If your organization is going to conduct a dependent eligibility audit, you should consider new federal requirement regarding Third-Party Administrators and their reporting of Social Security Numbers (SSN). Your TPA’s will start requiring all employers to provide SSNs for all covered individuals.
“A new Mandatory Insurer Reporting Law (Section 111 of Public Law 110-173) requires group health plan insurers, third party administrators, and plan administrators or fiduciaries of self-insured/selfadministered
group health plans to report, as directed by the Secretary of the Department of Health and Human Services, information that the Secretary requires for purposes of coordination of benefits…Two key elements that will be required to be reported are SSNs (or HICNs) and EINs.” Source:https://www.cms.hhs.gov/MandatoryInsRep/Downloads/CollectionofSSNsHICNsandEINsTINsALERT.pdf
If you do not have all of the SSNs for your employees’ dependents, a dependent eligibility audit can be a great time to gather this information.
