ARTICLE · 27 SEPTEMBER 2007

Controversy Continues: Can DHS Regulate SSA No-Match Letters?

Powell Goldstein LLP

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On August 15, 2007, Department of Homeland Security published its final “No-Match” regulation, entitled “Safe Harbor Procedures for Employers Who Receive a No-Match Letter”, which was scheduled to become effective on September 14, 2007.

United StatesGovernment, Public Sector

Rebecca Sigmund

Marilee Fiebig

Aimee Todd

On August 15, 2007, Department of Homeland Security published its final "No-Match" regulation, entitled "Safe Harbor Procedures for Employers Who Receive a No- Match Letter," which was scheduled to become effective on September 14, 2007. However, a temporary restraining order issued by a district court in California has delayed this effective date and brought to the forefront the controversy of DHS’ authority to regulate in Social Security territory.

By way of background, employers annually send SSA millions of earnings reports (W-2 Forms) in which the combination of employee name and social security number does not match SSA records. In some of these cases, SSA sends a letter that informs the employer of this fact (called the no-match letter). There are many causes for such a no-match, including clerical error, but another cause could be the submission of information for a worker who provided a false social security number or a social security number assigned to someone else. SSA

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