Early Learning and Care Division
Subject: Phase-out of Collection of Social Security Numbers
Number: 17-20
Date: November 2017
Expires: Until Rescinded
Authority: United States Code, Title 42, Section 9858i(a)(1)(E)
Attention: Executive Directors and Program Directors of all Child Care and Development Services
Purpose
The purpose of this Management Bulletin (MB) is to inform contractors that effective immediately, Social Security Numbers (SSNs) will no longer be required to be collected from families receiving Early Learning and Care Division (ELCD) subsidized services. Accordingly, ELCD contractors are no longer required to collect and report this information.
Background
The ELCD application, form CD-9600, required applicant SSNs for purposes of adhering to federal reporting. For the purpose of eligibility certification for subsidized child care and development services, the Federal Law (United States Code, Title 42, Section 9858i[a][1][E]), now prohibits states from reporting personally identifiable information, which includes SSNs. Since there is no more need to report on SSNs, ELCD will no longer be collecting such information.
Policy
Effective immediately, collection of SSNs is no longer required for purposes of eligibility certification.
Directives
The CD-9600, Confidential Application for Child Care and Development Services, has been revised and will no longer have a SSN field. Agencies will use the Family Identification Case Number (FICN) field on the application to assign family unique identifiers. The updated application has been renamed to Confidential Application for Child Development Services and Certification of Eligibility EESD-9600, and can be found on the ELCD Forms Web page at https://www.cde.ca.gov/sp/cd/ci/cddforms.asp.
Accordingly, the CD-9600A, Child Care Data Collection Privacy Notice and Consent form, will no longer be accepted and must not be used for any purpose.
Beginning with the September 2017 report month, the Child Development Management Information System (CDMIS) has been revised and will no longer require a SSN. Agencies will be required to complete the FICN field on CDD-801A Reports.
Note: It is not necessary to redact or destroy previously collected records. These records should be maintained only as long as the document is required for business necessity. As a reminder, in accordance with the California Code of Regulations, Title 5, Section 18117, the use or disclosure of information pertaining to the child or family shall be restricted to purposes directly connected with the administration of the program. Please be advised that use of the last four digits of SSNs on income-based Household Meal Applications for California Department of Education (CDE) Child Nutrition Programs has not changed and is still required for completing an application to the food program. This information may be found on the CDE School Nutrition Programs Eligibility Web page at https://www.cde.ca.gov/ls/nu/sn/eligmaterials.asp.
If you have any questions regarding the information in this MB or the new EESD-9600, please contact your assigned ELCD Field Services Consultant via the CDE Consultant Regional Assignments Web page at https://www.cde.ca.gov/sp/cd/ci/assignments.asp or by phone at 916-322-6233.
This Management Bulletin is mandatory only to the extent that it cites a specific statutory or regulatory requirement. Pursuant to the California Education Code Section 33308.5, any portion of this Management Bulletin that is not supported by a specific statutory or regulatory requirement is not prescriptive.