Social Security Numbers for ACA

The Affordable Care Act requires insurers and sponsors of self-funded health plans to report to the IRS information about individuals enrolled in health coverage. A Social Security Number is used to identify each person for ACA reporting. When ACA data is transmitted to the IRS, the IRS uses the SSN to match the information submitted on an individual’s federal income tax return.

Employers with self-funded health plans are responsible for obtaining SSNs for employees and covered dependents. The IRS requires the following steps for SSN collection:

1. The employer should request the SSN at the individual’s first enrollment in health coverage.
2. The employer should request the SSN again at a reasonable time after the first enrollment.
3. The employer should make a third request by December 31 of the year following the first request.

If after taking these steps, the employer is still not able to obtain the SSN, the employer may use the individual’s date of birth for ACA reporting.