| Request No. | 2019-37 |
|---|---|
| Date of Request | 5-31-19 |
| Requester | Emily Gerofsky - CCC Foundation for Immigrants Rising |
| Application(s) | Standard |
| Section / Page | Citizenship |
| Steering Hearing Date | 8.13.19 (sub-committee meeting coming) |
| Proposed Change to Download File | TBD |
| Proposed Change to Residency Logic | TBD |
| Table of Contents |
|---|
Problem / Issue
Proposed Edits to CCCApply from Immigrants Rising
The advocacy organization is "Immigrants Rising" - which is working closely with the Foundation on Dreamers, undocumented students - has reviewed the CCCApply application and found several issues and highlighted several concerns regarding accessibility of the application for un-documented students.
| Note |
|---|
10/4/19: At the time this change request was received from Immigrants Rising in May, the Tech Center was already discussing options for streamlining the question, including the legal language that appears on screen. The revision planned would remove two fields from the layout, but would still maintain all existing data fields currently being downloaded in the SSN set of fields. The language would not change, but would be placed almost entirely behind a pop-up hyperlink within the SSN question. As the changes to the SSN have not yet been developed, the suggestions from Immigrants Rising are being taken under consideration now. |
Summary of Proposed
SolutionThe document contains a series of proposed changes. Each one is listed below with a summary of the response from CCCApply.
Social Security Number
Concern: "There is a lot of language in the question and if your eye is skimming it, key words are” required” “federal law”, “failure to provide” “penalty levied against the student” which could create a lot of fear."
Our response: We have a comprehensive revision proposed for the SSN question that has already passed the preliminary approval but a second review by Immigrants Rising would be ideal.
The proposed revision includes a new streamlined layout, with all the required legal language moved to a slider drawer (accessed by a series of hyperlinks).
None
No additional changes beyond what is already planned for SSN revision.
NOTE: At this time, we have not been able to get Legal Office help on whether any of the existing legal language can be removed from the question/application; therefore, none of the language has been changed or removed, we've just placed it behind hyperlinks and help icons. See below.
This language would appear when the user clicks on the hyperlink, "Privacy Policy?"
PROBLEM: Currently, the only existing hyperlink for "Privacy Policy" is within text that is to be moved into the slider drawer.
We would need to expose the link in the onscreen text, I believe, to streamline access to this information.
Acknowledge Financial Aid Checkbox
The sentence that reads “I plan to apply for admission to college or financial aid” directly under SSN could easily lead students to believe that an SSN is required for admission or fin aid, which is not true.
Suggestion: Add However, it is not required for admission after “The SSN... facilitate financial aid.”
Our response: This checkbox question is gone or going away in the revision, so the new language proposed will not be included in question text.
The <ack_fin_aid> flag behind the checkbox was removed several years ago, and therefore no data field needs to be removed by the college.
CCCApply Privacy Policy is outdated;
Privacy policy does not include FERPA or SB 54, only info practices act of 1977.
Suggestion: Add FERPA and SB54 to privacy policy.
Our Response: This change is on the roadmap. The CCCTC Communications team is working on a combined MyPath - CCCApply-OpenCCC privacy policy and Terms of Use. This suggestion will be passed on to that team.
Federal Statement about SSN Exceptions
A lot of students get confused about “non-resident aliens” And believe that undocumented students fall into this category.
Suggestion: Add the following after: “Federal law requires...... with a few exceptions” including students in noncredit classes, international students, undocumented students and non-resident aliens.
Our Response
The text in the SSN Exception question can be revised. We will add "students in noncredit classes and undocumented students"...to our existing language.
It should read:
"...Changes
- Revise language and layout of the SSN number
- Revise language in the Financial Aid Acknowledgment checkbox
- Revise language in the SSN Type question
- Privacy Policy needs to be updated
- Add Link to IRS for Nonresident Aliens
- Move up the SSN Exceptions question
- Encouragement to Provide SSN
- Fear of Disclosing Personal Information in Parent/Guardian Information Section
- Add Language about Discriminatory Practices up under ? Gender / Citizenship/Military sections?
- “No documents” is very small font
- Visa Type: Other
- ADD to “California Residence” for Tuition Purposes
- Support for Undocumented Students
See also, language for SB 68. Should we make Citizenship language stronger?
