One of the most common types of ACA e-filing errors returned from the IRS AIR system are TIN validation errors.
What causes a TIN Validation Error?
This will happen when the last name and SSN submitted in your filing doesn’t match what the IRS has on file, and this can happen for the following reasons:
- A maiden name was used when married name is registered with the SSA (or vice-versa)
- A Hispanic last name was used where 2 last names are common. In this case, the first last name listed in the last name field must be the one registered with the SSA.
- There is a typo in the last name or SSN field.
- An employer EIN mismatch on the 1094-C in Part I and also in Part IV of the 1094-C for Aggregate ALEs. (Note: This can also cause TIN validation errors in the associated 1094-Cs for remaining ALE members.) More Information…
How do I prevent these errors going forward?
The best fix for TIN validation issues is to catch them before you submit your filings to the IRS. We strongly recommend verifying the TINs of all new employees and re-verifying existing employee’s TINs annually to catch any changes or updates.
If you are a BoomTax customer, you will receive 10 free verifications by registering with our affiliate TINCorrect:
What is error code 1095C-010-01?
This is new for Tax Year 2016 and this indicates that the employee is the source of the TIN validation error.
This is new for Tax Year 2017 and this indicates that the employee’s covered individual is the source of the TIN validation error. The IRS will now tell you which covered individual triggered the error to help with correcting this (unlike previous years).
How do I fix this?
Depending on the type of issue, here are some ways to correct a TIN validation error:
- Verify the data you are filing matches a signed W-9 or I-9.
- Contact your employees to get the correct information and document this thoroughly. According to the IRS:
Due to privacy/disclosure issues, we can only inform you that the name and social security number do not match our database. Ask your client to double check the information and if he still believes there is no error, have his employees contact IRS customer service who can direct them properly. You or your client won’t be able to act on the taxpayer’s behalf without a proper POA so that is why we recommend that the employees in question call IRS to confirm what name and SSN is on file for them. The customer service number is 1-800-829-1040, or they can contact their local IRS office. There are also specific numbers per state on IRS.gov they can use if they wish. Have them visit this link – https://www.irs.gov/help/contact-your-local-irs-office for those numbers.
- Try alternate last names. Remember, only the first 4 letters of the last name are looked at for determining an IRS match, so if a last name like Smith-Doe doesn’t match, Doe-Smith may work.
- Remove the SSN for covered individuals on erred records, and use the date of birth instead (as long as you have attempted to solicit the correct TIN).
- Correct your employer EIN and/or name (if the error happens on a 1094-C). You will also want to make sure to update the Part IV Aggregate ALE section in all affected filings as well. More Information…
I can’t fix this issue. What now?
In some cases, it may not be possible to fix a TIN validation error. If an employee has left the employer and can’t be contacted, they may not be able to get an up-to-date TIN. In this case, the IRS has specified that you should follow (and document) the TIN solicitation process as follows:
- Make an initial solicitation of recipient and covered individuals’ TINs at the time of enrollment unless you already have the required TINs.
- If you do not receive the TINs, the first annual solicitation is generally required by December 31 of the year in which enrollment with the recipient begins (January 31 of the following year if the enrollment begins in December).
- Generally, if TINs are still not provided, a second solicitation is required by December 31 of the following year. If TINs are still not provided, no further solicitation is required.
I’m still not sure about all of this, I have special circumstances, etc…
If you have any questions or doubts about your specific situation, we recommend consulting with a licensed tax professional.
BoomTax does not provide tax or legal advice. Any information contained in this article is strictly for introductory/educational purposes. Always consult with a tax or legal professional for actionable guidance.