Under the Affordable Care Act (ACA) mandatory information reporting requirements, sponsors of self-funded plans are required to provide 2015 eligibility and coverage information about employees and dependents on Forms 1094 and 1095 B or C, and must include SSNs if available. If SSNs are not available, dates of birth may be used, but employers must be able to document three attempts to obtain the SSNs.

The initial request for SSNs is on the initial enrollment form. To assist in satisfying the additional two requests, Health Plans will be conducting two outreach efforts and will provide current clients with the documentation they will need to confirm that they have made “reasonable attempts” to obtain SSNs for all individuals covered under their plans.

For members enrolled through June 30, 2015:
1) August 2015, Health Plans will send requests to any subscriber (employee) who is missing subscriber or dependent SSNs.
2) November 2015, another request will be sent to those who did not respond to the August mailing.

If any SSN is still missing after the November request, Health Plans will provide the member’s date of birth for the clients’ required ACA reporting.

For members enrolled on or after July 1, 2015, employers will need to obtain members’ SSNs upon their initial enrollment.

For questions regarding the social security outreach and reporting requirements, contact your NEEBCo representative.