Proposed Solution
The document contains a series of proposed changes. Each one is listed below with a summary of the response from CCCApply.
| Concern & Immigrants Rising's Suggestion | CCCApply's Response | Requirements | |
|---|---|---|---|
Social Security Number Concern: "There is a lot of language in the question and if your eye is skimming it, key words are” required” “federal law”, “failure to provide” “penalty levied against the student” which could create a lot of fear."
| Our response: We have a comprehensive revision proposed for the SSN question that has already passed the preliminary approval but a second review by Immigrants Rising would be ideal. The proposed revision includes a new streamlined layout, with all the required legal language moved to a slider drawer (accessed by a series of hyperlinks).
| None No additional changes beyond what is already planned for SSN revision. NOTE: At this time, we have not been able to get Legal Office help on whether any of the existing legal language can be removed from the question/application; therefore, none of the language has been changed or removed, we've just placed it behind hyperlinks and help icons. See below. | |
| This language would appear when the user clicks on the hyperlink, "Why am I being asked for my Social Security Number?" | ||
| This language would appear when the user clicks on the hyperlink, "Penalties" | ||
| This language would appear when the user clicks on the Hover Help question mark icon next to the Social Security Number field or the Confirm Social Security Number field. | ||
| This language would appear when the user clicks on the hyperlink, "Privacy Policy?" PROBLEM: Currently, the only existing hyperlink for "Privacy Policy" is within text that is to be moved into the slider drawer. We would need to expose the link in the onscreen text, I believe, to streamline access to this information. | ||
Acknowledge Financial Aid Checkbox The sentence that reads “I plan to apply for admission to college or financial aid” directly under SSN could easily lead students to believe that an SSN is required for admission or fin aid, which is not true. Suggestion: Add However, it is not required for admission after “The SSN... facilitate financial aid.” | Our response: This checkbox question is gone or going away in the revision, so the new language proposed will not be included in question text. | No additional changes beyond what is already planned for SSN revision. | |
CCCApply Privacy Policy is outdated; Privacy policy does not include FERPA or SB 54, only info practices act of 1977. Suggestion: Add FERPA and SB54 to privacy policy. | Our Response: This change is on the roadmap. The CCCTC Communications team is working on a combined MyPath - CCCApply-OpenCCC privacy policy and Terms of Use. This suggestion will be passed on to that team. | REQUIREMENT: Update Privacy Policy & Terms of Use. (Under determination) | |
Federal Statement about SSN Exceptions A lot of students get confused about “non-resident aliens” And believe that undocumented students fall into this category. Suggestion: Add the following after: “Federal law requires...... with a few exceptions” including students in noncredit classes, international students, undocumented students , and non-resident aliens, and other exceptions." We can also increase the font size in the question and additional information text. | Our Response The text in the SSN | language that is staying with SSN Revision change.||
Add Link to IRS for Nonresident Aliens Suggestion: Add a link to nonresident aliens: (the IRS definition seems like a good one: https://www.irs.gov/individuals/international-taxpayers/taxation-of-nonresident-aliens) | Our Response: It's NOT our policy to include links in the CCCApply applications which takes the user away from the application, and given the amount of text we are already placing behind the hyperlink, we would rather have colleges send an email or notification to students who indicate they are "Exceptions" by clicking the "SSN Exceptions" checkbox after stating they have no SSN. However, I do agree that the IRS information provided in the link is valuable for the colleges and could be transferred into a MyPath checklist notification. | N/A | |
Move up the SSN Exception question and text “Check this box” immediately below the SSN Type field and prompt text, "Please indicate the type of number: SSN or Tax ID Number".
| Our Response: The SSN Type field is being removed from display to the end user. Logic is being added to the SSN input text fields to determine which type of SSN is being entered. SSN's never begin with the number 9. Taxpayer ID's ONLY begin with the number 9. This field will be auto-populated depending on which type of number is entered. | None No additional changes beyond what is already planned for SSN revision. | |
Encouragement to Provide SSN Even though I've indicated no SSN or ITIn in account creation, it still tells me it’s important to provide one in my school application. Suggestion: Use a conditional formula to program to determine if it ask me again if I don’t have a social security number. | Our Response: We removed the SSN Encouragement language (nudge) pop-up in September 2018. | N/A | |
Exception question can be revised. We will add "students in noncredit classes and undocumented students"...to our existing language. It should read: "...including students in noncredit classes, international students, undocumented students, non-resident aliens, and other exceptions."
