TN 7 (01-26)

RM 01101.004 Addressing Anomalous Electronic Annual Wage Reporting Activity and Misuse of SSA's Wage Reporting Services

Citations: Act as amended, Sec. 232 and Sec. 205(c)(2)(A);

20 CFR §422.114 Annual Wage Reporting Process.

The Internal Revenue Service (IRS) requires employers to file annual wage reports for each employee with the Social Security Administration (SSA) using Forms W-2 and W-3, or their equivalents, to ensure accurate wage reporting. IRS regulations require most employers to submit these reports electronically using one of SSA's electronic wage reporting services. Accurate wage reporting is essential for proper tax administration and the correct calculation of Social Security benefits.

This policy applies to any user of SSA's electronic wage reporting services. It outlines the processes SSA follows to ensure that only correct earnings reports are accepted and processed by SSA and that users comply with SSA's terms of service related to online services including electronic wage reporting. This policy does not address, nor supplant, any other SSA or IRS requirements related to wage reporting.

At all times, SSA maintains authority to prevent wage reports from posting to SSA's earnings records when SSA has identified a concern with the accuracy or completeness of the submitted data. Under SSA's Terms of Service agreed to by users before accessing and using SSA's electronic wage reporting services, users (submitters) are prohibited from unauthorized or improper use of SSA's systems. Submitters are authorized to use SSA's wage filing services to submit accurate wage reports. Submitting inaccurate wage reports, or any misuse of SSA's wage reporting services may result in administrative actions, including suspending access to electronic wage reporting services and deactivating a submitter's Business Services Online (BSO) credentials. This POMS section indicates the procedures and policy SSA will follow when it detects submissions of anomalous wage reports or misuse of SSA's wage reporting services as defined in this section.

A. Key terms and definitions related to anomalous wage reporting and misuse of SSA's filing services

  • Anomalous Wage Reports: Wage reports submitted to SSA that are irregular, inconsistent, exceptional, or unusual and have a high probability of being inaccurate or erroneous.

  • Deactivation of BSO Credential: If SSA deactivates a submitter's credential, the submitter will not be able to access any of SSA's online wage reporting services. (All submitters, prior to using SSA's electronic wage reporting services, are required to register with SSA and obtain a BSO credential).

  • Employer Wage Reports: Wage reports for an employer that consist of the following: Form W-2 (Wage and Tax Statement), with a Form W-3 (Transmittal of Wage and Tax Statements), or a Form W-2c (Corrected Wage and Tax Statement) with a Form W-3c (Transmittal of Corrected Wage and Tax Statements); or in the case of employers in Guam, the Commonwealth of the Northern Mariana Islands, American Samoa, the U.S. Virgin Islands, or Puerto Rico, the equivalent versions of these forms; and/or electronic filing equivalent of these forms.

  • Investigative Notice: Notice to the submitter that an anomaly has been identified in a submitted wage report(s) and further action is required. The notice will contain information related to specific wage reports identified and will provide instructions and a deadline for taking the required actions related to those wage reports.

  • Misuse of SSA’s Wage Reporting Services: Misuse includes any activity that is inconsistent with the Terms of Service.

  • Submitter: Any person or party using SSA's electronic wage reporting service to submit employer wage report(s) to SSA.

  • Suspension of Submitter Access: SSA may suspend a submitter's access to its electronic wage reporting services. A submitter will be unable to submit electronic wage reports but may still access SSA's online wage reporting services and can, for example, check the status of prior submissions.

  • Terms of Service: SSA's required rules and guidelines that govern use of SSA's online services, including electronic wage reporting service platforms. All users of SSA's online wage reporting service platforms must first agree to the Terms of Service when registering for or using SSA systems.

  • Third-Party Submitter: Any person or party that acts as an agent for other employers and uses SSA's online wage reporting services to electronically file employer wage reports on behalf of the employer(s) it represents.

  • Wage Reporting Services: Any SSA service offered to assist employers with electronic wage reporting, including wage filing services (e.g., Social Security Number Verification Service (SSNVS) through its BSO and online wage reporting services (e.g., Employer Wage Reporting Web Service (EWRWS)), that permit electronic submission of formatted files of wages to SSA without having to log into the BSO website (creating a BSO account is still necessary).

