Under Health Care Reform, a health coverage provider, including an employer that provides self-insured health coverage, must report to the IRS certain items, including a taxpayer identification (TIN) number for all covered individuals. The TIN (usually the Social Security Number) is required for the IRS to verify an individual’s coverage.
If providers are not able to obtain a TIN after making a reasonable effort to do so, the provider may report the individual’s date of birth instead of TIN.
The IRS has advised that making a “reasonable effort” includes:
- Making an initial request for the number at the time the relationship with the individual is established (when individual first becomes eligible for coverage).
- Requesting the number by December 31 of the year in which the relationship with the individual begins (January 31 of the following year if the relationship begins in December).
- Requesting the number again by December 31 of the following year.
If the provider does not receive the TIN after these three attempts, the employer can use the individual’s date of birth on its health care reform reporting to the IRS.
