FROM: KIM EVANS, DIRECTOR
SUBJECT: THE WORK NUMBER FAIR CREDIT REPORTING ACT REQUIREMENTS
DISCUSSION:
The information provided by The Work Number is subject to FCRA requirements. Refer to manual section 0110.060.05 Electronic Verification System Legal Basis for more information.
Policy regarding proper authorization to review FCRA sources is available in the Electronic Verification System portion of the General Information manual.
A guide outlining when an IM-6EVS is required is in development.
Eligibility unit members who are not applying for or receiving benefits must sign an Authorization for Verification (IM-6EVS) form before FSD can access their employment verification in The Work Number portal.
To determine if an IM-6EVS is required consider the following:
- Requesting benefits: Do not request a signed IM-6EVS. The request for benefits on the application provides the necessary authorization to consult FCRA sources.
- Not requesting benefits: If the individual is a mandatory member of the eligibility unit a signed IM-6EVS is needed..
NOTE: Refer to each program policy for mandatory members
As discussed in manual section 0110.060.15 Fair Credit Reporting Act Authorization, the IM-6EVS is valid until benefits are denied or terminated, or FSD receives a written and signed revocation.
Questions:
Questions should be sent through normal supervisory channels. Policy questions can be submitted by managers to the policy unit email addresses:
MHABD and Family MHN: COLE.MHNPOLICY@dss.mo.gov
SNAP: COLE.FSPOLICY@dss.mo.gov
TA and CC: FSD.COLETAPOLICY@dss.mo.gov
For case specific policy clearances, utilize the Request for Interpretation of Policy (IM-14) process.
NECESSARY ACTION:
- Review this memorandum with appropriate staff.
KE/rr/kg/am/cs/sb