| Request No. | 2018-34 | ||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Date of Request | July 25, 2018 | ||||||||||||||||||||||||
| Requester | Steering; CCCApply Redesign Workgroup; | ||||||||||||||||||||||||
| Application(s) | OpenCCC Account Creation, Edit Account, Recover Account | ||||||||||||||||||||||||
| Section / Page | Page 1 | ||||||||||||||||||||||||
| Steering Hearing Date | TBD | ||||||||||||||||||||||||
| Proposed Change to Download File | Yes* | ||||||||||||||||||||||||
| Change to Residency Logic | No | ||||||||||||||||||||||||
| Jira |
|
| Table of Contents |
|---|
| Note |
|---|
August 16, 2019: This is the official/revised 2019 change request specification for the two-part SSN revision project. This issue is currently under advisement with the Chancellor's Office (Legal) via Michael Q. Various previous requests, implementations, and updates to SSN are now stored under "Requirements" in the restricted OpenCCCApply confluence space. As these forms are consolidated, this page will be update. See below in "Supporting Documentation" for links to all existing research and references. |
Problem / Issue
Per email from Michael Quaioit, the SSN question must be implemented in the domestic version of the CCC application for admission (cite legal codes). |
Problem / Issue
The current Social Security Number question in the OpenCCC Account has long been known as a barrier for applicants; attributing factors include the overall layout design, the look & feel, the legal jargon, etc. The feedback received from students and colleges is that the question is intrusive. Many students, including noncredit students, international students, minors, etc, don't have an SSN, or if they do have one, they don't know the number. Furthermore, the layout is confusing, and NOT user-friendly. Though the question is optional, there are many state, federal and local reasons why we need students to provide their SSN.
In 2014, the IRS fined the California Community Colleges hundreds of thousands of dollars due to incorrect or missing SSNs for thousands of students. . The Chancellor's Office worked with the IRS and then released Legal Opinion 13-05 (see attached) which dictates the language and layout specifications which CCCApply implemented in September 2014.
Per IRS regulations, the SSN question must be implemented as an initial “statement” to all students and was required to include exactly what data is being collected, the purpose for collecting this data, and the consequences for not providing the data (penalties). In addition, State of California regulations required CCCApply to disclose what info needed to be collected for the CCCCO and why (shown in blue below).
In addition to the full disclosure statement and all other collection compliancy, Per Legal Opinion 13-05, CCCApply cannot “require” that students provide their SSN/TIN; likewise, per the exceptions, some students will not have the info to provide. This checkbox will alert page verification to pop up a reiteration of the “statement” and consequences per IRS requirements (SSN/TIN Encouragement).
Later in 2015, we added Taxpayer Identification Number to all the question labels and language, and "SSN Type" field was added to identify format. Validation checking will determine if the number is a TIN (begins with the number 9) or an SSN. OpenCCC Account Creation Data Dictionary will be revised to include new language, download values, etc
Business Requirements
- Collect and deliver the social security number (or taxpayer identification number) from every required applicant (other than authorized exceptions) per the legal guidelines required by the Internal Revenue Service to the College in the CCCApply application for admission;
- Move the current question from the OpenCCC Account System to the CCCApply standard application, displaying and collecting the data once per individual (CCCID). The question would only appear once and the SSN would be auto-populated as needed in subsequent applications, if needed.
- Revise and enhance the question layout and onscreen language in the current SSN section to increase engagement and streamline the student experience. The onscreen language and layout should be short, simple, and user-friendly, ensuring all requirements are met in the most streamlined way possible.
- Deliver the encrypted SSN to the college through multiple methods (downloads, Glue data delivery, reporting) and store the information securely in the Student Profile service (aka Data Lake/Remove the current SSN question from OpenCCC Account creation, edit account, and CCCApply edit account modules completely.
- Implement a streamlined, shortened layout for collecting the Social Security number in the CCCApply Standard Application and display to all students.
- Entering a SSN or TIN is optional; however, the applicant must either provide a valid SSN or TIN number or check the No SSN box to continue.
