Editors Note: In a rare (or rarely admitted) error, Bob neglected to include the State of Illinois in this article. They actually have the thrid lowest percentage of forms requiring social security numbers in the nation. He has published the correction and his apology here. Additionally, an error in our forms survey regarding the State of Wisconsin has been brought to our attention. For the vast majority of their forms, inclusion of the Social Security number is optional. You may read about the correction here.
I have been highlighting in recent weeks the need to purge the use of injured workers’ social security numbers from the jurisdictional forms used in the management of their claims. As I have noted, this is an unacceptable practice that is exposing injured workers’ personal identities to possible theft and needless abuse. This week I want to discuss some of the states that are both getting it right, as well as those who are moving to purge this risky practice. Some of these states have hit on manageable solutions; ones that, with a bit more refinement, should be replicated across all jurisdictions.
Before we get started, I must make an admission. My last discussion of this topic labeled Wisconsin, West Virginia and Washington, DC as the “bad boys” of workers’ comp. This was because, as a percentage of total forms, they required social security numbers on the greatest actual share. In further review, that may not be a fully accurate reflection. Looking at the sheer number of forms in other jurisdictions, there are states creating much more exposure risk than the three I singled out. Even though the percentages of these other states are lower than the top three “bad boys”, by actual number of forms they are no less a problem. In fact, they are probably a much bigger concern. I will be covering those states in the next post related to this topic.
Remember, I promised you I was going to stick with this story. Anyone who doubts my ability to grab on to a bone and not let it go probably never followed the SAIF/Plotkin saga in this blog.
Very first, on our winners hit parade, are the states of Maine and Connecticut. Maine has 50 forms, none of which require or ask for a full social security number. This is no accident. Maine Commission Chairman Paul Sighinolfi told me that their goal was to stop exposing their workers to this risk. As a result, Maine recently revised all their forms, so that 38 of them now only ask for the last 4 digits of the IW’s number.
That is, in my view, an extremely responsible approach.
Connecticut, similarly, does not require the number on any of the 44 forms we surveyed. Both states are excellent examples that other jurisdictions should strive to emulate.
Oklahoma, like Maine, has made efforts to minimize exposure. Of their 100 forms, only 2 require a full social, and they are mirror forms reflecting old court and new administrative claims. 44 more now only ask for the last 4 numbers.
Mississippi, with 7 of 26 forms containing SS# fields, says that providing that information is optional. Massachusetts, with 26 out of 80 forms, uses a notation on most saying that disclosure is voluntary, but will expedite the processing of the form.
Texas, with a whopping 169 forms on file, have 27 forms (16%) that use a full SS ID. They make the “good list”, however, because ongoing reform efforts there have converted another 29 forms to just require the last 4 digits. The same is true for North Carolina, where form redesigns have reduced their full SS seeking forms to 14 out of 72. They now have 26 forms that just require those “safe” last 4 digits. These states are not yet where they need to be, but we must acknowledge the efforts they are making.
Other states have developed positive practices that could be used to solve this issue. Georgia has a place for a social security number on 27 of their 71 forms we reviewed. However, Georgia does indicate that the “Board Tracking Number” is acceptable to be used in lieu of SSN on all forms. Similarly, Minnesota, with 27 out of 77 total forms having this field, allows use of the “Worker Identification Number” (WID) on 26 of them. The WID is generated by the Notice of Injury. The NOI is the only form that requires a social security number.
Pennsylvania, with 42.5% (37) of their 87 forms containing SS fields, is close to the prior two states. It maintains a policy that says, on most forms displaying a full SSN, it is considered optional if the WC ID # (generated after the NOI) is entered in a separate field.
Georgia, Minnesota, and to a lesser extent Pennsylvania, are on to the solution here. They are just missing one step; making the use of the Board Tracking or Worker Identification numbers mandatory after the NOI is filed. A full social security number can be used in the initial notice filing, but after that point all forms and correspondence should use a commission/board/agency generated number to track and manage the file. Even just a basic claim number could be used. These states have laid the foundation for a better method. They just need to pull the trigger and finalize the fix.
There is no reason – zero – zip- zilch – nada – to use these critical social security numbers on so many flippin’ documents.
So, hats off to Maine, Connecticut, Oklahoma, Mississippi, Massachusetts, Texas, Pennsylvania, Minnesota, Georgia and North Carolina. All have made attempts to reduce or eliminate dependence on the social security numbers of injured workers. We encourage them to see it through, and eliminate the exposure once and for all.
There you have it. That is the Good. Last week I mentioned the Bad.
Up next in our social security soiree; the Ugly. The very, very Ugly.