HHS Clarifies SSN Not Required for CCDF Child Care

IMMIGRANTS & PUBLIC BENEFITS

Verification and Reporting

HHS clarifies SSN not required for CCDF child care
Immigrants' Rights Update, Vol. 14, No. 7, Nov. 28, 2000

On Oct. 27, 2000, the U.S. Dept. of Health and Human Services (HHS) released a program instruction clarifying its policy on requests for Social Security numbers (SSNs) of families seeking child care under the Child Care and Development Fund (CCDF). The instruction follows HHS's recent guidance regarding inquiries into immigration status and Social Security numbers on benefit application forms (see "Federal Agencies Issue Guidance Clarifying Proper Use of Immigration Status and Social Security Number Inquiries on Benefit Application Forms," Immigrants' Rights Update, Oct. 19, 2000, p. 10). Consistent with that guidance, HHS confirmed that SSNs are not required of children, parents, or guardians seeking CCDF child care and that states may not deny child care to families that do not provide an SSN. The instruction also reminds agencies that only the immigration status of the child is relevant in determining eligibility.

HHS warned child care agencies about the potential for discrimination taking place should eligible immigrant families be deterred from securing benefits due to unnecessary questions on application forms. If states do choose to request SSNs, they must inform families that the provision of an SSN is voluntary and that benefits cannot be denied for failure to furnish an SSN. States must also specify how the SSN will be used. Child care agencies that collect SSNs from persons who voluntarily provide them must submit the information to HHS's Child Care Bureau in their case reports. These numbers are used to assemble data and are not linked to individual family identity. Child care agencies are encouraged (but not required) to institute unique case identifiers to help them in reporting the number of families and children served.

Unlike the CCDF program, applicants for Temporary Assistance for Needy Families (TANF) must supply an SSN. However, HHS encourages states to allow family members who are not seeking TANF to designate themselves as nonapplicants early in the application process. These family members are not required to provide an SSN. Significantly, the HHS instruction confirms that families receiving child care through CCDF or the Social Security Block Grant (SSBG) are not affected by TANF's SSN requirement-even when the SSBG or CCDF funding stream includes transferred TANF funds. Those funds are governed by the CCDF rules. The program instruction has been posted to HHS's web site at www.acf.dhhs.gov/programs/ccb/policy1/current/pi0004/pi0004.htm.

Program Instruction ACYF-PI-CC-00-04 (Oct. 27, 2000).