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Reform Update

Background
In order for the IRS to have sufficient information to enforce health reform, the IRS will require employers to report whether they offered an employer-sponsored plan to full-time employees and their dependents. The reporting requirement rule is a critical element of the enforcement mechanism for the law. Taken together with information residing in the insurance exchange data base, the reporting will reveal when penalties might be triggered for either individuals or employers subject to the law.

Collections Social Security Numbers

Health reform and its reporting rules require an employer with 50 or more full-time employees (including full-time equivalent employees) to have Social Security Numbers (SSNs) for all enrolled employees and their family members covered by the health plan. Additionally, even smaller employers with under 50 full-time and full-time equivalent employees who offer a self-funded health plan generally must have the SSNs for the employee covered under the plan. For adults, that information may be readily provided. In fact, most carriers and third party administrators already capture SSNs for eligibility, billing and Medicare reporting purposes. The dependent child SSNs may be more elusive. A parent may enroll an infant child prior to obtaining an SSN, and some parents procrastinate on ever obtaining the SSNs. Now, under health reform rules, for the calendar year starting January 1, 2015, an employer will need to either have the actual SSN for each covered person, or be able to show it asked for dependent SSNs at least three times. Asking three times is considered a “reasonable” attempt by the federal agency. What if an SSN is never provided? The employer can simply use the child’s date of birth instead.


The government is not specific about exactly how or where to make the requests, but the employer should be sure the communication method is reasonably expected to reach at least the enrolled employees. The rules do not require a targeted notice, so some employers may choose to include the request in an item provided to all employees such as the plan sponsor’s benefit guide. Although this generalized approach is acceptable, the materials should specify that only those individuals actually enrolled in the health plan need to respond. MORE...

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