New Social Security Number Requirements for International Students Presented By International Student and Scholar Services

Agenda for Today’s Meeting Introductions Social Security Number Requirements for International Students before October 13, 2004 The New Requirements Documentation that Students Must Present What are the BU Issues for Compliance? Next Steps

Social Security Number Requirements for International Students Before October 13, 2004

Social Security Number Requirements for International Students before October 13, 2004 For any applicant who is not a U.S. citizen, Social Security Administration regulations require that it first match the applicant’s information with the Department of Homeland Security’s immigration database before a social security card can be issued A person in J-1 status will be issued a social security card once the data match is made A person in F-1 status must also provide a letter from the school’s “Designated School Official”

Social Security Number Requirements for International Students before October 13, 2004 At BU, the “designated school officials” are in the ISSS The letter must verify that the F-1 student is enrolled in a full-course of study AND is eligible to be employed The letter must be on office stationery and have an original signature. An individual letter must be issued for each student Thus, most new international students do not receive a social security number until at least three weeks after classes begin

The New Requirements

Took effect October 13, 2004 Applies only to students in F-1 non-immigrant status A Social Security Number will only be issued if the F-1 can show PROOF that he or she has a job, or has been offered a job If there is no job or job offer, then no Social Security Number for the F-1. The F-1 can apply for a SSN at any point in the future once he or she secures employment

The New Requirements The Social Security Administration states that it has changed its regulations due to national security concerns identity theft the need to protect the integrity of the Social Security Number

The New Requirements In its publications that announce the new requirements, the Social Security Administration reminds employers that F-1 students may work while the Social Security Number application is being processed See “Employer Responsibilities When Hiring Foreign Workers” Available on the web at:

The New Requirements The Social Security Administration states that there is no provision in the Social Security Act that employers must have their employees’ SSNs before hiring them Neither is there any provision in the Act that prohibits an employee from beginning work if he or she has not yet obtained an SSN

The New Requirements “We believe that any disadvantages that might exist for F-1 students who do not yet have their SSNs, versus students who do, will be minimized once the school’s employer community understands that F-1 student applicants for on- campus jobs should receive their SSNs very quickly after providing evidence to SSA that they have job offers.” Supplementary information from the SSA that accompanies the October 13, 2004 final rule

The New Requirements “Also, F-1 students, once they apply for an SSN, can request that SSA issue them an ‘acknowledgement letter.’ This dated letter confirms that SSA has received an application for an SSN. An F-1 student can show this letter to an employer as proof that they have filed for an SSN.” Supplementary information from the SSA that accompanies the October 13, 2004 final rule

Documentation That Students Must Present

To show proof of on-campus employment, the F-1 must present: A letter on school letterhead from the Designated School Official with an original signature that identifies: –the student by name –the on-campus employer (bookstore, Biology Department, etc) –nature of the on-campus employment (teaching, waiting on tables, monitoring a laboratory, etc)

Documentation That Students Must Present The F-1 must also present: A pay slip or pay stub from the student’s employer OR A letter from the employer on employer’s letterhead that verifies employment

Documentation That Students Must Present The Employer’s letter must include: identity of student employee nature of job the student is, or will be engaged in anticipated or actual employment start date number of hours the student is expected to work Employer Identification Number (EIN) employer contact information, including telephone number and name of immediate supervisor original signature and signatory title, and date

Documentation That Students Must Present If an F-1 student will receive or is receiving an assistantship or fellowship in exchange for teaching or other services, the F-1 may present his or her letter of award, if it outlines the stipulations of the work portion of the fellowship or assistantship In such cases, the SSA will not require any additional statement from the employer, but will require the letter from the Designated School Official

Documentation That Students Must Present If the employer is the Designated School Official (ISSS): the letter verifying employment must come from a separate source, such as the department or payroll official that issues the paycheck and is responsible for wage reporting

Documentation That Students Must Present All documents must be originals. Photocopies or notarized copies will not be accepted In lieu of the separate letter from the Designated School Official, the DSO may sign off on the information provided in the employer’s letter The sign-off must contain the DSO’s original signature, printed name, telephone number and date

What are the BU Issues for Compliance?

Payroll systems that require a social security number before hire may need to develop “work-arounds” with their software vendor Due to lag payrolls, waiting for the first pay stub before applying for an SSN may be problematic for students Current funding/offer letters (other than assistantship letters) will need to meet all of the SSA requirements including the Employer Identification Number (EIN) Some on-campus employers do not routinely issue offer letters What are the BU Issues for Compliance?

Other compliance issues?

Next Steps

A plan will need to be developed to educate ALL on-campus employers (departments, offices) regarding the new regulation The “Smart Forms” listserv and other listservs may be a vehicle for communication A version of this workshop may need to be offered to on-campus employers

Next Steps Other next steps?

Resources “Employer Responsibilities When Hiring Foreign Workers” SSA Final Regulation: edocket.access.gpo.gov/2004/pdf/ pdf SSA Program Operations Manual System (POMS)

If I Have Questions, Whom Should I Contact?

The Social Security liaison in the Office of International Student and Scholar Services is: Karen Keefe-Guzikowski, Assistant Director