Q: What are districts obligated to do to verify Social Security numbers (SSNs)?

A: Districts are required to ensure that names and Social Security numbers (SSN) match corresponding information in the Social Security Administration (SSA) database. This is necessary for accurate reporting of payroll information to the SSA and the Internal Revenue Service. Districts can easily verify SSA information on line.

Employees can be required to provide the district with their SSN plus their name as it appears on their Social Security card. Employees typically present their Social Security card at the time of hire, but the ability to produce the card cannot be a condition of employment. Unless a discrepancy is found, employees cannot be asked to produce the actual card.

When a district learns that an employee’s name and SSN do not match, an HR staff member can ask to see the employee’s Social Security card to ensure the SSN and name have been correctly recorded in district records. Discrepancies may be the result of an unreported name change, a change in marital status, a stolen identity, or clerical error. HR administrators should be aware that an employee whose name and number do not match should not be fired: a discrepancy does not mean an employee is ineligible to work in the U.S.

Districts are also required to verify the accuracy of SSNs if they receive a “no match” letter from the SSA. These letters are sent to employers when the information on a W-2 does not match the SSA’s database. Rules for resolving and responding to “no match” letters are currently being revised by federal agencies. As a result, “no match” letters were not sent out this year. Once the rules are finalized, HR Services will include information in the Member Library to assist districts.

The process of verifying an employee SSN should not be confused with verifying his or her identity and employment eligibility on the Employment Eligibility Verification Form (I-9 Form) or with the E-Verify system. The Form I-9 and E-Verify are the mechanisms for complying with the verification requirements of U.S. Immigration and Customs Enforcement within the U.S. Department of Homeland Security. On Form I-9, a designated district employee certifies that he or she has examined the actual documents presented by the employee and believes the documents to be valid.