Are SSNs Required for Medical Plan Enrollment?

We are always told to protect our identities and keep our personally identifiable information, such as social security numbers (SSNs) and passwords, safe where they can’t be stolen and used fraudulently. In the 21st century, this concern is real, and we have all either experienced the violation and headache of identity theft or know someone close to us who has. To protect that information, it is prudent to exercise caution when someone requests it. These days, it seems like everyone says they require an SSN to provide service. But is it legally required? Or is it just the most convenient way to identify someone in their records and, sometimes, report on someone’s credit?

There seems to be confusion about whether employees, spouses, and dependents must provide a valid SSN or tax identification number (TIN) before enrolling in medical coverage. This confusion may stem from the requirement for minimum essential coverage reporting under the Affordable Care Act (ACA), which requires an SSN/TIN or date of birth on IRS Form 1095. Employees are often hesitant to provide these numbers, and employers and HR need the paperwork completed to remain compliant.

In general, an SSN or TIN is not required for enrollment in an employer group health plan unless the plan eligibility rules are written to require it specifically or if the carrier requires it. It is important to verify this information with your organization’s carrier and on your plan documents. 

For employees, a valid SSN or TIN is likely required for purposes other than benefits, including background checks, work authorization, and tax reporting. However, for spouses and dependents, there is more flexibility. The plan eligibility rules may require U.S. citizenship and/or residency, and the plan could require an SSN/TIN to be provided prior to enrollment, but they aren’t legally required to do so. If the carrier or plan eligibility rules do not specifically require an 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 as long as three attempts are made to collect it for any individuals enrolled in their medical coverage. To meet this requirement, the employer or carrier should request an 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 two additional attempts to obtain an SSN/TIN for enrolled individuals, but if the SSN/TIN is not provided, a date of birth may be used instead on IRS Form 1095.

FEDlogic is here to help with questions frequently found at the intersection of Federal and state benefits, healthcare, and employee benefits. We help employees understand and navigate their true options and help shoulder the burden of these confusing and complicated questions for our partners in HR, saving them valuable time and unnecessary costs for the employer group health plan.

New Client Spotlight: Lac du Flambeau Band of Lake Superior Chippewa Indians

FEDlogic is proud to feature the Lac du Flambeau Band of Lake Superior Chippewa Indians as one of our newest client partners.

A federally recognized Indian Tribe, the Lac du Flambeau Band of Lake Superior Chippewa Indians has occupied the Lac du Flambeau area in Northern Wisconsin since 1745, when Chief Kewaskum led the band to the area. The Lac du Flambeau Reservation, comprising 144 square miles, was established more than a century later by the Treaty of 1854. The Lac du Flambeau Band of Lake Superior Chippewa Indians boasts a rich cultural heritage, and the name "Lac du Flambeau" translates to "Lake of the Torches" in French, reflecting the tribe's traditional practice of harvesting fish at night by torchlight.
Over the years, the tribe has developed diverse economic enterprises in an effort to maintain self-reliance and ensure economic stability for community members. Today, tribal industries include the tribally-owned Simpson Electric Company, which manufactures digital panel meters, analog panel meters, and test instruments and equipment; the Lake of the Torches Resort and Casino; a tribal fish hatchery; the Waaswaaganing Indian Bowl Living Arts and Culture Center; and a comprehensive healthcare clinic and dental campus. The tribe is the area’s largest employer and contributes significantly to the local economy. In the region's cultural, economic, and social landscape, the tribe plays a crucial role in balancing heritage preservation with community prosperity and welfare.

Thank you for placing your trust in FEDlogic. We look forward to serving your families.

Check out the FEDlogic LinkedIn page for this and all new client features.

Spotlight on Client Success: Mara Rayner of Montana Credit Union League Group Benefit Health Trust

FEDlogic’s Director of Client Services, Kate Kellner, interviewed Mara Rayner, Director of Human Resource Benefits from the Montana Credit Union League Group Benefit Health Trust, about the organization’s experience with FEDlogic.

Kate: Thanks for joining me today to discuss your experience with FEDlogic. Let's dive right in. Can you briefly describe why you initially made contact with FEDlogic?

Mara: We are fortunate to be part of Leavitt's Tribute Captives for our stop loss reinsurance, and they have been wise enough to include FEDlogic as one of their trusted vendors. Through this partnership, we get to work with FEDlogic, which has been great.

Kate: Can you tell me about any specific experiences you've had with a FEDlogic expert?

Mara: Absolutely. FEDlogic experts are very knowledgeable. We've had members reach out for assistance with various issues. For instance, one member dealing with diabetes needed guidance on long-term benefits as their condition made working difficult. Another member approaching retirement age sought advice on how to manage their benefits. Both members were very pleased with the support they received from FEDlogic.

Kate: That’s excellent to hear. What aspects of FEDlogic’s service do you find most valuable for your organization?

Mara: FEDlogic is probably the most beneficial service we have for our members. They provide invaluable guidance on retirement planning, especially for those looking to retire early. Our credit union employees, being financially savvy, really appreciate learning what steps to take five to ten years in advance. This proactive approach helps them plan appropriately for their future.

Kate: Thank you. Can you recall any particular moment or experience with FEDlogic that stood out to you?

Mara: The webinars are fantastic and very informative. They allow members to choose topics of interest, get valuable information, and ask questions. These sessions are incredibly beneficial for our members.

Kate: How would you describe FEDlogic’s customer service and support?

Mara: FEDlogic has excellent customer service with great follow-up and support.

Kate: Would you recommend FEDlogic to others? If so, why?

Mara: Absolutely. Before using FEDlogic, we had a member whose dependent spouse mistakenly went on COBRA instead of Medicare after losing their spouse, who was our member. This lead to significant costs. With FEDlogic, we now have the resources to guide our members properly, preventing such costly mistakes and providing better financial security for them.

Kate: It’s wonderful to hear how FEDlogic has been a safety net for your organization. Do you have any final thoughts before we wrap up?

Mara: We're very blessed to have access to the FEDlogic program. It helps us mitigate costs and support our members effectively. What more could we ask for?

Kate: Thank you so much for sharing your experiences, Mara. We truly appreciate your feedback.

_{This interview has been edited for clarity and brevity.}

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_{DISCLAIMER: The information, education, and advice provided by FEDlogic, LLC (“FEDlogic”) shall be intended for educational purposes only. Each individual’s circumstances are inherently different from those of another, and therefore, the advice given to an individual may result in unintended consequences to another. The information provided by FEDlogic shall not constitute legal, financial, or accounting advice and further shall not be interpreted as advice from the Federal government. While FEDlogic makes every effort to ensure that the information provided by its consultants is up-to-date, useful, and accurate, FEDlogic makes no guarantees and may not be held liable nor responsible for any inaccuracy or detrimental consequence resulting from the information provided. Notwithstanding the foregoing, any errors or omissions discovered by FEDlogic, its agents, or its customers will be addressed and resolved as soon as possible.}