2018-34: Revise Social Security Number Question in CCCApply

Request No. 2018-34
Date of RequestJuly 25, 2018 
RequesterSteering; CCCApply Redesign Workgroup; 
Application(s)OpenCCC Account Creation, Edit Account, Recover Account 
Section / Page

Page 1 

Steering Hearing DateTBD 
Proposed Change to Download FileYes*
Change to Residency LogicNo 
Jira 

OPENAPPLY-6441 - Getting issue details... STATUS

CCCFEDID-2338 - Getting issue details... STATUS

August 16, 2019: 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 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 language, etc. The feedback received from students and colleges is that the legal language is overwhelming and the layout is confusing. Many students, including noncredit students, international students, undocumented, minors, etc, 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 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



Proposed Design Drafts

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


 Click here to expand...
  1. Proposed: Create two layouts and get student feedback.  
    1. Option A new proposed layout with the prompt text at the top, all legal language moved to right side bar as Help text, triggered by hyperlink, and SSN input fields. No SSN would remain at the bottom.
    2. Option B - New layout variation but move the "I do not have a  SSN" <no_ssn> question up to the top of the layout - even above the prompt text?
    3. Option C - implement scaffolding to the question - where the first and only question that appears includes the prompt text and then "Do you have a SSN number?" checkbox.  If the student indicates YES - display the new layout - SSN input field/Confirm input field and submit.
      NO - display the SSN Exceptions question and collect info about what type of exception they are?

  1. Option A, B, C = Providing a SSN or TIN would remain optional; however, the applicant must indicate whether they have an SSN or not.
  2. Option A, C = 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.  
  3. Option A, C = 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?"
  4. Options A, B, C = Maintain all current download fields and make no changes to the existing field formats in the Download Format Definitions file
  5. Options A, B, C = Continue to deliver the existing data fields - with encrypted SSN data - to colleges via Downloads and Glue. store the information securely.

See Proposed Option A SSN Layout slides

Variations of SSN Layout Options


One example in context of placement on the Account Information/Mailing page in CCCApply.




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


 Click here to expand...

Immediate priority -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.


Option A1 - Revise the layout of the existing SSN question - primary change would be to move all current legalese (including penalties, and IRS code language) to the Right Side Bar/Slider Drawer as Help Text which would be displayed when a Hyperlink is clicked. The hyperlink would say, "Why am I being asked for my Social Security number? All existing data fields would persist in the background (database) and downloads/Glue would not be changed.  Improve the student experience with new shortened layout with fewer questions, 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)
The SSN input fields would remain, and both No SSN or the SSN Exceptions checkbox questions would function as they do today, with slight text changes within the questions.

Proposed Option A1


Option A2: Modify legal language to soften legalese and harsh/scary words like "penalty" etc. - but the rest of Option A would remain.

Option B:  Move the "No SSN" checkbox question to the top of a static Option A layout - so users see that first. Keep all other text and fields on the screen as proposed in Option A1 and A2.  Work with Legal to made language changes and move behind hyperlinks as proposed above. Keep existing legal language, but revise the layout. 

Option C:  Build prototype with scaffolding that would display a revised "No SSN" question that would read, "Do you have a Social Security number?"  If yes, display the rest of Option A - with modified language and Help text - to collect number.  If No - or no checkmark - display an updated SSN Exception question to find out what type of exception they are?  < Not sure if we need this.





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

 Click here to expand...




SSN in Account Recovery

Internal Use:  Requirements for Redesigning SSN / TIN in OpenCCC & Apply


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

#

Description

Solutions

JIRA


(Add requirements to make the SSN question changes itemized below - configured for mobile /responsive)


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

Revise question text and additional onscreen question textBelow the "Social Security Number" question label, the question text should read:
The Social Security Number is used as a means for identifying student records and to facilitate federal financial aid. However, it is not required for admission."


Add new dropdown menu (new field or trigger)  asking if the user has a SSN or TIN

Do you have a Social Security Number or Taxpayer Identification Number?

Menu response options:

  1. Yes = I have a Social Security Number or Taxpayer Identification Number.
  2. No = I don't have a SSN or TIN because I am an international student, undocumented student, a nonresident alien, or enrolled exclusively in noncredit classes."
  3. I don't remember my SSN or TIN or
  4. I decline to provide one at this time.

MODIFY No SSN field OR create new field (Josh is deciding)

Validation

If YES then display the SSN and Confirm SSN data input fields 

If NO is selected, THEN display - fill fill exist a

If "I don't remember"...- THEN - display "Failure to provide..."  box

If "I decline to provide one..." THEN ...TBD



Add






Remove the SSN Type field <ssn_type> from the user interface, but keep the data field in the downloads and populate based on the existing logic (if SSN then populate the field with SSN; if TIN then populate the field with TIN)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).

ADD A NEW Help Text message under the hyperlink = "Why am I being asked for my Social Security Number?"

Add new hyperlink sentence under the question prompt text for the purpose of hiding (or moving) the majority of the required, legal language that is creating barriers for current applicants.

Language in the hyperlink:  "Why am I being asked for my Social Security Number? 

NOTE: There is too much required language to put it all in one slider drawer (using the one new sentence proposed). Some of the required language will be split out and displayed using other hyperlinks.





Keep both SSN and Confirm SSN input fields

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.

Force formatting so that user inputs numbers (no letters, etc.) with hyphens, formatted correctly, etc.

Ensure for att



Keep the "No SSN" checkbox question but update the question text as follows:Keep the "No SSN" checkbox question and existing field logic - to display the "SSN Exceptions" question if checked (is NOT empty).

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.)

Keep the "SSN Exception" checkbox question: 
Scaffolding

, 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.)



Out-of-Scope:  Redesign the SSN question to be a configurable question field (opt-in / opt-out)  This would require development in the Administrator 









Remove the language in red text and replace with the text in blue text.

Remove all hyperlinks from within the text that's being moved into the slider drawer. 

  • few exceptions
  • Taxpayer Identification Number
  • Privacy Policy

"Why am I being asked for my Social Security Number?" 


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(few exceptions, including international students, undocumented nonresident aliens, and noncredit students.)

The information required by the IRS includes the student’s name, address, Social Security Number (SSN) or Taxpayer Identification Number 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 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 following Help text messages - using the existing hyperlinks. The Help text will display in right-side slider drawer instead of a pop-up error message. See mock-up for placement.

with new or modified text



Keep:  Privacy Policy - keep linking this out to the OpenCCC Privacy Policy




REMOVE

REMOVE:  Exceptions: (keep existing hyperlink(s) and text boxes/language)

REMOVE:  Few exceptions (keep existing hyperlink(s) and text boxes/language)

REMOVE:  Taxpayer Identification Number (keep existing hyperlink(s) and text boxes/language)



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
(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...


§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 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

/wiki/spaces/OPENAPPLY/pages/72155246

no longer valid


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

no longer valid

SSN in the Common Application

SSN in the CSU Apply


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

.

Amanda

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

  •  I plan to apply for admission to college or financial aid.

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
(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.

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:

  • Social Security Number

  • Taxpayer Identification 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

  • Check this box if you do not have a Social Security Number (or Taxpayer ID Number), or decline to provide one at this time.

International Exception

<ssn_exception>

Checkbox

  • Undocumented international students, nonresident aliens, and other exceptions, may not have a SSN, or TIN, and should check this box.

For Internal Use Only

Related JIRAs

CCCFEDID-2338 - Getting issue details... STATUS