- Revise the question layout and minimize the amount of onscreen text and legal language in the current layout to remove language barriers and ease concerns from special populations, such at undocumented students.
- Move all the legal language that currently appears as "additional text" to a Help slider drawer and display the drawer when the user clicks on a hyperlink, "Why am I being asked for my Social Security number?"
- Maintain all current download fields and make no changes to the existing field formats in the Download Format Definitions file
- Deliver the encrypted SSN to the college through multiple methods (downloads, Glue data delivery, reporting) and store the information securely in the Student Profile service (aka Data Lake/Warehouse). Data would be passed to the college via application downloads and SuperGlue.
Proposed Solution: Two Options
Implement phased solution in FY19/20.
Option 1 - Keep existing legal language, but revise the layout - Immediate priority - Improve the student experience with new shortened layout , with fewer data fieldsquestions, and move existing legal text behind slider drawer (triggered by hyperlink, asking: “Why am I being asked for my social security number?”) - Move the SSN input field (Enter SSN Number) to the top of the question, and remove the fields that aren’t needed (i.e., SSN Type, Financial Aid Acknowledgement)
This option requires CO approval to place legal language in slider-drawer, versus what is currently required to be onscreen.
Option 2 - Update the Legal Language Required by IRS & State/Fed Requirements - quick solution - Support the student experience by revising the current onscreen legal language (short & legal) to ensure we are in compliance with the IRS, state, and any other federal requirements, and improve the layout of the input fields. (see comparison to CSU disclosure). NOTE: The language proposed will reference the Privacy Policy which is also being revised. See below.What about minors? Is different text needed if the applicant is a minor? Question about minors.
Quick Specs: Social Security Number Revision
- Implement new layout for SSN - as detailed Remove the current SSN question from the CCCApply Edit OpenCCC Account pages
- Implement the new SSN question layout - as detailed in OA-6441
- Revise the current SSN onscreen text as approved.
- Add legal language for SSN in the privacy policy - (pending approval)
- Add revised SSN to the Account Info page in Standard Application, but do
- Do not display the SSN question in the Noncredit Application workflow;
- Add logic on the Account Info page in the BOG to see if the SSN was collected in Apply for the student. If yes, do not display the question. If no SSN info is stored in Student Profile under CCCID, then display the SSN question in BOG and store data in Profile.
- Do not display the SSN question in the International Application.
The SSN number question currently appears in OpenCCC and then passes through CCCApply applications to the Download Client to the colleges.
In 2014, the IRS fined the California Community Colleges large fines for failing to collect SSN from students correctly, and failing to report correct SSN collected to the IRS. These penalties against the Chancellor’s Office to disclose specific information to students when collecting their SSN/TIN. See Legal Opinion 13-10
Historical Reference Information
These docs below provide some history around the layout and design of the legacy implementation:
Research Notes:
In reviewing the LEGAL information - there may be additional changes included to better serve our students.
The noncredit application does not need to include the SSN - this has been requested by NOCE as well.
The International application may not need to include the SSN - this has been requested by LACCD several times.
- When the SSN is moved out of OpenCCC and into CCCApply Standard App (which it must be asked by Federal law) - we could add logic to confirm that the SSN has been submitted (Student Profile = CCCID) and if yes, do not display the question in the SSN - pass that data to college via Glue or Report Center.
- Instead of auto-population, for security purposes, if an applicant has already provided their SSN via OpenCCC account (associated to their CCCID) or Edit Account - do not display the question, but do pass the SSN data to the college from Student Profile via DLC, GLUE, or Report Center.
Current SSN Question Language & Layout
(see below)
Click here to see screenshots of the current (legacy) implementation
SSN in Account Recovery
| Note |
|---|
Breakdown of Change Requirements
#
Description
Solutions
Notes
Revise the overall layout, look & feel, question text, hyperlink pop-up boxes, etc., of the Social Security Number question to:
Remove the "I plan to apply for financial aid" checkbox from this question/layout.
Remove the SSN Type fields <ssn_type> from the user interface, but keep the existing logic around the number type and populate the field (for download and reporting). (Example, If the logic identifies that the number entered is a Social Security number vs. the Taxpayer ID number, populate the SSN Type field value accordingly).
