SSA - POMS: DI 11010.273 - Disability Claim or Appeal Filed Under a New Social Security Number (SSN)

A. Claimant files a disability claim or appeal under a new SSN, and has a prior or pending claim under a former SSN

An individual may obtain a new SSN, with or without a name change, for various reasons, including in situations of harassment, abuse, or life endangerment (HALE); identity fraud; adoption; or religious or cultural objections to the number pattern of the current SSN. If a claimant files a disability claim under a new SSN and has a prior claim(s) under a former SSN, or if a claimant files an appeal under a new SSN on a claim under a former SSN, the field office (FO) must determine what steps are necessary, if any, to handle the new filing. The reason for the SSN change will dictate how the FO handles the new filing.

Use the new SSN and name, as applicable, in all communications with the claimant or with a third-party about the claimant’s disability claim. Do not disclose to a third-party the former SSN or name, or the reason for the change(s). Before releasing any personal information, follow agency privacy and disclosure policy as listed:

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GN 03301.020 Privacy Act

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GN 03340.001 Policy on Access to SSA Records Under the Privacy Act

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GN 03305.002 Limitations on Disclosure with Consent

IMPORTANT: The instructions that follow do not apply to claimants who changed their identity under the Department of Justice’s Federal Witness Protection Program (FWPP). Follow guidance in DI 11010.270 and DI 11055.115 when the claimant is under the FWPP.

NOTE: If a claimant receives a new SSN while the claimant's disability claim or appeal is pending (i.e., a final determination or decision has not yet been made in the case), the FO will reestablish the case using the new SSN in the applicable claims processing systems and convert the Electronic Disability Collect System (EDCS) case to a paper folder. The FO must manually clear (MANCLR), terminate (T50), or close with 'No Determination' (ND), as applicable, the active case segment(s) established with the prior SSN.

B. New SSN due to HALE

If a claimant who obtained a new SSN under HALE criteria files a new disability claim or an appeal on an existing claim, it is important to handle the new claim or appeal with the utmost confidentiality. SSNs issued based on HALE have a special indicator code of “6” (SPIN 6) on the Numident record.

NOTE: For instructions on confidentiality, see GN 00203.001B.4.

1. FO disability interview

For face-to-face interview requirements in HALE cases, see GN 00203.003.

At the start of the interview, verify the claimant’s identity to establish that he or she is the person alleged. Identity verification requirements ensure that we use correct information in a claim as well as protect the claimant's information and privacy. During the interview, verify with the claimant that the mailing address provided is a secure address to send notices regarding the claim. If the claimant does not have a secure address to receive mail, determine if the FO address can be used as indicated in GN 02401.050B.

For additional instructions on FO disability interviews, see DI 11005.001.

2. Disability case processing

a. No prior filing under former SSN

Process the claim electronically and add the HALE flag in EDCS. For instructions on adding case flags in EDCS and eView, see DI 81010.080B.

b. Prior filing under former SSN

EDCS cannot associate a claim filed under a claimant's former SSN with a new claim or an appeal filed under the claimant's new SSN. To process the new claim or appeal as an EDCS exclusion, convert the case to a paper folder and add the HALE flag to the top of the folder.

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Print the documents from sections A, B, and D of the EDCS case and place the documents in the corresponding sections of the paper folder. Add a message, marked sensitive, to the EDCS case that was converted to paper explaining the reason for converting the case to paper and the date that the case was converted to paper. Add a Report of Contact (SSA-5002), marked sensitive, to the paper folder to document the reason for the conversion to a paper folder.

For more information on processing EDCS exclusion cases, see DI 81010.030. For further instructions on identifying and documenting prior claims activity, see DI 11005.085 and GN 01010.030.

C. New SSN obtained for other reasons

If the Numident does not have the special indicator “6” and multiple SSNs are cross-referenced on the record, ask the claimant to clarify the reason for the multiple SSNs.

NOTE: An individual may have received a new SSN for authorized reasons other than HALE, e.g., adoption. However, if there is not an authorized reason for the claimant to have received a new SSN, the additional SSN(s) can be an indicator that an error or problem has occurred. For instructions on SSN policy, general procedures, and resolving issues, see RM 10200.000.

1. Current claim filed under new SSN, prior claim under former SSN

If the current disability claim is based on a new impairment (i.e., not the same impairment alleged in the prior claim) and the alleged onset date is after the date of the final determination or decision on the prior claim, process the current claim under normal procedures (including electronic process procedures). Add an EDCS message, marked sensitive, to the current case indicating that a prior claim under a different SSN exists and include the claim level, type, and SSN for the prior claim.

If the impairment alleged on the current claim is the same as in the prior claim or the alleged onset date is within the period adjudicated in the prior claim, annotate on item 5 of the SSA-3367 (Disability Report - Field Office), or EDCS 3367, the former SSN and name under which the prior claim was filed to notify the Disability Determination Services (DDS) or Office of Hearing Operations (OHO) of possible relevant evidence contained in the prior filing.

For the additional FO responsibilities and required actions involving a prior folder, follow instructions in DI 11005.085.

NOTE: If the claimant files a new disability claim under a new SSN while the claimant has a prior claim pending administrative review under the former SSN, the FO may need to determine whether a common issue exists. For instructions on common issue cases, see DI 12045.005 and DI 12045.010.

2. Appeal filed under new SSN on existing claim under former SSN

If the claimant uses a new SSN to file an appeal in an existing claim under a former SSN, this is an EDCS exclusion. Convert the appeal to a paper folder, print documents from the electronic folder and place them in the paper folder. Use an SSA-5002 to:

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document the reason for the conversion to a paper folder, and

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document the former SSN and name.

Place the SSA-5002 in the paper folder. Add a message to the EDCS case that was converted to paper explaining the reason for converting the case to paper and the date the case was converted to paper.

NOTE: The FO prints the documents from sections A, B, and D to add to the paper folder. The DDS or OHO prints other documents and adds them to the paper folder when necessary.

Social Security

Program Operations Manual System (POMS)

DI 11010.273 Disability Claim or Appeal Filed Under a New Social Security Number (SSN)