Can Employers Deny Spousal Coverage if the SSN is Not Provided?
Understanding ACA Health Coverage and SSN Requirements
The Affordable Care Act (ACA) established specific reporting requirements for employers who provide health insurance to their employees. These requirements include the collection of Social Security numbers (SSNs) for all covered individuals, including spouses.
SSN Reporting for ACA Compliance:
Under the ACA, employers with self-insured health plans or group policies with insurers must file Forms 1095-C and 1095-B, respectively. These forms provide information about health insurance coverage to the IRS and individuals.
Part III of Form 1095-C requires employers to list either the SSN or date of birth for each covered individual. Insurance companies filing Form 1095-B also have similar reporting requirements.
SSN Exemption:
The IRS allows employers to omit the SSN if they have made reasonable efforts to obtain it but were unsuccessful. However, employers must still report the date of birth for covered individuals.
Employer Requirements:
Typically, employers cannot refuse to cover a spouse if the employee does not provide their SSN. However, they may ask for the SSN to comply with ACA reporting requirements.
Employee Considerations:
Employees who are hesitant to provide their spouse’s SSN can ask their employer for a specific reason why it is required.
Employers should be able to provide a satisfactory explanation, such as compliance with ACA reporting or data integrity for insurance processing.
Employees can verify their SSN requirement by reviewing their health insurance plan documents or contacting their insurance provider.
Conclusion:
Generally, employers cannot deny spousal coverage due to the absence of a spouse’s SSN. However, they may request it for ACA reporting purposes. Employees have the right to question the SSN requirement and request alternative methods of verifying their spouse’s identity. It is important for both employers and employees to understand the ACA reporting requirements and the implications of withholding or providing SSNs.
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