Self-insured Applicable Large Employers (ALEs) may want to take time now to review their health plan participant data for missing social security numbers. Part III of Form 1095-C requires a Social Security number (SSN) or Taxpayer Identification Number (TIN) for each covered participant. If you don’t have the number on file, you are required to request the information three times. Dates of birth can be recorded on the 1095-C in lieu of the appropriate identification number when employers have requested the missing information and have not received it.
Fully-insured large employers are not required to complete Part III of the Form 1095-C so there is no need to request missing SSNs or TINs unless the identification numbers are needed by the company for some other business reason.
Required Solicitations
- First attempt: Make an initial request at the time the relationship with the covered individual is established. This request would generally take place when the employee enrolls in the health plan. SSNs or TINs should be provided for all family members enrolled.
- Second attempt: Solicit the missing SSN or TIN at a reasonable time thereafter, no later than December 31st of the year the participant is enrolled (or no later than January 31st if the participant enrolls in December).
- Third attempt: Another solicitation by December 31st of the following year.
Penalties
ALEs that fail to file a correct information return or to furnish a correct statement are subject to penalties. Penalties may be waived if the failure is due to reasonable cause and not willful neglect; that is, if a reporting entity demonstrates that it has acted in a responsible manner and that the failure is due to significant mitigating factors or events beyond the reporting entity’s control.
Please contact your HBI analyst or consultant if you have questions regarding this process.
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Please note that the information contained in this document is designed to provide authoritative and accurate information, in regard to the subject matter covered. However, it is not provided as legal or tax advice and no representation is made as to the sufficiency for your specific company’s needs. This document should be reviewed by your legal counsel or tax consultant before use.
Additionally, the messages and content within the Pittsburgh Health Care Reform group do not reflect the advisory services of Henderson Brothers, Inc.
