GBS Health & Benefits Compliance
ACA 1094/1095 Reporting
Steps when you receive a TIN error response
After 1094/1095 forms are submitted electronically to IRS through the AIR system, a submitter will receive a response. There are a variety of possible messages, but typically when there is a TIN mismatch, the response will be “accepted with errors”. Depending on your vendor, you may not see the actual IRS response, and instead you may simply hear from the vendor that your submission has a TIN mismatch issue. Either way, an “accepted with errors” message means your submission was accepted but there are additional steps you need to take, and those steps vary, depending on the facts and reason for the mismatch. Generally, you are expected to correct the data and send a correction to the IRS, where applicable, but there are times when the only steps you will take will be internal.
The following provides general guidance on TIN validation errors and next steps:
What does this mean?
A TIN validation error generally indicates that the employee’s name and SSN (or other TIN), or those of any covered individuals (e.g., dependents), do not match IRS records. This can occur due to:
- A typographical error in the name or TIN
- A mismatch in how the name appears (e.g., due to a name change)
- Use of an invalid or incorrect TIN
If the individual is listed both as an employee and as a covered individual, the name/TIN mismatch must be corrected in both sections.
What should you do?
- Review your internal records (HR/payroll/benefits) to ensure the name and TIN were entered exactly as provided by the individual.
- Attempt to verify the information with the individual, if possible, including any covered dependents listed on the form.
- If the individual is no longer reachable, use the information you previously collected (e.g., W-4 or enrollment forms).
- The Social Security Number Verification Service (SSNVS) provided by the SSA may be helpful The Social Security Number Verification Service. It is an optional tool, but recommended. (Note that the separate E-Verify system is the standard on the HR employment law side to address authorization to work and immigration issues, so for ACA 1094/1095 TIN mismatch issues, use SSNVS)
If you determine the information submitted was accurate based on your records and the employee’s documentation, you may choose to submit a correction with supporting documentation or leave the submission as-is and maintain records of your good-faith effort to investigate and comply.
If no valid TIN is available for a covered individual who is not an employee e.g. dependents, you may substitute a date of birth, but this solution does not apply to the employee.
What should you do?
If you are unable to obtain corrected information from the individual (for example, they are no longer employed or responsive), and you’ve confirmed your records are accurate based on what was provided:
- Maintain documentation showing your good-faith effort to collect accurate data.
- Keep records of using SSNVS if you have used this tool.
- The IRS outlines a process of three TIN solicitations:
- Initial: At time of enrollment
- Second: Within a reasonable time if the TIN is not received
- Third: By December 31 of the following year
- (No further solicitation is required once coverage is terminated)
If you are aware that the Name/TIN combination is inaccurate, but you cannot obtain the correct information (e.g., the individual is no longer employed and unresponsive, or you suspect the original TIN was invalid), then:
- No correction is possible at this time. You are not expected to refile the form unless you obtain updated information.
- You should retain documentation showing:
- The original information provided by the employee,
- Your efforts to validate or correct the information,
- Any outreach to the individual and responses (or lack thereof),
- Any additional relevant information
- And your determination that a correction could not be made.
May 2025
This document is not intended to be exhaustive, nor should any information be construed as tax or legal advice. Readers should contact a tax professional or attorney if legal advice is needed. Although we have made every effort to provide complete, up-to-date, and accurate information in this document, such information is meant to be used for reference only. If there is any inconsistency between the information contained in this document and any applicable law, then such law will control.
