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:
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.