R 141804Z JUL 10

ALCGCIV 006/10
SUBJ: UPDATED INFORMATION REGARDING REINSTATEMENT OF SOCIAL SECURITY
NUMBERS ON CIVILIAN EMPLOYEE PERFORMANCE PLANS
REF.  A.  ALCGCIV 005/10
1.  REF A.  REINSTATED THE REQUIREMENT TO USE THE SOCIAL SECURITY
NUMBER (SSN) AS AN IDENTIFIER ON THE EXCELLENCE, ACHIEVEMENT AND
RECOGNITION SYSTEM (EARS) AND DEPARTMENT OF HOMELAND
SECURITY/PERFORMANCE MANAGEMENT SYSTEM (DHS/PMS) PERFORMANCE
APPRAISALS TO BOTH FACILITATE ELECTRONICALLY TRANSFERRING EMPLOYEE
APPRAISALS INTO AN ELECTRONIC OFFICIAL PERSONNEL FOLDER (EOPF) AND
IMPROVE ACCURACY AND INFORMATION RETRIEVAL EFFORTS.  THIS MESSAGE
OFFERS NEW INFORMATION FROM OPM WHICH SUPPORTS THIS DECISION.
2. EMPLOYEE APPRAISALS ARE BUT ONE OF MANY DOCUMENTS, BEARING AN SSN,
WHICH MAY BE FILED IN AN EOPF.   FULL SSNS ARE REQUIRED TO FACILITATE
ELECTRONIC FILING, TO AVOID THE HEFTY FINANCIAL COST ASSOCIATED WITH
MANUALLY MATCHING PARTIAL SSNS FROM THE PERFORMANCE APPRAISAL TO THE
EMPLOYEES FULL SSN FOR SCANNING. LIKEWISE, THE EMPLID WILL NOT
SUFFICE BECAUSE THIS NUMBER IS NOT RECOGNIZABLE OUTSIDE OF THE COAST
GUARD.  THEREFORE, THE SCANNING OF PERFORMANCE APPRAISALS USING FULL
SSNS IS THE MOST EFFICIENT AND COST EFFECTIVE OPTION.
3. THE OFFICE OF PERSONNEL MANAGEMENT (OPM) HAS TAKEN A DIFFERENT
TURN ON THE MATTER OF USING SSNS AS AN IDENTIFIER.  IN A 29 JANUARY
2010 NEXTGOV ARTICLE, THE DIRECTOR, MR. JOHN BERRY, ANNOUNCED THE
WITHDRAWAL OF A PROPOSED RULE (FEDERAL REGISTER OF 18 JANUARY 2010)
INTENDED TO BAR AGENCIES FROM USING SSNS AS A PRIMARY IDENTIFIER.  HE
CITED THE IMPRACTICALITY OF THE EFFORT TO MOVE AWAY FROM USING THE
SSN AS AN IDENTIFIER WITHOUT ASSIGNING AN ALTERNATIVE GOVERNMENTWIDE
EMPLOYEE IDENTIFIER, AND REFERRED TO COMMENTS FROM FEDERAL AGENCIES,
INSURANCE CARRIERS AND A LABOR UNION ECHOING THE NEED FOR AN
ALTERNATIVE, IF USE OF SSNS WAS NOT PERMISSIBLE.  MR. BERRY ALSO
HEARD COMMENTS ADDRESSING THE NUMEROUS GOVERNMENT INTERNAL AND
EXTERNAL SYSTEMS AND BUSINESS PRACTICES, E.G., ELECTRONIC RECRUITMENT
SYSTEMS, FEDERAL BENEFITS SUCH AS HEALTH, SOCIAL SECURITY, WORKERS
COMPENSATION, ETC., THAT WOULD BE IMPACTED IF SSNS COULD NOT USED.
4. MAINTAINING THE SAFETY OF EMPLOYEE PERSONALLY IDENTIFIABLE
INFORMATION (PII) IS OF THE HIGHEST IMPORTANCE, AND THE OFFICE OF
CIVILIAN HUMAN RESOURCES REMAINS FULLY COMMITTED TO DOING ALL THAT IT
CAN TO ENSURE PPI IS HANDLED WITH THE UTMOST CARE.  IN MY 9 SEPTEMBER
2009 E-MAIL MESSAGE TO CG-121 STAFF, I ESTABLISHED SPECIFIC
REQUIREMENTS FOR PROTECTING EMPLOYEES PII, AND I EXPECT A ONE HUNDRED
PERCENT COMMITMENT FROM STAFF TO COMPLY WITH THESE REQUIREMENTS TO
THE GREATEST DEGREE POSSIBLE.
5. IF THERE ARE ADDITIONAL QUESTIONS, PLEASE CONTACT EITHER MS.
SHERRIE HAILSTORKS, COMMANDANT (CG-1213) ON AREA CODE 202-475-5318 OR
MS. JOYCE WELLS, COMMANDANT (CG-1213), ON AREA CODE 202-475-5266.
6. CYNTHIA NELSON-POSSINGER, CHIEF, OFFICE OF CIVILIAN HUMAN
RESOURCES SENDS.
7. INTERNET RELEASED AUTHORIZED.