| REQUIREMENT:
| ||
Add Link to IRS for Nonresident Aliens Suggestion: Add a link to nonresident aliens: (the IRS definition seems like a good one: https://www.irs.gov/individuals/international-taxpayers/taxation-of-nonresident-aliens) | Our Response: It's NOT our policy to include links in the CCCApply applications which takes the user away from the application, and given the amount of text we are already placing behind the hyperlink, we would rather have colleges send an email or notification to students who indicate they are "Exceptions" by clicking the "SSN Exceptions" checkbox after stating they have no SSN. However, I do agree that the IRS information provided in the link is valuable for the colleges and could be transferred into a MyPath checklist notification. | N/A | |
Move up the SSN Exception question and text “Check this box” immediately below the SSN Type field and prompt text, "Please indicate the type of number: SSN or Tax ID Number".
| Our Response: The SSN Type field is being removed from display to the end user. Logic is being added to the SSN input text fields to determine which type of SSN is being entered. SSN's never begin with the number 9. Taxpayer ID's ONLY begin with the number 9. This field will be auto-populated depending on which type of number is entered. | None No additional changes beyond what is already planned for SSN revision. | |
Encouragement to Provide SSN Even though I've indicated no SSN or ITIn in account creation, it still tells me it’s important to provide one in my school application. Suggestion: Use a conditional formula to program to determine if it ask me again if I don’t have a social security number. | Our Response: We removed the SSN Encouragement language (nudge) pop-up in September 2018. | N/A | |
Fear of Disclosing Personal Information in Parent/Guardian Information Section Students are worried to put in their parents’ information without knowing that it is protected under federal and state law. Information about residency could cause confusion about eligibility for AB540 and SB68 Suggestions:
| REQUIREMENT: Update Our Response: Update the text in the Parent/Guardian Information section (additional information) as suggested to support student identity and reduce ambiguity.
| Sexual Orientation & Transgender Students are concerned that it is unsafe to state this information and don’t know how it will be shared Suggestion: Add this language under the citizenship box:
| Our Response: REQUIREMENT: Update the text in the Parent/Guardian Information section (additional information) as suggested to support student identity and reduce ambiguity.
|
Sexual Orientation & Transgender Students are concerned that it is unsafe to state this information and don’t know how it will be shared Suggestion: Add this language under the citizenship box:
| REQUIREMENT: Our Response: Add this language under the citizenship box:
| REQUIREMENT: Update the language in Gender section with the proposed additional information language, as follows: Add this language under the additional information language displayed in the Gender section:
| |
Citizenship / Visa Type “No documents” is very small font and is not very clear because it could be interpreted as I don’t have my documents with me. Suggestion Use: bigger Font for No Documents ADD Including Undocumented, DACA, AB 540/SB 68 after “No documents” So it would read: No Documents (Including Undocumented, DACA, AB 540/SB 68) | Our Response: Increase the font size for "No documents" Add text:" And | REQUIREMENT: Increase the font size in the "No documents" label/checkbox to the same size as the question text size. | |
Visa Type: Other If you choose "Other" in the Citizenship status, and you don’t see the box, this visa information comes up right away. Then you have to scroll ALL the way down this visa list to choose other again. Suggestion: Move the no documents box (with new proposed language up to right after Citizenship Status drop down menu, before Visa Status. | Our Response: This suggestion will be reviewed by the International steering committee to determine relevancy. | N/A | |
Concern: In reading the date below, many students could assume they meet the residency if they have been in CA since this date (as if it’s physical presence alone that decides it) Suggestions: ADD to “California Residence” for Tuition Purposes Add a link to what requirements are for CA residency for tuition purposes, with info regarding non-resident tuition exemptions (including AB 540/SB 68) | Our Response: Currently we don't link out to additional information because we don't want to add a hassle or barrier to the application workflow.link the student out of the application for any reason. Usually, if it there's a critical need we will add Help text to clarify ambiguous language to avoid adding a hassle or barrier to the application workflow. However, this information could be added to the Support pages we are considering. | NA/ for now | |
Support for Undocumented Students No listing of support for undocumented students Suggestion : Add Undocumented Student Support”in programs and services | Our Response: This suggestion will be reviewed by CCCApply & MyPath Steering committees. If approved, we will add to Programs & Services in Needs & Interests page. | N/A for now | |
TO BE REVIEWED BY STEERING COMMITTEES
Language from Gender and Sexual Orientation
This information will be used for state and federal reporting purposes. It is optional and voluntary and will not be used for a discriminatory purpose. "Gender" in this context, means a person's sex, or a person's gender identity and gender expression .
