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Why Does ADP Need Social Security Numbers For Dependents?

The Medicare Secondary Payor Mandatory Reporting Provisions have been finalized and require certain information pertaining to group health plan participants who are “active covered individuals”, including their social security numbers, be gathered and submitted to the Centers for Medicare and Medicaid Services (CMS). Additional information can be found at the CMS website at: www.cms.hhs.gov/MandatoryInsRep.

“Active covered individuals” are defined by CMS as the following:

  • Effective January 1, 2009 through December 31, 2010, all individuals covered in a group health plan age 55 through age 64 who have coverage based on their own or a family member’s current employment status.
  • Effective January 1, 2011 and after, all individuals covered in a group health plan age 45 through 64 who have coverage based on their own or a family member’s current employment status.
  • All individuals covered in a group health plan age 65 and older who have coverage based upon their own or a spouse’s current employment status.
  • All individuals covered in a group health plan who have been receiving kidney dialysis or who have received a kidney transplant, regardless of their own or a family member’s current employment status.
  • All individuals covered in a group health plan who are under age 55 (age 45 effective January 1, 2011), are known to be entitled to Medicare, and have coverage in the plan based on their own or a family member’s current employment status.

Per CMS guidance, individuals receiving coverage under the group health plan as a result of a COBRA election are NOT considered “active covered individuals” unless such individuals have been receiving kidney dialysis or have received a kidney transplant.

Effective January 1, 2009 and specifically in relation to social security numbers, insurers or third-party administrators of group health plans or a plan administrator or fiduciary of a self-insured plan must:

  • Gather and submit to CMS via the first quarter report of 2009, the social security numbers of ALL subscribers (employees) who are “active covered individuals” currently enrolled under the group health plan.
  • Gather and submit to CMS, on a quarterly basis, the social security number of any new subscribers and dependents (i.e. spouse / child) of subscribers who are “active covered individuals” whose initial date of coverage under the plan is on or after January 1, 2009.
  • Gather and submit to CMS, no later than the first quarter report of 2011, the social security numbers of any dependents of a group health plan subscriber who are “active covered individuals” whose first date of coverage under the plan was prior to January 1, 2009.