memo 8-28-07

1. Why would kids under 7YO be working? I could imagine child actors, but they would certainly be
making too much money to qualify for benefits…. In fact, I would imagine that earnings reports for most
kids under 14YO would be suspect (why would someone younger than 14YO have an earnings record?).
As such, why does SSA not verify the earnings reporting for most kids, if not all?
There are some legitimate occupations for children under 7 such as child
actors, models, music recording artists, child musicians, etc. However there
are people who knowingly or unknowingly provide their employer with an
incorrect SSN or the employer reports the earnings under an incorrect name and
number. In the beginning of the year when SSA receives the earnings
reports/wage information from employers for the past year SSA verifies the
reported name and SSN with the information on our records. If it is
determined that the earnings for the SSN reported are for a child who is 6 and
under, then the earnings are placed in SSA’s Suspense File and the SSA-L3231C1 is sent to the employer to verify that the employer indeed employed a child
under the age of 7. (If SSA has previously contacted the employer and the
employer has verified that they do employ young children – for example a child
modeling agency SSA does not send the SSA-L3231-C1 to the employer as it is
assumed the earnings do belong to the child.)
The decision was made by SSA’s top officials to use the benchmark age of
7 and younger.
The above is just one of several SSA systems that identify earnings
problems with young children’s SSNs. For example, SSA is implementing in
their Employer Verification System (EVS); (a system employers use upon
hiring an individual to verify that the SSN the individual provided is a
valid number and belongs to that individual) that SSA records indicate
the date of birth on our records for the perspective employee belongs to
a child age 14 and under. In addition, if a child is entitled to monthly
social security benefits and has earnings posted to their records over a
the yearly allowable amount set by law for SSA recipients, the record is
alerted for development.

2. Also, why are businesses the primary respondents?

The SSA-L3231 is one of three letters used to verify whether earnings
reported for a young child do indeed belong to that child. IF the
employer does not respond or if there is a question as to the employer’s
response, a letter is sent to the last known address of the child
advising that earnings were reported for the child (but not credited to
the SSN) and to contact their local SSA office. If SSA receives selfemployment earnings for a SSN that belongs to the child a letter is also
sent to the last known address requesting the child/guardian to contact
SSA.