- Gender 2. -- Select Gender -- Female Male
Decline to state 3. Do you consider yourself transgender ? 4. -- Select Transgender Response -- Yes
No Decline to State
Sexual Orientation
By California law, the California Community Colleges collect voluntary demographic information regarding the sexual orientation, gender identity, and gender expression of students.
- This information is used for summary demographic reporting and will not be used for a discriminatory purpose.
- Your responses are kept private and secure.
- Providing this information is optional. 1. Please indicate your sexual orientation
See also, language for SB 68. Should we make Citizenship language stronger? LANGUAGE from SB 68 information obtained in the implementation of this section is confidential, shall be used only to administer tuition payments pursuant to this section, shall not be open to the public for inspection, and shall not be disclosed without the written consent of the student, except as necessary to administer this section, or as otherwise required by California law or a state or federal court order.
NEW Layout
Dependencies, Risks and/or Reporting Requirements?
Question
Yes
No
Which data field(s)?
What/How?
Dependency, Citizenship, Gender
Does this change affect any other state or federal regulations or requirements?
Supporting Documentation
Definitions
Taxation of Nonresident Aliens
NOTE: If you were a nonresident alien student, teacher, or trainee who was temporarily present in the United States on an "F,""J,""M," or "Q" visa, you are considered engaged in a trade or business in the United States. You must file Form 1040NR, U.S. Nonresident Alien Income Tax Return (or Form 1040NR-EZ, U.S. Income Tax Return for Certain Nonresident Aliens With No Dependents) only if you have income that is subject to tax, such as wages, tips, scholarship and fellowship grants, dividends, etc. Refer to Foreign Students and Scholars for more information.
| Description | File Type | URL | Notes |
|---|---|---|---|
Dependencies, Risks and/or Reporting Requirements?
Question | Yes | No | Which data field(s)? | What/How? | |||
|---|---|---|---|---|---|---|---|
| Would this change affect an existing question or data field on the Standard Application? | Would colleges be affected by this change? | Would the Download Client be affected by this change<fin_aid> <ssn_type> Language changes throughout | Text changes only | ||||
| Would this change affect an existing question or data field on the International Application? | Same fields | ||||||
| Would this change affect an existing question or data field on the Promise Grant Application? | i.e., Glue staging table? | Other dependencies? | Other implementation considerations? |
Supporting Documentation
Definitions
Taxation of Nonresident Aliens
NOTE: If you were a nonresident alien student, teacher, or trainee who was temporarily present in the United States on an "F,""J,""M," or "Q" visa, you are considered engaged in a trade or business in the United States. You must file Form 1040NR, U.S. Nonresident Alien Income Tax Return (or Form 1040NR-EZ, U.S. Income Tax Return for Certain Nonresident Aliens With No Dependents) only if you have income that is subject to tax, such as wages, tips, scholarship and fellowship grants, dividends, etc. Refer to Foreign Students and Scholars for more information.
| Would Account (OpenCCC) data be affected by this change? | SSN Text | |||
| Does the question or data field align to an MIS reporting requirement now? | ||||
Does this change affect any other state or federal regulations or requirements? | ||||
| Would this change affect existing residency logic? | ||||
| Would any other data fields be affected by this change? | ||||
| Would students users be affected by this change? | ||||
| Would colleges be affected by this change? | ||||
| Would the Download Client be affected by this change? | ||||
| What other tech center web services will be affected by this change? | i.e., Glue staging table? | |||
| Other dependencies? | ||||
| Other implementation considerations? |