Ask the HR Expert — ACA

on January 9, 2019

Q: We are self-insured. We have an employee who would like to add his wife to his health insurance, but she doesn’t have a SSN. What are acceptable forms of ID? Can we deny coverage under the ACA?

A: If you’re considered an Applicable Large Employer (ALE) under the Affordable Care Act (ACA), then a valid SSN is required for the employer to report the SSNs of covered employees and spouse/children on Form 1095-B.

However, you may be able to temporarily use the spouse’s birthdate in place of her SSN if you continue asking your employee for his wife’s SSN and you do so in a reasonable manner as described under Treasury Regulation § 301.6724–1(a)(1). This means, you’ll want to:

  • Make an initial, documented solicitation to your employee for the SSN.
  • Complete the first annual solicitation by December 31 (or January 31 if the account is opened in December), and
  • Conduct a second annual solicitation by December 31 of the following year.

Additional Resource:

Bottom Line:
Before denying coverage, consult with your benefits broker.

Jill Schaefer

Jill Schaefer

Jill is the Content and Community Manager here at KPA. She breaks down complex regulations into why they matter and what they mean for clients. In short, she tries to make compliance easier and help employers do the right things.

In her spare time, she is equal parts crazy cat lady, triathlete, and pizza connoisseur.

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Jill SchaeferAsk the HR Expert — ACA

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