American Payroll Association

Government Affairs Task Force

SSA Wage Reporting Redesign Subcommittee

Questions to Consider

1. Would employers want the option of submitting a “corrected” W-2 that would completely overwrite the W-2 it already submitted for an employee? SSA mentioned this could be helpful in situations in which, for one reason or another, the employer doesn’t even know what was reported on behalf of an employee.

2. What if SSA could create an online, real-time process for changing already-submitted W-2 information? In such a system, instead of preparing and submitting a W-2c, an employer would access the wage record from within SSA’s database and make changes as necessary.

3. After an employer submits a wage file, would we like the receipt issued by Business Services Online (BSO) to indicate any data based on the file (e.g., number of wage reports)?

4. Should SSA develop an employer equivalent of the Earnings Statement, notifying an employer of the following?

a. the number of W-2s and total dollar amount of wages it filed

b. the number and dollars that were successfully processed

c. the number and dollars that could not be processed

d. internal corrections, such as duplicate W-2s identified

5. Are there other types of communications we’d like to see go out from BSO, via direct e-mail from SSA to the employer and/or the service provider that files on behalf of the employer? SSA already collects the e-mail address of the entity that actually files the W-2s, but in order to send e-mail to employers that have service providers filing on their behalf, SSA would have to additionally collect the employer's e-mail address, via a new field on EFW2 record layout.

6. Should SSA accept wage data in different formats than it currently does (e.g., XML)?

7. Do we need to change the procedures for third-party sick-pay reporting?

8. Do we need changes to the procedures for W-2 box 11 (Nonqualified plans) or Form SSA-131?

9. Should there be different services for reporting agents (those that perform wage reporting on behalf of others)?

10. How can SSA give IRS better or quicker access to filed W-2 data, so IRS can verify wage and tax amounts before issuing tax refunds?

11. What are our reactions to the prospect of more-frequent wage reporting? This could be required under President Obama’s budget proposal, in order to support other proposed programs that would rely on this data, such as national healthcare, mandatory IRAs, or basing unemployment benefits on more recent wage data.

a. SSA mentioned that more frequent wage reporting could reduce W-2 fraud (e.g., individual who makes up a W-2 showing low wages and high taxes in order to get a refund). SSA/IRS could more quickly validate whether that person really worked for that employer.

b. Would it be more palatable if decreased the number of agencies with which an employer files (single-point filing for SSA and state income tax/UI agencies)?

12. What else is on your wish-list when it comes to SSA’s filing requirements, filing options, and services?