Self-Insured Plans May Struggle to Get SSNs from Employees

The Affordable Care Act requires that self-insured employers report the "taxpayer identification numbers," or Social Security numbers, of their employees, but wary employees have often not answered these requests for personal financial information. The Internal Revenue Service proposed regulations in July 2016 detailing a "three tries" approach that could allow employers to prove they proactively requested SSN information. Attorney Nicole Elliott comments on the concerns of self-insured employers to comply with health coverage regulations.

"Their concern was particularly acute because of the hefty penalties that are associated with failure to file accurate and complete information returns with the IRS," said Ms. Elliott.

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