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PA Bulletin, Doc. No. 09-709



Social Security Number Exemption

[39 Pa.B. 2058]
[Saturday, April 18, 2009]

Purpose of Notice

   The United States Department of Health and Human Services (DHHS) is announcing it has been granted an exemption request to the Department of Public Welfare (Department). This notice provides information regarding an exemption from the Title IV-D Child Support Enforcement Law requiring collection of Social Security Numbers (SSNs) for Pennsylvania license applications for recreational licenses.

   Under the Social Security Number Privacy Act, Act 2006-160 (Act 160), the Department was required to apply to DHHS for an exemption from Federal law that requires an applicant applying for or renewing a professional license or certification, occupational license or certification, or recreational license (hunting and fishing), to include the applicant's SSN on the application. See 42 U.S.C.A. § 666(a)(13)(A). Act 160 further provides that if the exemption is granted, an applicant shall be permitted to provide a driver's license number or Department of Transportation (PennDOT)-issued nondriver identification card number as an alternative to disclosing the applicant's SSN.

   DHHS granted the Department's exemption request in part and denied the request in part. DHHS granted the Department's exemption request to collect a driver's license number or PennDOT-issued nondriver's identification card number instead of a SSN for any applicant for a recreational license. The Department's request was granted because of privacy concerns with the current collection process for SSNs on recreational license applications and that compliance with 42 U.S.C.A § 666 (a)(13)(A) would not increase the efficiency and effectiveness of the Commonwealth's Title IV-D Child Support Enforcement Program. However, any recreational license applicant who does not possess a PennDOT-issued driver's license number or nondriver identification card number is required to supply an SSN on the recreational license application.

   DHHS, however, denied the Department's request to collect a driver's license number or PennDOT-issued nondriver identification card number instead of a SSN on applications for professional and occupational licenses or certifications. The Department's request was denied since the application information for these programs is adequately safeguarded, and the proposed procedure to use driver's license numbers and nondriver identification card numbers would not be as efficient and effective as the existing procedure.

Effective Date

   The use of the SSN alternatives for the application or renewal of recreational licenses will take effect 1 year after the publication date of this notice.

Fiscal Impact

   The Department estimates that the necessary change in the application process for recreational licenses as it affects the Commonwealth's Title IV-D Child Support Enforcement Program will be minimal.

Public Comment

   Interested persons are invited to submit written comments regarding this notice to the Department of Public Welfare, Bureau of Child Support Enforcement, P. O. Box 801, Harrisburg, PA 17105-8018, ATTN: Thomas Sheaffer.

   Persons with a disability who require an auxiliary aid or service may submit comments using the Pennsylvania AT&T Relay Service at (800) 654-5984 (TDD users) or (800) 654-5988 (voice users).


   Fiscal Note: 14-NOT-592. No fiscal impact; (8) recommends adoption.

[Pa.B. Doc. No. 09-709. Filed for public inspection April 17, 2009, 9:00 a.m.]

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