Social Security number requirements

The need for a Social Security number

To get CalFresh benefits you must have a Social Security number (SSN), or have applied for one, or have good cause for not applying for one. [7 C.F.R. § 273.6(c); MPP § 63-404.1; ACL 24-44.]

All people in a household applying for CalFresh benefits must give the CalFresh office their SSNs. [7 C.F.R. § 273.6(a), MPP § 63-404.1.] The county should not ask for SSN information for people in the household who are not seeking benefits for themselves.

The CalFresh office must check the SSNs of everyone in the household with the Social Security Administration (SSA). However, if the county has already checked a household’s SSN for a CalFresh, CalWORKS, or Medi-Cal application, then the CalFresh office does not need to check again. [7 C.F.R. § 273.2(f)(1)(v); MPP § 63-404.62.] The CalFresh office cannot delay or deny CalFresh benefits while it waits to check a SSN. [7 C.F.R. § 273.2(f)(1)(v); MPP § 63-404.63.]

If an applicant is not sure if they has a SSN, or cannot remember it, they can contact Social Security. He may need to reapply at a Social Security office for a SSN. [7 C.F.R. §§ 273.6(c), (d); MPP §§ 63-404.31.]

Applications should be filed using the exact name associated with the Social Security Number.  This is true even when the applicant is incarcerated under an alias or other alternate name.  [ACWDL, November 18, 2022.]

Good cause to not apply for a Social Security number

Applicants without SSNs must apply for one before receiving benefits unless there is “good cause.” [7 C.F.R. § 273.6(b)(2); MPP § 63-404.31, 404.41.] “Good cause” means that the person tried to apply for a SSN but cannot, yet. [7 C.F.R. § 273.6(d); MPP § 63-404.5; ACL 24-44.] For example, someone may have “good cause” if their Social Security office will not take his SSN application because he does not have proof of his age, and Social Security and must send away for his birth certificate.  CDSS says that delays because of illness, temporary absence or lack of transportation are not good cause.  [ACL 24-44.]

If the CalFresh office finds good cause for not trying to get a Social Security number, an applicant can get CalFresh benefits for one month in addition to the month of application. [7 C.F.R. § 273.6(d); MPP § 63-404.52; ACL 24-44.] The CalFresh office will then decide if there is good cause for not applying for a SSN at the end of each month. [7 C.F.R. § 273.6(d); MPP § 63-404.52.] Eventually, either the applicant will get a SSN, or lack good cause for not applying for one.

An otherwise eligible person should not be denied SNAP benefits for failure to provide a Social Security number where that failure was for reasons beyond their control. See, e.g., Cox v. Department of Health and Rehabilitative Services, 480 So.2d 149, 150 (Fla.App. 1985).

Applying for a Social Security number

The county should provide an application for a SSN. An applicant should take the completed application to their local Social Security office. [MPP § 63-404.3.]

To get a SSN, a person needs to show her:

  • Identity;
  • Age; and
  • Citizenship status

Non-citizen applicants have to show proof of their immigration status. [7 C.F.R. § 273.2(f)(1)(ii)(B).] Applications for SSNs may also be done by mail, but the county may require that proof also be mailed. [7 C.F.R. § 273.6(d).] The county should assist applicants unable to obtain proof. [7 C.F.R. § 273.6(d); MPP § 63-404.51.]

CDSS has developed a new form for request a non-work SSN, the Non-Work Social Security Number Request Form (GEN 2101). [ACL 24-44.]  Social Security will accept the new form.  A wet signature of an authorized county management official or designee is required.  [Id.]  Counties can develop their own form, but only the GEN 2101 has been approved by the Social Security Administration.  [Id.]

Going from a SSN application to CalFresh

A SSN applicant should get a receipt proving he turned the application in. Then, he should give a copy of the receipt to the CalFresh office. [7 C.F.R. § 273.6(b)(2)(ii); MPP § 63-404.51.] The CalFresh program should arrange with SSA to be notified directly of when the SSN is issued.

Once the receipt is submitted, the CalFresh office will approve benefits while the application for the SSN is processed. [7 C.F.R. § 273.6(d); MPP §§ 63-404.5, 404.34.] Once a person gets a SSN and the CalFresh office has the new SSN, benefits should be paid. [7 C.F.R. § 273.6(b)(2)(ii); MPP § 63-404.34.]

Effect of having no Social Security number

If a household member fails to provide or apply for a SSN without a good cause, she will not receive benefits due to disqualification. [7 C.F.R. § 273.41; MPP §§ 63-404.11, 63-404.4.] This disqualification applies only to that individual member and not to the entire household. [Id.] The disqualified person’s income and resources can affect the entire household’s benefit allotment and eligibility. [MPP § 63-404.42.]

Disqualification for lacking a SSN can end. Once a disqualified household member provides the county with his SSN, proof of an SSN application, or good cause for why an SSN application cannot be completed, that member becomes eligible for benefits. [7 C.F.R. § 273.6(e); MPP § 63-404.7.]

Social Security Number for Newborns

A newborn baby is exempt from this requirement for six months. If after 6 months the household is unable to provide a SSN or proof of applying for a SSN for a newborn, the County must determine if there is a good cause for non-compliance and, if good cause is found, approve an additional month’s benefit. The County must review information from multiple sources, including the family member and the Social Security Administration, and must accept documentary evidence of the SSN application.  [ACIN I-54-22.]

If the household cannot provide an SSN when they apply for CalFresh for the newborn, the child is eligible until the next recertification or six months after the application, whichever is later. If the recertification is earlier, the county must send the family a Request for Verification Form (CW 2200) six months after benefits are granted. [Id.] The family will have ten days to respond to the request for verification.  If the recertification is more than six months after benefits are granted, the county must request the child’s SSN during the recertification process.  If the household does not provide the child’s SSN, the child will be excluded from the CalFresh household unless there is good cause for the newborn not having a SSN.  [Id.]

A new baby must be added to the CalFresh program one month after verbal communication of the newborn and date of birth. Counties cannot require the household to complete an application form to add the newborn to the CalFresh household.  [Id.]