SSN Mismatch Errors
The most common errors tied to ACA forms 1095-C and 1094-C electronic submissions to the Internal Revenue Service (IRS) are “Social Security Number (SSN) and Name Mismatch” errors. The Errors have been historically called “Shared -008” or “1095C-010-01” errors. The issue does need to be addressed but the IRS currently does not require a resubmission to clear them.
An SSN-to-name mismatch error does carry a potential penalty, so it is important to follow the IRS guidance on the subject and document efforts.
Where can I go to learn more?
The IRS has compiled a regulations and requirements document to help employers avoid these errors: https://www.irs.gov/pub/irs-pdf/p1586.pdf (see pg.9). In summary, it offers a three-solicitation rule over a period of a couple of years:
- "Initial Solicitation" is a must when the "relationship [is] established"; when the person is first enrolled.
- "First Annual Solicitation" is required if something has alerted the client that there is something wrong (like an Accepted With Errors (AWE ) with a mismatch) within 75 days.
- "Second Annual Solicitation" is basically every year after doing that First Annual Solicitation and for which an error persists (by 12/31); OE time is best practice.
At Benefitfocus we work with our customers to correct errors, including SSN mismatches, as part of our monthly process. We believe in a year-round approach to helping to keep clients compliant and on track with ACA reporting. Our end-to-end ACA compliance solution is powered by proprietary software and delivered by our experienced services team. If your current vendor is falling short, we’d love to help.
The information provided does not, and is not intended to, constitute legal advice; instead, all information and content herein is provided for general informational purposes only and may not constitute the most up-to-date legal or other information.
