171118), but was actively enrolled in a 1915(b) waiver and managed care plan, the end dates for the WAIVER-PARTICIPATION-ELG00012 and MANAGED-CARE-PARTICIPATION-ELG00014 record segments do not have to be populated with his or her date of death or any other date. In addition, all other Eligible file record segments for the individual can remain as they are and do not have to be end-dated with the individual’s date of death or any other date.

There might be some instances when states’ current reporting entails adding end dates to active Eligible file record segments to reflect an end date equivalent to the eligible person’s DATE-OF-DEATH. In those specific cases, states can continue to add end dates equivalent to the DATE-OF-DEATH for records when an individual is deceased. However, please note that states do not have to change their reporting to add end dates equivalent to DATE-OF-DEATH and should follow the guidance provided here, unless the state is already currently reporting in this manner.

[1] The FILE-HEADER-RECORD-ELIGIBILITY-ELG00001 record segment is the ultimate parent for the file, but the unit of analysis is at the file level, whereas all other record segments in the Eligible file have a unit of analysis at the individual level.

[2] See T-MSIS Data Dictionary version 2.1 Record Segment Relationships.

[3] On the T-MSIS Eligible header record segment (FILE-HEADER-RECORD-ELIGIBILITY-ELG00001), the data element SUBMISSION-TRANSACTION-TYPE (ELG0003) is used to designate whether the transactions in the file are original submissions of the data, a resubmission of a previously submitted file, or corrections of edit rejects.