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USDOL warns states about removing SSN’s from UC notices

The U.S. Labor Department (DOL) is warning states about serious adverse consequences if they remove full Social Security Numbers (SSNs) from unemployment compensation claims and appeal notices to employers. The warning was contained in DOL’s recent Unemployment Insurance Program Letter (UIPL) 21-05, sent to state workforce agencies responsible for administering the nation’s unemployment insurance (UI) system.

     “This DOL announcement is extremely important,” said Eric Oxfeld, President of UWC – Strategic Services on Unemployment and Workers’ Compensation. “It alerts the states that full SSNs remain the only available means for most employers (large and small), as well as third party administrators used by many employers, to identify and track workers who file unemployment claims. As UIPL 21-05 points out employer participation in the adjudication process is essential to prevent payment of fraudulent and improper claims. Due process requires that employers have the opportunity to participate in predetermination hearings, appeal erroneous decisions, and participate in appeals. When states remove full SSNs from notices to employers, they can’t identify the workers who file claims, and they cannot exercise their rights.

     “UWC will continuing working to educate state officials about the importance of providing full SSNs on UI claim and appeal notices sent to employers, in the absence of a reliable alternative UI claim identifier. The states which removed SSNs were not aware of the problems this action created. We encourage state administrators to consult with the stakeholders in the UI system before changing long-established procedures, including the use of full SSN’s.
     “UWC has made UI due process a priority. We are working with the state workforce agencies and DOL to develop a reliable alternative system to using full SSNs, but at present, none exists.

     “Preserving the use of full SSN’s also benefits workers,” Oxfeld said. “Using full SSN’s helps ensure that valid claims are accurately tracked and timely paid, both of which are critical to an efficient, and affordable, unemployment compensation system.”