From Independence Blue Cross:

As you may know, the Affordable Care Act (ACA) requires all health insurers to report certain information about health care coverage to the Internal Revenue Service (IRS) for individuals with fully insured commercial health plans.

This information includes an individual’s Tax Identification Number, which is typically the Social Security Number (SSN). The purpose of the IRS reporting is to help ensure that Americans have minimum essential coverage as required by the ACA. This is commonly referred to as the individual mandate.

Independence Blue Cross (Independence) has determined that we do not have SSNs on file for some of your customers’ employees and/or their covered dependents. The ACA rules state that Independence must attempt to obtain missing SSNs from health plan subscribers in fully insured customer groups only. Employers who provide self-funded health care coverage to their employees are responsible for their own data collection and reporting to the IRS.

How Independence will obtain missing SSNs
We will mail a subscriber letter and form with a postage-paid envelope to subscribers in your fully insured customer groups before December 31, 2014, as stated in the ACA rules. We are asking subscribers to provide the required information no later than two weeks from receipt of the letter. We are providing members with a write-in option only at this time for tracking and audit purposes.


To inform  fully insured customers of the ACA minimum essential coverage reporting requirements and our outreach to their employees, we will send a group letter in early December.

Protecting our members’ privacy is a priority
We understand members may have concerns about sharing SSNs. We take every possible measure to safeguard our members’ personal information, and we are working with a trusted third-party vendor to securely collect and report their personal information to the IRS.

We are using the information reported to the IRS to provide your fully insured customers’ employees with an IRS Form 1095-B. To verify their health care coverage, they will need this form to file their federal income tax return each year, beginning in 2016 for tax reporting year 2015. If we do not have SSNs to accurately report health care coverage status, your customers’ employees may experience issues filing their tax return.

Resources to help you talk to your customers
We have prepared a Fact Sheet/FAQ to help you learn more about ACA requirements for minimum essential coverage reporting and to address questions. Your Independence account executive can also provide you with a list of your impacted customer groups.

As always, we appreciate the work brokers do to help Independence ensure that your customers and their employees are in compliance with the ACA.

If you have any questions, please contact your Total Benefit Solutions account manager at (215)355-2121.