Page Comparison

Problem / Issue

The current The Social Security Number question, that currently appears in the OpenCCC Account system, has long been known as a barrier for applicants; attributing factors include the overall layout design, the look & feel, the legal jargonlanguage, etc. The feedback received from students and colleges is that the question is intrusivethe legal language is overwhelming and the layout is confusing. Many students, including noncredit students, international students, undocumented, 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 that do not have a SSN, are being forced to navigate through the legal information and penalties information - even though they are legitimate exceptions and are not required to have one or provide one. Although providing a SSN is optional, there are many reasons why students that have a SSN must provide it.

History Behind the Current Question

In 2014, colleges within the California Community Colleges were fined hundreds of thousands of dollars, each, because they were not providing SSNs for students, or they were providing bad numbers. The Chancellor's Office advocated for the colleges with the IRS and then released 1098-T Legal Opinion 13-05 (see attached) which dictates the language and layout specifications which CCCApply implemented  which dictated the specific language that must appear on-screen in the application 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 

1. 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;
2. 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. 
3. 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.
4. 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. 

What about minors? Is different text needed if the applicant is a minor? Question about minors.

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Quick Specs:  Social Security Number Revision

1. Implement new layout for SSN - as detailed in OA-6441
2. Revise the current SSN onscreen text as approved.
3. Add legal language for SSN in the privacy policy - (pending approval)
4. Add revised SSN to the Account Info page in Standard Application, but do not display in the Noncredit Application workflow;
5. 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.
6. 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: 

1. 13-05 1098 Penalties.doc

2. NEW Social Security Number language.CCCCO.Final.doc

3. ssn specifications excerpt ammedits 22515(3).doc

4. 2014-02 Revise SSN TIN Question on Application.doc

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 

Click here to see screenshots of the current (legacy) implementation

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SSN in Account Recovery

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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:

1. Remove the "I plan to apply for financial aid" checkbox from this question/layout.

2. 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).

3. 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.

4. 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.)

5. 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.)

6. Revise ALL onscreen text as specified:

   1. The question prompt text should read:

   2. 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).

7. See mock-up screenshot for layout

8. Implement or maintain the following pop-up Help text boxes with new or modified text:

   1. 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.)

   2. Existing:  Privacy Policy - keep linking this out to the OpenCCC Privacy Policy

   3. Existing:  Exceptions: (keep existing hyperlink(s) and text boxes/language)

   4. Existing:  Few exceptions (keep existing hyperlink(s) and text boxes/language)

   5. Existing:  Taxpayer Identification Number (keep existing hyperlink(s) and text boxes/language)

1. (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:

Proposed Design Drafts

Link to mock-up: https://xd.adobe.com/view/9a4384cf-dace-4baa-4c46-83ee0de6e393-ec72/?fullscreen

Proposed Solutions

Based on initial meeting discussion with CCC Foundation, Immigrants Rising, and CCCCO representatives, draft up another option or two - in addition to the main layout redesign (Option A) and test with students. The Foundation, Immigrants Rising and possibly CCGI - could all provide opportunities for student testing and feedback fairly quickly.  Time is of the essence in order to meet the OpenCCC Redesign launch and CCCApply integration with that schedule. 

Currently, CCCApply is working with the CCC Foundation on a design that incorporates all of the previously proposed layouts into a clickable, high-fidelity mock-up.  

Please read about the mock-up:

• The mock-up is an Adobe XD export meant to represent and mimic the behaviors of a real website, it is not a real website.
• While the SSN question is currently in OpenCCC, not CCCApply, anticipating the integration roadmap this mock up shows SSN with anticipated placement in CCCApply (but could also be added to OpenCCC in the interim)
• The team only focused on the SSN section of the application — at this time.
• Not all links in the mock-up are live, just the options in the SSN section (pull downs, pop-up window, etc.)

(important note: to select “No” it is best to mouse around the “Yes” option; hit the Cancel button or Reload the page to simulate the optional behavior paths. This is a software limitation, not design)

Link to mock-up: https://xd.adobe.com/view/9a4384cf-dace-4baa-4c46-83ee0de6e393-ec72/?fullscreen

Historical Reference Information

These docs below provide some history around the layout and design of the legacy implementation: 

1. 13-05 1098 Penalties.doc

2. NEW Social Security Number language.CCCCO.Final.doc

3. ssn specifications excerpt ammedits 22515(3).doc

4. 2014-02 Revise SSN TIN Question on Application.doc

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.

• 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

EXISTING SSN LAYOUT IN OPENCCC screenshots of the current (legacy) implementation

Breakdown of Change Requirements

1. Phase I: Revise the current SSN question in the OpenCCC Account (legacy) system, including the Edit Account system in CCCApply.
   
   
2. Phase II: Remove the revised question from NEW OpenCCC system and move onto the CCCApply and place on the Account Information section of the Account Info/Mailing page.
   
   
3. Implement a streamlined, shortened layout for collecting the Social Security number in the CCCApply Standard Application and display to all students. (Work with stakeholders to determine if SSN should appear in the Noncredit application, Promise Grant and International Applications, too.)
   (see below)
4. See breakdown of requirements below.

Quick Specs:  Social Security Number Revision

1. Remove the current  SSN question from the CCCApply Edit OpenCCC Account pages 
2. Implement the new SSN question layout - (Update  OA-6441)
3. Add legal language for SSN in the privacy policy - (pending approval)
4. Add revised SSN to the Account Info page in Standard Application
5. Do not display the SSN question in the Noncredit App workflow or the International Application. < pending approval.

REQUIREMENTS - New Layout from Foundation 11/26/19

SSN in the Common Application

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SSN in the CSU Apply

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Notes

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Notes

Supporting Documentation

NEW Social Security Number language.CCCCO.Final.doc

ssn specifications excerpt ammedits 22515(3).doc

CURRENT Spec Details

For Internal Use Only