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The IRS requires health plans to get Social Security Numbers for covered dependents. SSN is used by the IRS to match 1095 information with the individual’s federal tax return information.
Employers with self-insured health plans are responsible for obtaining missing SSNs for employees and covered dependents. An employer will be subject to a penalty for failing to use a correct SSN unless it takes the following steps:
- The employer requests the SSN at the individual’s first enrollment in health coverage
- The employer requests the SSN again at a reasonable time after first enrollment
- The employer makes a third request by December 31 of the year following the first requests.
If after taking this progression of steps, the employer is still not able to obtain the SSN, the employer may use the individual’s date of birth for reporting. The employer will have to be able to show documentation it took the above steps, didn’t get a response, and needs to use birthdate.
Employers were required to do a similar 3-step SSN request outreach in 2015/2016 when ACA reporting first became effective to gather SSNs for existing covered employees/dependents.
