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Wisconsin Department of Children and Families Wisconsin Works (W-2) Manual |
2.7.1.1 Initial SSN Exemptions
2.7.1.2 Timeframe for Providing an SSN
Every W-2 Group member, including newborns, must provide a Social Security Number (SSN), or proof that they have applied for one, unless the individual is initially exempt.
2.7.1.1 Initial SSN Exemptions
An individual is initially exempt if they do not have an SSN, do not have a work authorization, and belong to one of the following qualified non-citizen groups:
1. Cuban/Haitian entrants, as defined in section 501(e) of the Refugee Education Assistance Act of 1980;
2. Certified, foreign-born victims of trafficking;
3. Parolees (alien paroled into the U.S. for at least one year under section 212(d)(5) of the Immigration and Nationality Act (INA) );
4. Certain battered aliens who meet the requirements of 8 U.S.C. s. 1641(c); or
5. Any qualified non-citizen (see 2.4.2) who cannot apply for an SSN until their immigration status paperwork has been revised.
An initially exempt individual must continue working towards obtaining an SSN to remain eligible for W-2. If assistance is needed, the W-2 agency must help the individual complete the process. (See 4.1.3)
See 4.1.2 for recommended sources of allowable verification.
2.7.1.2 Timeframe for Providing an SSN
Once an SSN application date is verified, the individual has at least six full calendar months from the SSN application date to provide the SSN. The SSN must be provided by the end of the 13th full calendar month after the month of the SSN application date.
The FEP may collect the SSN at any point beginning in the seventh full calendar month and ending in the 13th full calendar month. This policy aligns with Health Care and FoodShare policy.
To support the policy of all three programs, beginning in the seventh full calendar month and ending in the 13th full calendar month, CWW will prompt the FEP or IM worker to collect the SSN anytime the FEP or IM worker completes an:
Note: The timeframe described above also applies to individuals who are initially exempt. For initially exempt individuals, the individual has at least six full calendar months from the W-2 Initial Exemption Date in CWW to provide the SSN. The SSN must be provided by the end of the 13th full calendar month after the month of the W-2 Initial Exemption Date in CWW.
EXAMPLE 1: Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is February 10, 2024. Because the SSN application date is more than six full calendar months in the past at the time of the W-2 intake, CWW will prompt the FEP to pend for or enter Hashim’s SSN.
EXAMPLE 2: Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is August 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
At the June 2025 W-2 review, the SSN application date will be more than six full calendar months in the past and CWW will prompt the FEP to pend for or enter Hashim’s SSN.
EXAMPLE 3: Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is August 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
In March 2025, the IM worker completes an IM renewal. Because Hashim’s SSN application date is more than six full calendar months in the past at the time of the IM renewal, CWW will prompt the IM worker to pend for or enter Hashim’s SSN.
EXAMPLE 4: Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is August 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
However, Moira informs the FEP that Hashim received his SSN. The FEP enters Hashim’s SSN into CWW and the SOLQ-I data exchange verifies Hashim’s SSN. The requirement that all individuals in the W-2 Group must provide an SSN has been met.
EXAMPLE 5: Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is November 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
Moira loses W-2 eligibility in April 2025 and reapplies for W-2 in June 2025. Because Hashim’s SSN application date is now more than six full calendar months in the past, CWW will prompt the FEP to pend for or enter Hashim’s SSN.
Note: Because a W-2 eligibility review is required every six months, the latest that CWW would prompt the FEP to pend for or enter the SSN is the 12th calendar month after the SSN application date or the W-2 Initial Exemption Date in CWW. Therefore, the latest possible verification deadline would occur in the 13th calendar month after the SSN application date or the W-2 Initial Exemption Date in CWW.
If the W-2 agency determines that a W-2 Group member has refused to provide or apply for an SSN, the entire W-2 Group is ineligible for W-2.
W-2 agencies must only use SSNs and personally identifiable information for the direct administration of the program. Each time a FEP requests an SSN, the FEP must inform the individual:
1. That disclosure is mandatory for eligibility determination;
2. How the agency will use the number; and
3. Under what statutory or other authority the agency is requesting the number.
See below for an example statement:
Provision of your SSN or cooperation in applying for an SSN is required to determine eligibility for Wisconsin Works (W-2). The number you provide to the agency will be verified for program management. Wisconsin Stat. s. 49.145 (2)(k).
History: Release 25-03; Release 19-03; Release 16-01; Release 13-01.