2.7.1  Providing Social Security Numbers

Every member of the W-2 Group, including newborns, must provide a Social Security Number (SSN), or provide proof that any W-2 Group member without an SSN has applied for one, unless the individual is initially exempt. An individual is initially exempt if he or she does not have an SSN, does not have a work authorization, and is a member of 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; or

2.             Certified, foreign-born victims of trafficking; or

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 his or her immigration status paperwork has been revised.

An individual who is initially exempt must continue to complete the necessary steps for obtaining an SSN in order to remain eligible for W-2. W-2 agencies must assist the individual with these steps if the individual requires assistance. (See 4.1.3)

See 4.1.2 for suggested sources of allowable verification.

Once an SSN application date is verified, the individual has at least 6 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 7th 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, CWW will prompt the FEP or IM worker to collect the SSN anytime the FEP or IM worker completes an Intake, Review/Renewal, or Program Add beginning in the 7th full calendar month and ending in the 13th full calendar month.

Note: The timeframe described above also applies to individuals who are initially exempt. For initially exempt individuals, the individual has at least 6 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 2019. The IM worker previously verified that her son Johnny’s SSN application date is February 10, 2018. Because the SSN application date is more than 6 full calendar months in the past at the time of the W-2 Intake, CWW will prompt the FEP to pend for or enter Johnny’s SSN.

 

EXAMPLE 2:  Moira applies for W-2 in January 2019. The IM worker previously verified that her son Johnny’s SSN application date is August 10, 2018. Because the SSN application date is less than 6 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 Johnny’s SSN.

At the June 2019 W-2 review, the SSN application date will be more than 6 full calendar months in the past. Therefore, CWW will prompt the FEP to pend for or enter Johnny’s SSN.

 

EXAMPLE 3:  Moira applies for W-2 in January 2019. The IM worker previously verified that her son Johnny’s SSN application date is August 10, 2018. Because the SSN application date is less than 6 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 Johnny’s SSN.

In March 2019, the IM worker completes an IM renewal. Because Johnny’s SSN application date is more than 6 full calendar months in the past at the time of the IM renewal, CWW will prompt the IM worker to pend for or enter Johnny’s SSN.

 

EXAMPLE 4:  Moira applies for W-2 in January 2019. The IM worker previously verified that her son Johnny’s SSN application date is August 10, 2018. Because the SSN application date is less than 6 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 Johnny’s SSN.

However, Moira informs the FEP that Johnny received his SSN. The FEP enters Johnny’s SSN into CWW and the SOLQ-I data exchange verifies Johnny’s SSN. The requirement that all individuals in the W-2 Group must provide a SSN has been met.

 

EXAMPLE 5:  Moira applies for W-2 in January 2019. The IM worker previously verified that her son Johnny’s SSN application date is November 10, 2018. Because the SSN application date is less than 6 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 Johnny’s SSN.

Moira loses W-2 eligibility in April 2019. In June 2019, Moira reapplies for W-2. Because Johnny’s SSN application date is now more than 6 full calendar months in the past, CWW will prompt the FEP to pend for or enter Johnny’s SSN.

Note: Because a W-2 eligibility review is required every 6 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. Because any driver flow initiated by any worker will prompt the worker to pend for or enter the SSN when the SSN application date is more than 6 full calendar months in the past, it will be rare that the 13 month duration is reached.

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 that disclosure is mandatory for eligibility determination, how the agency will use the number, and under what statutory or other authority the agency is requesting the number. A sample statement follows:

Provision of your SSN or cooperation in applying for a SSN is required to determine eligibility for Wisconsin Works (W-2). The number you provide to the agency will be verified through a computer matching program to monitor compliance with program regulations and for program management. Wisconsin Statutes 49.145 (2)(k).

 

 

History: Release 19-03; Release 16-01; Release 13-01.