Employers may occasionally hire an employee who is authorized to work but has not yet received a Social Security number (SSN). While this situation can create questions about onboarding, payroll, reporting, and benefits, the absence of an SSN does not necessarily mean the hiring process must be delayed.

Employers should proceed with their normal new-hire paperwork, including Form I-9, Form W-4 to the extent the form and payroll system allow, applicable Michigan withholding and new-hire forms, and benefits enrollment documents.

An employee does not need to have a Social Security card in hand to complete Form I-9. Employment eligibility can be established using other acceptable documents listed on the form. Employers should follow the standard Form I-9 process and avoid requesting specific documents beyond those permitted.

Employers should never make up an SSN or create a temporary number for an employee. An Individual Taxpayer Identification Number (ITIN) cannot be used in place of an SSN for employee identification, employment, or Form W-2 reporting.

Instead, employers should contact their payroll provider to determine how the system handles employees whose SSN applications are pending. Employers should document that the employee has applied for an SSN and update payroll records as soon as the number is received.

The lack of an SSN does not necessarily prevent an otherwise authorized employee from being paid. SSA procedures address wages reported without an SSN or with incorrect identifying information, and Form W-2c may be used to correct previously filed wage statements when the SSN becomes available. IRS penalties may apply for incorrect information returns in some circumstances.

Employers participating in E-Verify should be aware that an E-Verify case cannot be created without the employee's SSN. If the employee has applied for but has not yet received an SSN, the employer should document the delay, allow the employee to continue working if all other employment eligibility requirements have been met, and create the E-Verify case as soon as the SSN is available.

Michigan employers must also report newly hired and rehired employees through the state's new-hire reporting system, generally within 20 days of the hire date. Employers should not create an SSN for reporting purposes. If an employee's SSN is pending, employers should consult their payroll provider or the Michigan New Hires Operation Center for the appropriate reporting procedure.

Benefits enrollment should generally proceed within the organization's normal eligibility period rather than being delayed until the SSN is received. Requirements vary by carrier and plan, but some benefits providers may allow enrollment using a temporary identifier, without an SSN, or through a pending-SSN process.

Employers should confirm the appropriate procedure with their benefits broker, carrier, or third-party administrator.