SL 80001.820 SSA Responsibilities for Pre-1987 Contributions
Prior to 1987, SSA assigned 69-numbers to identify State and local entities and interstate
instrumentalities that obtained Social Security coverage under a Section 218 Agreement.
Since SSA was responsible for processing the wage reports and accounting for the Social
Security contributions paid by State and local government employers, SSA assigned
a 69 employer identification number (EIN) for reporting and record keeping purposes.
The 69-numbers were used through tax year 1986.
Beginning with wages paid after 1986, State and local government employers with Section
218 Agreements report Social Security and/or Medicare Qualified Government Employment
(MQGE) wages under their IRS-assigned employer identification numbers (EINs).
Some States, on their own, assign and use 69-numbers for administrative recordkeeping
purposes. If a State uses a 69-number and submits a modification that extends coverage
to one or more years prior to 1987, the State should notify the SSA regional office
(RO) in a cover letter what 69 number(s) should be used for the newly covered entity.
However, the State needs to provide in the modification the EIN number assigned by
If retroactive coverage involves periods prior to 1987, the State needs to make the
deposit with a Federal Reserve Bank or branch in the same manner that pre-1987 deposits
were made. This is because those sections of Section 218 of the Social Security Act
that were repealed by Public Law 99-509 are still in effect for pre-1987 years. If
the State experiences problems with a FRB deposit, contact the SSA Office of Earnings
and Program Integrity Policy at 410-965-1963.