Apr 16, 2024
Employer Compliance Tip
Are SSNs Required for Medical Plan Enrollment?
There seems to be confusion about whether employees, spouses and dependents must provide a valid social security number (SSN) or tax identification number (TIN) prior to enrolling in medical coverage, perhaps because ACA minimum essential coverage reporting requires a SSN/TIN or date of birth on Form 1095s.
In general, a SSN or TIN is not required for enrollment unless the plan eligibility rules are written to specifically require it, or if the carrier requires it. For employees, a valid SSN or TIN is likely required for purposes other than benefits. However, for spouses and dependents there is more flexibility. The plan eligibility rules could require U.S. citizenship and/or residency, and the plan could require a SSN/TIN to be provided prior to enrollment, but isn't required to do so. If the carrier or plan eligibility rules do not specifically require a SSN or TIN, and the spouse or dependent otherwise meets the plan eligibility rules, it would be okay to allow enrollment without it.
Separately, for ACA reporting purposes, the carrier or employer is not actually required to have a valid SSN/TIN so long as 3 attempts are made to collect it for any individuals enrolled in the medical coverage. To meet this requirement, the employer or carrier should request a SSN/TIN upon enrollment, but if the employee or dependents don't provide it, the plan could still allow enrollment. The employer would then need to make 2 additional attempts to obtain a SSN/TIN for enrolled individuals, but if the SSN/TIN is not provided, a date of birth may be used instead on the Form 1095.
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