B. Assistance with annual wage reporting

A submitter may contact SSA for assistance through our Employer Service Center website.

C. SSA's investigative actions

SSA may delay processing or decline to process anomalous wage reports. When anomalies are detected that, in SSA's judgement, warrant investigation, SSA will suspend processing some or all electronic reports from the submitter and contact the submitter to initiate an investigation.

When SSA suspends processing wage reports, it holds them until a determination about the accuracy of the reports can be made. While on hold, the reports will not be processed.

When SSA contacts the submitter to initiate an investigation of the anomalous electronic wage reports, SSA will send an Investigative Notice with a list of the wage reports (listed by Wage File Identifier (WFID), Employer Identification Number (EIN), and Tax Year (TY)) that SSA identified as anomalous. The submitter will be instructed to review the identified reports and determine the applicable required action. The notice will provide instructions on how to submit a response and evidence in support of the accuracy of the reports, but submitters may reach SSA with questions through BSO, Customer Support for Wage Reporting.

Examples of required actions may include, but are not limited to, a submitter filing corrected data; resubmitting data without the anomalous wage reports that SSA identified; or providing information as requested by SSA. If a submitter notifies SSA that data was submitted in error, SSA will delete the erroneous submission or reports.

If a submitter believes that certain anomalous wage reports that SSA identified are legitimate wage reports, they may provide supporting evidence to SSA for review. Acceptable evidence may include, but is not limited to, documentation from the employer, authenticated employer status through BSO, tax returns, or IRS Form 941 copies. SSA will review the submitted evidence and, if verified, will allow the legitimate reports to be processed accordingly. See RS 01403.010 for types of employer documents we might accept and the probative weight we give this evidence.

The submitter has 45 calendar days after receipt (SSA presumes 5 additional days for all mailed notices) from the date of the Investigative Notice to take required action. The submitter may request a one-time extension of 15 calendar days.

If the submitter’s required action does not address SSA’s concerns, SSA will provide the submitter a Second Investigative Notice, with a list of reports (by WFID, EIN, and TY) that SSA believes are anomalous wage reports.

The submitter has 15 calendar days from the date of the Second Investigative Notice to determine and take the applicable required action(s) for the anomalous wage reports identified in the Second Investigative Notice. The types of actions the submitter may take are the same as after the first investigative notice.

If the submitter's required actions do not address SSA's concerns, and SSA is unable to resolve the concerns it identified through the investigation process, SSA will reject the anomalous wage reports in BSO or notify the submitter that it will not process the anomalous Forms W-2 and W-2c. SSA will provide the submitter with the WFID, EIN, and TY for Forms W-2 and W-2c that SSA will not process. Submitters may also review the status of their wage reports in BSO.

D. Non-compliance with SSA's electronic annual wage reporting policies

If the submitter fails to participate in the investigation process or fails to act in good faith in its interaction with SSA during the investigation, SSA may suspend the submitter’s (including any accounts affiliated with the submitter) access to SSA’s electronic wage reporting services. An affiliated account may include, but is not limited to, accounts registered under the same employer identification number (EIN), accounts managed by the same third-party filer or consolidator, or accounts that share common contact information or authorized representatives.

Criteria for suspending a submitter’s access to SSA’s electronic wage reporting services include, but are not limited to:

  • Non-response to SSA’s attempts to contact the submitter to initiate or continue the investigation;

  • Failure to cooperate with SSA in investigations of suspected or suspicious activity;

  • Failure to timely reply to SSA’s requests for information;

  • Failure to take timely corrective action; or

  • Continuous or repeated submissions of anomalous wage reports over multiple filings or tax years.

When SSA suspends a submitter’s access to SSA’s electronic wage reporting services, SSA will provide the submitter with a written Suspension Notice describing the basis for SSA's decision to suspend the submitter's online access. The notice will explain how the submitter may request review of the suspension, including contact and mailing information.

If the submitter disagrees with SSA’s decision to suspend access to SSA’s electronic wage reporting services, the submitter may request review of that decision within 10 calendar days of the Suspension Notice issuance date. The Suspension Notice will include information about how to request review, or view the Employer Reporting Service Center for appropriate contact. The request for review of suspension must explain with specificity why SSA’s basis for the decision to suspend is incorrect. SSA will review the request for review of suspension within 30 calendar days of receipt and issue a final response to the submitter. If the submitter does not timely request review, the suspension (including affiliated accounts) will become final.

