PPACA Reporting Requirements: Collecting SSNs

07/17/2014

Under PPACA, employers are required to report on the minimum essential coverage offered to employees and their dependents starting in 2016.  Employers will need to include the Taxpayer Identification Number (TIN), typically Social Security Numbers (SSNs), of each covered individual in the IRS filing.  The request of SSNs usually makes an employee and even the employer apprehensive as to its safekeeping and necessity.  According to the IRS final regulations, employers must make “reasonable efforts” to obtain TINs through various ways, including electronic, paper, telephonic and in-person.  So what is a reasonable effort?  If an employer does not already have the SSN of a plan participant, it must solicit the information up to three times to demonstrate that it acted in a responsible manner.

  • The initial attempt begins at the time relationship begins i.e. date of hire, open enrollment or other qualifying event for employees and dependents;
  • The second attempt must be made  by December 31st of the year in which the relationship begins if the SSN is not disclosed;
  • The final attempt must be made by December 31st of the following year if the SSN is not given;
  • If a SSN is still not provided after the third attempt, the employer has acted in a responsible manner and need not continue to solicit a SSN.   The employer may now use the date of birth for any of those participants.

The reporting process will require proper documentation and understanding of the regulations.  The IRS is encouraging voluntary compliance for 2014 so it is important for employers to get comfortable with the outreach process as the effective date nears.

If you have any questions, please contact your WGA’s Compliance Team info@WGAins.com.