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| Last Revision: | 03/28/2006 |
| Posted to Website: | 03/28/2006 |
EPAWeb New Employment Actions for Individuals Without U.S. Social Security Numbers
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Overview
EPAWeb requires a U.S. Social Security Number (SSN) to perform a New Employment action to initiate either paid or unpaid (e.g., zero rate) EPA appointments. In many circumstances, foreign nationals newly arriving in the U.S. do not have a permanent U.S. SSN, but need a temporary dummy SSN to enable processing in EPAWeb. The following describes how to obtain a temporary SSN to permit this processing.
Please note: Visiting scholars do not receive EPA appointments and are not processed in EPAWeb. If you need to obtain a PID or One Card for a visiting scholar, you may do so by submitting a Application for Registration as UNC Affiliate to the UNC PID Office. A U.S. SSN is not required to obtain PID or Onyen services for these individuals.
- For non-resident aliens that will work for the University within the U.S. for pay under an EPA Appointment -- see Option #1.
- For non-resident aliens or foreign nationals that will be affiliated with or perform services for the University within the U.S. under an EPA appointment but receive no compensation from the University (e.g., unpaid adjunct faculty) -- see Option #2.
- For foreign nationals that will work for the University outside the U.S. for pay as an Independent Contractor or under a paid EPA appointment -- see Option #3.
- For non-resident aliens or foreign nationals that will be affiliated with or perform services for the University outside the U.S. under an EPA appointment but receive no compensation from the University (e.g., unpaid adjunct faculty) -- see Option #4.
Important Note Regarding Dummy SSNs and the Homeland Security Employment Eligibility Verification (EEV) and Form I-9 Procedures: While a "dummy" SSN can be used to process someone in EPAWeb and onto the University Payroll while a permanent number is being obtained, it may and should not be used on the Form I-9 or in initiating an EEV Check. Instead, if an individual does not yet have an SSN issued by the U.S. Government, the words "Pending" should be used in place of SSN in the on-line EEV Tool and on the federal Form I-9. If you have questions regarding I-9 or EEV processing for individuals with dummy SSNs, contact the EEV Coordinators in HR Workforce Planning & Compensation at 962-2991.
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Option 1 - Working in the U.S. for Pay
The Office of International Student & Scholar Services (OISSS), formerly called the International Center, is responsible for assisting departments in confirming eligibility for foreign nationals to work within the United States, and for initiating certain necessary administrative details that permit such individuals to be legally employed by the University (click here for further information). Once OISSS has confirmed eligibility to work at the University and completed their orientation process, they will issue a temporary dummy SSN for those individuals who presently lack a permanent U.S. SSN. Once a permanent SSN is issued to the employee by the U.S. Social Security Administration, the EPAWeb SSN Change action should be completed to reflect the newly assigned SSN in EPAWeb and Payroll.
Also note that EPAWeb includes a field called "Immigration Work Eligibility Expiration Date," which is used by departments to track the date through which this person may be legally permitted to remain employed by the University. This information should be confirmed by the employing department when processing the I-9 form. If you have questions regarding how to identify this date, contact OISSS for assistance.
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Option 2 - Unpaid EPA Appointment in U.S.
OISSS may be consulted for assistance in arranging or confirming appropriate immigration status for individuals who will be visiting the U.S. and affiliated with the University under an EPA appointment (e.g. adjunct faculty) in an unpaid status. In these situations, OISSS can issue a temporary dummy SSN to enable the individual's unpaid appointment to be processed into EPAWeb. However, this temporary SSN will not be cleared for paid employment and will be ineligible for payroll purposes. Such issuance will require completion of the Request for Temporary Dummy SSN form by the appointing department confirming its intentions to initiate an unpaid EPA appointment with the University. For purposes of entering an unpaid EPA apppointment in the EPAWeb System, the new employment action includes a required field for anyone coded as a non-resident alien (N in the "Citizenship" field). Since work eligibility is not relevant for an unpaid appointment, you should enter 01/01/9999 in the "Immigration Eligibility Work Expiration Date" entry field.
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Option 3 - Working Outside the U.S. for Pay
If a foreign national will work for the University for pay but all such work will be conducted outside the United States, there is no processing of this individual through OISSS. In these instances, the first decision is whether the individual will function as an employee of the University and therefore hold an EPA appointment and be paid on the University Payroll, or instead function as an independent contractor with payments processed through Disbursement Services.
If the work arrangement satisfies the IRS Independent Contractor guidelines: If the independent contractor guidelines can be satisfied, then payment can be accomplished through the University's Request for Check process and the individual does not need to be entered in EPAWeb or placed on the University payroll. Click here for specific guidelines and the related payment request process. Under this process, the department does not need to obtain a temporary dummy SSN for the individual being paid.
If the work arrangement is not as an independent contractor and/or an EPA appointment is desired: The department will need to process the individual in EPAWeb using the New Employment action. This action can be accomplished using a zero rate of pay to permit lump sum payments or at an established monthly rate for work performed over a fixed duration at a fixed rate. Please note, in these instances, you should enter 01/01/9999 in the "Immigration Eligibility Work Expiration Date" entry field, as this field is required for anyone coded as a non-resident alien (N in the "Citizenship" field) but in this case, no immigration work eligibility is relevant. If the individual does not have a permanent U.S. SSN, the department will need to request one from the Payroll Office using the Request for Temporary Dummy SSN form.
Please note that if circumstances change and the individual in question will later be performing work for the University in the United States, OISSS should be consulted to ensure appropriate immigration/visa requirements are satisfied.
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Option 4 - Unpaid EPA Appointment Outside the U.S.
A temporary dummy SSN may be obtained from Payroll Services to initiate a non-compensated EPA appointment (e.g., adjunct faculty) in EPAWeb for foreign nationals who will function in their unpaid capacity outside the U.S. The dummy SSN is obtained using the Request for Temporary Dummy SSN form.
Please note that if circumstances change, and the individual in question may later need to perform some of their unpaid duties within the U.S., OISSS should be consulted to ensure appropriate immigration/visa requirements are satisfied.
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For Additional Information and Assistance
- For general questions regarding the appropriateness of EPA appointments for individuals under any of these circumstances, consult your normal EPA administrative approval channels (e.g., Dean's Office) and, if needed, the Office of the Provost or the Office of the Chancellor depending on which serves as the final approval authority for EPA appointments for your unit.
- If you have immigration/visa-related questions regarding non-resident aliens who will perform work within the U.S. for the University under an EPA appointment, with or without pay, contact OISSS at 962-5661. Under these circumstances, OISSS can issue temporary dummy SSNs when no permanent U.S. SSN has yet been issued to enable processing in EPAWeb.
- If you have questions regarding Foreign Nationals who will be paid for work performed outside the United States for the University as independent contractors, contact Disbursement Services at 962-0213.
- If you have questions regarding foreign nationals who will be paid as employees (e.g., under an EPA appointment) for work performed outside the United States or who will receive a non-compensated (e.g., zero rate) EPA appointment for duties performed outside the United States, contact the Director of Payroll Services at 962-0046. Payroll Services will issue dummy SSNs for such individuals who have no permanent U.S. SSN assigned to enable processing in EPAWeb.
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