Addendum - 0960-0066

Justification for Substantive Changes for Forms SS-5, SS-5-FS

Application for a Social Security Number (SSN) Card, the Social Security Number Application Process (SSNAP), the Online Social Security Number Application Process (oSSNAP) and the Internet SSN Replacement Card (iSSNRC) Application

20 CFR 422.103 - 422.110

OMB No. 0960-0066

Background

SSA currently collects race and ethnicity information as part of our SSN card application process. We ask for this information under four of the modalities 0960-0066 comprises, including the Social Security Number Applications Process (SSNAP), Internet Social Security Number Replacement Card (iSSNRC), script screens (for phone calls or in-office visits), as well as the paper Forms SS-5 and SS‑5‑FS. We collect this information when individuals apply for their original or replacement SSN card in our offices, through video (when applicable), or through the mail. While applicants for original or revised SSN cards must provide all the other information 0960-0066 requests, completing the race and ethnicity questions is voluntary. Our aggregate internal management information data indicates that approximately 51% of respondents complete the racial data questions, while 43% answer the ethnicity questions.

We are adding the voluntary race and ethnicity questions to the Enumeration at Birth (EAB) application collections under OMB No. 0960-0066 mentioned above to encourage more applicants to answer these questions as they file for an SSN card. We hope our doing so will encourage more respondents to answer the questions, in accordance with the goals of the Administration’s Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.

Revisions to the Information Collection for Enumeration at Birth (EAB):

• Change #1:  The State Processing Guidelines for EAB include the current data fields SSA collects from States and Jurisdictions during the EAB process. When a parent applies for their newborn’s SSN in a field office, they are asked to voluntarily provide the race and ethnicity of their child. However, under our current EAB process, if the parent(s) use the birth registration process through a hospital, birthing center, or licensed midwife to obtain their newborn’s SSN then race and ethnicity are not electronically sent to SSA. We plan to add race and ethnicity data for the newborn and parents to the EAB process. This will allow the parent(s) to answer the questions when completing the hospital birth record form or worksheet and provide consent to voluntarily share the race and ethnicity information on the form or worksheet with SSA.

The State Bureaus of Vital Statistics (BVS) already ask for the parents’ race and ethnicity during the birth registration process and this information is also on the hospital birth record form or worksheet. When the parent(s) provide consent, SSA asks State BVS to electronically share this data with SSA through data-matching agreements for research and statistical purposes.

The hospital forms or worksheets do not currently ask for the newborn’s race and ethnicity, so States and Jurisdictions will add questions to ask for this information. On the hospital forms or worksheets, we expect States and Jurisdictions to use the same categories for the newborn as they use to collect the parents’ race and ethnicity for consistency. The parent(s) completing the form would make the selections for their newborn. We are asking State BVS to begin collecting this information and to electronically share this data (if consent is provided) with SSA through data-matching agreements for research and statistical purposes.

We anticipate the States can use one consent checkbox to cover the release of all race and ethnicity information the filer selects on the form. The parent(s) would also receive the Privacy Act Statement, which informs the application filer of SSA’s legal authority for the collection; that the collection is voluntary; how SSA will use the information, including some possible disclosures; as well as how SSA will maintain the information (i.e., system of records notice), which lists all possible routine uses.

If the States obtain consent, the State BVS will then electronically send the race and ethnicity data information they collected for the newborn and for the parents, along with the request for a new SSN to SSA to assign an SSN and issue an SSN card for the newborn. The race and ethnicity data is stored with an indicator that it was obtained through the EAB process.

States and Jurisdictions typically conduct training when making updates to the hospital worksheets or forms. Hospital staff training will cover the new race and ethnicity questions for the newborn, the consent checkbox, that SSA intends for the parent(s) to select the newborn’s race and ethnicity, and that providing this information to SSA is voluntary. The training also ensures the parent(s) completing the form understand that SSA will use the response for research and statistical purposes.

Justification #1:  We are making the change to help encourage more respondents to answer the voluntary race and ethnicity questions within our enumeration product. SSA hopes to use the data we collect through the race and ethnicity questions for research and statistical purposes to ensure we are treating our applicants and beneficiaries equitably.

The information SSA needs for issuing the SSN for the EAB process will remain the same and SSA will continue to use it to enumerate the newborn. The only change will be the addition of the race and ethnicity questions for the newborn (the States already collect the parents’ race and ethnicity) and a question consenting to share the race and ethnicity information on the hospital form or worksheet with SSA. Upon receipt of the updated information, SSA will store the race and ethnicity data separately in the Race and Ethnicity Collection System (RECS).

This revision to the EAB process will not change the overall burden for this information collection. The addition of the newborn race and ethnicity questions and the consent checkbox will have a de minimis impact. We will implement this revision upon OMB’s approval.

Note: SSA currently has no template which shows the new race and ethnicity data collection questions for the newborn; however, we expect the questions to be similar to the current questions states use to collect this information for the parents. Once we have a state on boarded for this data collection and they have a revised hospital worksheet or form, we will share a sample template with OMB in a change request to show how this information will be collected.

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