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.
Current SSN Question & Layout
Click here to see screenshots of the current (legacy) implementation
These docs below provide some history around the layout and design of the legacy implementation:
- 13-05 1098 Penalties.doc
- NEW Social Security Number language.CCCCO.Final.doc
- ssn specifications excerpt ammedits 22515(3).doc
CURRENT Spec Details
Name | Data Field | Format | Question Text |
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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 |
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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:
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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 |
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International Exception | <ssn_exception> | Checkbox |
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Proposed Solution & Change Specifications
# | Description | Solutions | Notes |
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Revise the overall layout, look & feel, question text, hyperlink pop-up boxes, etc., of the Social Security Number question to: |
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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 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... | |
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 the pop-up Help text box and hyperlink for "Taxpayer Identification Number" - keep all existing | Keep existing | ||
Keep the existing link out to the Privacy Policy (OpenCCC) | Keep existing but check that it's pointing to the correct doc. | ||
Update Account Matching logic to reduce duplicates for Account & proxy Account Account Matching OPTION A | Currently our duplication rate is .003 and we need to protect that number What can be done to remove reliance on SSN? Account Creation, Matching & Verification Specification v5.4.0 | ||
Account Matching Redesign SSN Question | Keep in OpenCCC Account for now Remove the SSN Encouragement pop-up Consider: Why am I being asked for my SSN? See Patty's version of revision to the language in our existing Account app here: /wiki/spaces/PD/pages/729514134 | SSN Original Specs: |