Currently for the FF-SHOP, we are experiencing an issue with including both the SSN and a Tax ID Number (TIN) on the 834 enrollment transaction. The SSN has a home at the 2100.NM1 for Member name with a "34" qualifier on the NM108 field. The problem arises when you have either an employee or a spouse that doesn't have a SSN. The only qualifiers in the 2100.NM1 are 34 and ZZ, and the situational rule for ZZ states "Value is required if National Individual Identifier is mandated for use. Otherwise, one of the other listed codes may be used."
We are trying to find a tempory work around that we could incorporate in our development for this year, as well as long term solution of getting another qualifier added to the NM108 field, such as "EI" or "MI".
Please let me know if I need to submit a Formal RFI for this issue.
The Loop 2100A Member Name NM1 only accommodates the Social Security Number or National Individual Identifier for the member being identified in this loop. An Individual Taxpayer Identification Number (ITIN) is not the same as an SSN, therefore it is not appropriate to report an ITIN using a SSN qualifier.
The Loop 2000 Member Supplemental Identifier REF can be used when sending additional identifying information on the member. Qualifier code ZZ=Mutually Defined in REF01 may be used by mutually agreeing trading partners to identify the ITIN of a member when the individual does not have an SSN.
Future versions of the 834 TR3 will accommodate reporting an ITIN in the Loop 2100A Member Name NM1.