One issue that can hinder reconciliation of APTC through tax filing is use of an SSN that does not belong to the enrollee. Our preliminary analysis of federal Marketplace data identified over 29,000 SSNs (0.21 percent of SSNs that received APTC) with more than 365 days of insurance coverage with APTC in plan year 2023. For example, the most frequently used SSN in plan year 2023 was used to receive subsidized insurance coverage for over 26,000 days (over 71 years of coverage) across over 125 insurance policies. Further, our preliminary analysis identified nearly 66,000 SSNs (0.37 percent of SSNs that received APTC) with more than 366 days of insurance coverage with APTC in plan year 2024.⁽³⁶⁾ This overuse can occur because of identity theft and synthetic identity fraud, as well as data entry errors.⁽³⁷⁾ Given complexities around identifying the true SSN-holder, we are further examining these cases and other instances of apparently overlapping coverage as part of our ongoing work.
According to CMS officials, the federal Marketplace does not prohibit new enrollments that use an SSN that is already enrolled. They further explained this is done to help ensure that the actual SSN-holder can enroll in insurance coverage in cases of identity theft or data entry errors. These officials told us that the federal Marketplace uses a logic model that analyzes various elements of personally identifiable information to distinguish individual applicants and enrollees. They added that they apply this model on a monthly basis to deduplicate enrollments. Further, applications with SSNs already enrolled should be addressed through CMS’s existing data matching inconsistency processes, where applicants provide documentation to support application information that could not be originally verified.
For example, enrollees with these overused SSNs should be identified through CMS’s existing data matching inconsistency processes and required to submit documentation to substantiate their SSNs. This is because multiple identities with different personally identifiable information will not match SSA records for the same SSN. However, our analyses and identification of enrollments with these overused SSNs suggests that the data matching inconsistency processes may not always function as expected. We are reviewing the federal Marketplace’s data matching inconsistency processes, including overused SSNs, as part of our ongoing work.
townhall.com
