2019-37: Proposed Changes to Support Undocumented Students from Immigrants Rising

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

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.

These screenshots have been shared with various undocumented students and CCC educators to help identify concerns and agree upon proposed language/suggestions.

I really appreciate you taking the time to look this over because these issues are very likely reducing the enrollment of a growing population in California’s Community Colleges.

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.

Proposed Solution

The 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: The plan for the revised questions includes a new, streamlined layout and all the legal information text is being placed in a pop-up hyperlink adjacent to the new prompt question. NOTE: None of the legal language is being changed or removed from the question at this time - it is just being hidden behind a hyperlink.
Acknowledge Financial Aid Checkbox Concern: The sentence that reads “I plan to apply for admission to college or financial aid” RIGHT 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.
Privacy Policy is outdated; Privacy policy does not include FERPA or SB 54, only info practices act of 1977.	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. 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 slightly 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." We will also increase the font size in the question and additional information text.
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 our policy to NOT 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.
Move up the SSN Exception question and text “Check this box” immediately following the SSN Type field and prompt text. a) 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.

NEW Layout

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 this change affect an existing question or data field on the International Application?
Would this change affect an existing question or data field on the Promise Grant Application?
Would Account (OpenCCC) data be affected by this change?
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? Multiple Measur
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.

Foreign Students & Scholars

Description	File Type	URL	Notes