Keep both SSN / Confirm SSN input fields. Add field logic to the SSN input field to determine if the number entered is a SSN or TIN.
(NOTE: maintain existing field validation for SSN/TIN that currently exists today, including A) must have 9 numbers; B) if number starts with a 9, then it is a TIN; etc.
Keep the "No SSN" checkbox question/field and keep the existing language (Note - this is being reviewed by the Redesign Workgroup. The language in this question may change slightly.)
Keep the "SSN Exception" checkbox, which is conditional based on the user selecting the "No SSN" box. Keep the existing language (Note - this is being reviewed by the Redesign Workgroup. The language in this question may change slightly.)
Revise ALL onscreen text as specified:
The question prompt text should read:
Add a new hyperlink adjacent to the SSN/Confirm SSN fields that says, "Why am I being asked for my Social Security Number?"
The hyperlink pops up text box with all the legacy legal information displayed (see next requirement in this table).
See mock-up screenshot for layout
Implement or maintain the following pop-up Help text boxes with new or modified text:
New: "Why am I being asked for my Social Security Number? (Display displaced legal information when user clicks this link. See row below for details.)
Existing: Privacy Policy - keep linking this out to the OpenCCC Privacy Policy
Existing: Exceptions: (keep existing hyperlink(s) and text boxes/language)
Existing: Few exceptions (keep existing hyperlink(s) and text boxes/language)
Existing: Taxpayer Identification Number (keep existing hyperlink(s) and text boxes/language)
(Spike: Confirm this field is not used in any logic or other purposes. It could be moved to the Needs & Interests page. For the initial revision, don't remove the data field from the Download Client (DLC), but it will no longer collect data.
Add pop-up help box under a new hyperlink: "Why am I being asked for my Social Security Number?"
"Why am I being asked for my Social Security Number?" Pop-Up Help Box Hyperlink
The Social Security Number is required to claim tax credits for higher education costs known as the American Opportunity Tax Credit in accordance with the Taxpayer Relief Act of 1997.
Federal law requires the California Community Colleges to provide specific information to the Internal Revenue Service (IRS) for the purpose of filing an information return (IRS Form 1098-T “Tuition Statement”) for each student in attendance, with a few exceptions.
The information required by the IRS includes the student’s name, address, Social Security Number (SSN) or Taxpayer Identification Number (TIN/iTIN), and enrollment status, as well as the amount of tuition paid or billed, and scholarships received. (26 C.F.R. 1-60505-1(b)(2)(ii).)
Failure to provide a correct Social Security Number or TIN while claiming tax credits for specified education expenses may result in a penalty levied against the student by the IRS in the amount of $100, per year, until the missing or incorrect information is provided
(26 C.F.R. 1-60505-1(e)(4)).
In addition, California Education Code sections 68041 and 70901(b)(7) authorizes the California Community Colleges Chancellor’s Office (CCCCO) to collect information you submit through the OpenCCC Online Student Account and CCCApply Online Application for Admission for the purposes of completing and submitting California College admission applications and financial aid on your behalf.
Further, information acquired by the CCCCO is subject to the limitations set forth in the Information Practices Act of 1977 (Title 1.8 (commencing with Section 1798) of Part 4 of Division 3 of the Civil Code). Compliance with these laws is identified in the Privacy Policy.
(See CSU disclosure in the screenshot below:
"pursuant to Section 41201, Title 5, Code of Regulations, and Section 6109 of the Internal Revenue Service..- App workflow or the International Application.
Historical Reference Information
These docs below provide some history around the layout and design of the legacy implementation:
Research Notes:
In reviewing the LEGAL information - there may be additional changes included to better serve our students.
- Explore the idea of making the SSN question Opt-In/Opt-Out - default to having it off and allow colleges to turn it on or visa versa
- The noncredit application does not need to include the SSN - this has been requested by NOCE as well.
The International application may not need to include the SSN - this has been requested by LACCD several times.
