In 2014, California established a Work Number Express Service Pilot program, relying on electronic verification systems provided via Equifax. Created in response to the rise in “identify theft,” the Equifax Work Number verification system may report that a particular person reporting work earnings did not work for the employer indicated on an application or periodic report form.
The counties using Equifax for verification are required to comply with certain steps to inform individuals how to contest disputed reports of earnings. [ACIN I-41-14.] Additionally, if taking an adverse action based on an Equifax report, the counties must sent a Notice of Action that must include:
- The name, address, and telephone number of the Credit Reporting Agency (CRA), (including a toll-free telephone number, if it’s a nationwide CRA), that provided the report;
- A statement that the CRA did not make the adverse decision and is not able to explain why the decision was made;
- A statement setting forth the right of the client (“consumer”) to obtain a free disclosure of the consumer’s file from the CRA if the consumer makes a request within 60 days; and
- A statement setting forth the consumer’s right to dispute directly with the CRA the accuracy or completeness of any information provided by the CRA.
- The notice must also provide the client with a copy of the “Universal Membership Agreement,” attached as Exhibit 3 to ACIN I-41-14. [ACL 16-118.]
Counties cannot obtain consumer credit reports without written authorization of the applicant or recipient. Consumer credit reports can be used in conjunction with existing fraud detection resources. Consumer credit reports cannot be used as the only means of verification. [ACL 16-118.] If a county takes adverse action based on information received from The Work Number, the county must send a notice of action stating the name, address, and telephone number of The Work Number, the right to get a copy of the report from The Work Number if requested within 60 days, and that the information can be disputed by contacting The Work Number. [ACL 16-43.] Counties must contact the household and give an opportunity to resolve any discrepancies before taking adverse action. [Id.]
Information from a consumer credit report must be made available to an applicant or recipient who requests it from the county welfare department or if an applicant requests a fair hearing to regarding the information in the consumer credit report.
If documentary evidence of income is unavailable, for example because a household member did not provide or does not have access to necessary documentation at the time of the application or interview, the Work Number can be used to verify income in real time at application, during the certification period, at recertification, or for a Quality Control review. [ACL 19-08.]
Counties cannot require the household to submit additional documentation that is duplicative of information received through the Work Number. Counties can request additional documentation only if the household states that the information is inaccurate or the Work Number does not verify all income sources. [ACL 19-08.]
Counties can use the Work Number to verify a voluntary report of a change in income or to verify income information provided at periodic report. [Id.]
For Quality Control reviews, counties can use the Work Number to substantiate information provided by the household or if the household refuses to cooperate. [Id.]
The Work Number cannot be used to verify a missing mandatory report of income over the Income Reporting Threshold. [Id.]