Jul 13, 2007

Policy Change On Name Changes

Social Security seems to be clearing the decks for an expected wave of calls and visits from people whose names and Social Security numbers do not match. Many Americans will soon be forced by new Homeland Security rules to clear these situations or lose employment. While some of these people with name match problems will be illegal immigrants, most of them are going to be simple name change situations. Here is an excerpt from a recent Emergency Message that seems to reflect a desire to get these processed as quickly as possible.
A. New Policy In name change situations when evidence of identity in the old name is required (e.g., name change occurred more than 2 years ago) and the applicant alleges not having any evidence of identity in the old name with him or her at the time the SSN application is filed, request the following documentation (1, 2) and Numident verification (3) to process the name change:
    1. Name change document (e.g., marriage document) showing the old name that agrees with the name on the latest Numident record (e.g., maiden name), and

    2. Evidence of identity in the new name (name to be shown on the SSN card), per criteria described in RM 00203.200E., excludes marriage document if it was submitted as the name change document in 1., above, and

    3. Verification of identifying information (SSN, name(s) on latest Numident record, date of birth, place of birth, parents’ names) from the latest Numident record (this information is propagated into the SS-5 Assistant/MES application path) with the applicant and data shown on the SS-5. Under this policy, consider the identifying information to match if the following minor discrepancies exist: minor spelling errors, mother’s maiden name is incorrect or unknown, and/or place of birth provided is County of birth instead of city.
Important: If these three documentation requirements are not met, the name change request cannot be processed under this new policy. Evidence of identity in the old name would need to be submitted if required under the instructions in EM-06064 (for name changes based on marriage and divorce) or RM 00203.210 (for other types of name changes).


Anonymous said...

I personally haven't seen anyone visit the FO yet because the employer reported a name discrepancy. Every single "no match" letter I've seen from an employer was in the hands of an illegal alien (with fake green card and fake ss card), and the letters actually told them to contact DHS, not SSA.

When people come in for a name problem it's usually because their tax return did not process or they got the letter from SSA because their wages didn't post correctly. I've seen nothing from an employer.

"Your mileage may vary," this is just my own personal experience. Maybe I'm just "lucky."

There was simply an issue with the previous name change policy, which required proof of identity in the previous name if the name change event occurred more than 2 years ago. Some people just simply did not have the ID and had no way to get it (like people who got married 15 yrs ago but forgot to change their SS card). The new policy takes those situations into account.

Anonymous said...

This is "anonymous" above - so yeah, it appears if employers are getting no match letters about SSA's name, they are by and large ignoring them. Foot traffic, gotta love it.

Anonymous said...

The RM 00203.210 has been a work in progress since it was update due to the The Intelligence Reform and Terrorism Prevention Act of 2004. This the second time it's been updated, EM-06064 being the last and it still hasn't been made part of POMS. This change as the last was probably due to people currently complaining about not being able to come up with the evidence to change their name.

I just wish people in field offices would read POMS and stop making up their own procedures, especially when it comes to someone on a visa having changed their name due to marriage after the immigration document was issued.

If it clears SAVE in the maiden name and that's the name on the immigration document it's NOT a mismatch if they apply in the married name.

RM 00203.210 C. Procedure - Immigration Document as Evidence of Legal Name

When an alien applies for an SSN card, presume the name on the immigration document is the legal name unless the applicant presents evidence of a legal name change (e.g., marriage) that occurred after the immigration document was issued.