- Instead of auto-population, for security purposes, if an applicant has already provided their SSN via OpenCCC account (associated to their CCCID) or Edit Account - do not display the question, but do pass the SSN data to the college from Student Profile via DLC, GLUE, or Report Center.
Pre-2020 SSN Question Language & Layout in OpenCCC
The SSN question currently appears on Page 1 of the OpenCCC Student Account System; HOWEVER, it is being removed in the upcoming OpenCCC redesign. It will move into CCCApply at that time.
The SSN is also currently used in Account Recovery. This will also change with the OpenCCC redesign. In 2020, the SSN question is slated to be removed from OpenCCC as part of the OpenCCC Account redesign project and will be moved into CCCApply (and Promise Grant) and possibly the International Application. In addition, the question may be moved into a future revision of the Student Profile Service, once OpenCCC and CCCApply are fully integrated in MyPath Portal.
(see below)
Click here to see screenshots of the current (legacy) implementation
| Expand |
|---|
SSN in Account Recovery
|
Breakdown of Change Requirements
# | Description | Solutions | Notes | ||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Revise the overall layout, look & feel, question text, hyperlink pop-up boxes, etc., of the Social Security Number question to: |
|
| |||||||||||||
Add pop-up help box under a new hyperlink: "Why am I being asked for my Social Security Number?" Spell out definitions of TINs or get rid of it? Display the "few exceptions" on screen or get rid of hyperlink? | "Why am I being asked for my Social Security Number?" Pop-Up Help Box Hyperlink The Social Security Number is required to claim tax credits for higher education costs known as the American Opportunity Tax Credit in accordance with the Taxpayer Relief Act of 1997. Federal law requires the California Community Colleges to provide specific information to the Internal Revenue Service (IRS) for the purpose of filing an information return (IRS Form 1098-T “Tuition Statement”) for each student in attendance, with a few exceptions. The information required by the IRS includes the student’s name, address, Social Security Number (SSN) or Taxpayer Identification Number (TIN/iTIN), and enrollment status, as well as the amount of tuition paid or billed, and scholarships received. (26 C.F.R. 1-60505-1(b)(2)(ii).) Failure to provide a correct Social Security Number or TIN while claiming tax credits for specified education expenses may result in a penalty levied against the student by the IRS in the amount of $100, per year, until the missing or incorrect information is provided In addition, California Education Code sections 68041 and 70901(b)(7) authorizes the California Community Colleges Chancellor’s Office (CCCCO) to collect information you submit through the OpenCCC Online Student Account and CCCApply Online Application for Admission for the purposes of completing and submitting California College admission applications and financial aid on your behalf. Further, information acquired by the CCCCO is subject to the limitations set forth in the Information Practices Act of 1977 (Title 1.8 (commencing with Section 1798) of Part 4 of Division 3 of the Civil Code). Compliance with these laws is identified in the Privacy Policy. | (See CSU disclosure in the screenshot below: "pursuant to Section 41201, Title 5, Code of Regulations, and Section 6109 of the Internal Revenue Service... §301.6109-3 IRS adoption taxpayer identification numbers.(a) In general—(1) Definition. An IRS adoption taxpayer identification number (ATIN) is a temporary taxpayer identifying number assigned by the Internal Revenue Service (IRS) to a child (other than an alien individual as defined in §301.6109-1(d)(3)(i)) who has been placed, by an authorized placement agency, in the household of a prospective adoptive parent for legal adoption. An ATIN is assigned to the child upon application for use in connection with filing requirements under the Internal Revenue Code and the regulations thereunder. When an adoption becomes final, the adoptive parent must apply for a social security number for the child. After the social security number is assigned, that number, rather than the ATIN, must be used as the child's taxpayer identification number on all returns, statements, or other documents required under the Internal Revenue Code and the regulations thereunder. | |||||||||||||
Keep the pop-up Help textbox and hyperlink for "Exceptions" in the "SSN Exceptions" checkbox | Exceptions Exceptions include students exclusively enrolled in noncredit courses, undocumented international students and nonresident aliens, unless the nonresident alien student requests that a return be provided to the IRS. (26 C.F.R. 1.60505-1(a)(2), (b)(5)(ii).) | ||||||||||||||
| Keep existing | ||||||||||||||
Keep the existing link out to the Privacy Policy (OpenCCC) | Keep existing but check that it's pointing to the correct doc. | ||||||||||||||
| |||||||||||||||
|
| no longer valid | |||||||||||||
|
| no longer valid |
SSN in the Common Application
SSN in the CSU Apply
Notes
Notes regarding "mobile support" conversion work - in-progress now for Apply, Promise, IA:
Notes
One more thing on this...on a phone or tablet, you won't see the second scrollbar for the notification because browsers for phones and tablets hide scrollbars. I'm not sure if that would be considered a plus or a minus, but that's how it'll be. It will still be scrollable though
.