After a suspension is final, SSA may notify affected persons (e.g., EINs that recently used a third-party submitter’s services to file electronic wage reports), as determined by SSA, of the submitter’s suspension by such means as SSA determines appropriate, which may include direct notice to the affected persons or posting the name of the third-party submitter to SSA's Suspended Third-Party Submitters page on BSO's public pages.

In addition, if SSA denies the submitter’s request for review of suspension or the submitter does not timely request review of suspension, SSA may deactivate the submitter’s BSO credentials (and any accounts affiliated with the submitter) if SSA has concerns that a submitter is not acting in good faith and cooperating with SSA in resolving the issues identified in the Suspension Notice. If SSA deactivates the submitter’s BSO credentials, SSA will issue a Deactivation Notice. A submitter may request reactivation of the BSO credential and removal of their suspension by submitting a reactivation request to SSA at any time (view the Employer Reporting Service Center for instructions on the “Reactivation Process”). The reactivation request must document all good faith action(s) that the submitter has taken to address the issues identified in the Suspension Notice and, if applicable, the Deactivation Notice. SSA maintains the authority to reinstate or not reinstate the submitter.

E. Misuse of SSA's wage reporting services

If SSA has reliable information that a submitter is misusing SSA’s electronic wage reporting services, SSA may immediately suspend the submitter's (and any accounts affiliated with the submitter) access to SSA’s electronic wage reporting services without issuing an investigative notice.

On the date SSA suspends a submitter’s access to its electronic wage reporting services, SSA will issue a Misuse Suspension Notice, which will notify the submitter of the reason(s) for the misuse suspension and will explain the process for the submitter to seek reinstatement. The submitter has 10 calendar days from the date the Misuse Suspension Notice was issued to provide a clear and specific explanation why the identified incident should not be considered misuse of SSA’s electronic wage reporting services. If SSA, in its sole discretion, finds the submitter has not adequately explained how their use complies with SSA's Terms of Service or is otherwise not improper, SSA will deactivate the submitter’s BSO credentials (and any accounts affiliated with the submitter), which will restrict the submitter’s access to SSA’s electronic wage reporting services. SSA will issue a Misuse Deactivation of Credentials Notice on the date that the deactivation is effective.

Notice was issued to provide a clear and specific explanation why the identified incident should not be considered misuse of SSA’s electronic wage reporting services. If SSA, in its sole discretion, finds the submitter has not adequately explained how their use complies with SSA's Terms of Service or is otherwise not improper, SSA will deactivate the submitter’s BSO credentials (and any accounts affiliated with the submitter), which will restrict the submitter’s access to SSA’s electronic wage reporting services. SSA will issue a Misuse Deactivation of Credentials Notice on the date that the deactivation is effective.

If SSA suspends the submitter’s access to SSA’s electronic wage reporting services and deactivates the submitter’s BSO credentials, the submitter may request reactivation of the BSO services and credential by submitting a reactivation request to SSA (for appropriate contact, view the Employer Reporting Service Center). The reactivation request must document all good faith action(s) that the submitter has taken to address the issues identified in the Misuse Deactivation of Credentials Notice. SSA maintains the authority to reinstate or not reinstate the submitter.

If applicable, SSA may notify affected persons or post the name of the submitter to the Suspended Third-Party Submitters BSO page, according to the procedures described in RM 01101.004D.

NOTE: 

If SSA issued both a Misuse Suspension Notice and a Suspension Notice described in subsections D and E, the reactivation criteria must be met before the submitter can be reactivated. In all cases, SSA maintains the authority to reinstate or not reinstate the submitter.

F. Office of Inspector General (OIG) referral

SSA may also refer a matter to OIG for possible investigation. Technicians should report suspected cases of fraud to OIG via Allegation Referral Intake System (ARIS).

G. References

 


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http://policy.ssa.gov/poms.nsf/lnx/0101101004
RM 01101.004 - Addressing Anomalous Electronic Annual Wage Reporting Activity and Misuse of SSA's Wage Reporting Services - 01/27/2026
Batch run: 01/27/2026
Rev:01/27/2026