Supporting Documentation
NEW Social Security Number language.CCCCO.Final.doc
ssn specifications excerpt ammedits 22515(3).doc
CURRENT Spec Details
Name | Data Field | Format | Question Text |
|---|---|---|---|
Label & Question | Prompt Text | Social Security Number (or Taxpayer ID Number) The Social Security Number is used as a means of identifying student records and to facilitate financial aid. | |
Financial Aid Interest | <fin_aid> | Checkbox |
|
IRS Legal Language | Prompt Text | The Social Security Number is required to claim tax credits for higher education costs known as the American Opportunity Tax Credit in accordance with the Taxpayer Relief Act of 1997. Federal law requires the California Community Colleges to provide specific information to the Internal Revenue Service (IRS) for the purpose of filing an information return (IRS Form 1098-T “Tuition Statement”) for each student in attendance, with a few exceptions. The information required by the IRS includes the student’s name, address, Social Security Number (SSN) or Taxpayer Identification Number (TIN/iTIN), and enrollment status, as well as the amount of tuition paid or billed, and scholarships received. (26 C.F.R. 1-60505-1(b)(2)(ii).) Failure to provide a correct Social Security Number or TIN while claiming tax credits for specified education expenses may result in a penalty levied against the student by the IRS in the amount of $100, per year, until the missing or incorrect information is provided In addition, California Education Code sections 68041 and 70901(b)(7) authorizes the California Community Colleges Chancellor’s Office (CCCCO) to collect information you submit through the OpenCCC Online Student Account and CCCApply Online Application for Admission for the purposes of completing and submitting California College admission applications and financial aid on your behalf. Further, information acquired by the CCCCO is subject to the limitations set forth in the Information Practices Act of 1977 (Title 1.8 (commencing with Section 1798) of Part 4 of Division 3 of the Civil Code). Compliance with these laws is identified in the Privacy Policy. | |
Help Boxes | hyperlink | Pop-Up Hyperlink | A Few Exceptions: Exceptions include students exclusively enrolled in noncredit courses, undocumented international students and nonresident aliens, unless the nonresident alien student requests that a return be provided to the IRS. (26 C.F.R. 1.60505-1(a)(2), (b)(5)(ii).) Taxpayer Identification Number: Privacy Policy: Hyperlink to the existing Privacy Policy. Opens in a new page Other Exceptions |
SSN Type | <ssn_type> | Radio Buttons | Please indicate the type of number:
|
SSN / Confirm SSN | <ssn> | Text Input | By providing my Social Security Number (or Taxpayer Identification Number) below, or indicating that I do not have a Social Security Number or decline to provide one at this time, I confirm that I have read and understand the federal regulations provided above, and the state regulations provided in the privacy policy. Your Social Security Number must be accurate to ensure the integrity of your permanent record and to avoid potential penalties imposed by the IRS for providing an incorrect number. Social Security Number (or Taxpayer Identification Number) Repeat Social Security Number (or Taxpayer Identification Number) (This statement ensured we are complying with regulations by having students “confirm” they have read and understand exactly what data is being collected and why, and the consequences for not complying with federal regulations. By wording the confirmation statement in this way, we were also removing the need for another download field.) |
Decline to State | <no_ssn> | Checkbox |
|
International Exception | <ssn_exception> | Checkbox |
|
For Internal Use Only
Related JIRAs | ||||||||
|---|---|---|---|---|---|---|---|---|
|