10 Apr 2009
District Engaged in Practice Used by Other Educational Institutions
DALLAS—An independent investigation has concluded that that there was no evidence of criminal or intentional wrongdoing by the district or its employees with regard to the district's former practice of generating temporary internal nine-digit identification numbers in order to track and issue paychecks to employees in the Alternative Certification Program.
The investigation, conducted by the law firm of Fish & Richardson P.C. and led by former U.S. Attorney Paul Coggins, found that the district employed a practice used by many educational institutions when it generated and assigned "temporary social security numbers" to foreign nationals pending receipt of their permanent social security numbers. Dallas ISD, like many other educational institutions, employs a payroll system that requires the entry of a nine-digit identification number in order for its system to permit a paycheck to be issued. The numbers were assigned and utilized internally to facilitate the issuance of paychecks during the 6-8 week period, during which Alternative Certification employees applied for and were issued permanent social security numbers.
The report states that in 2003, Dallas ISD—at the advice of counsel—began the practice of using temporary nine-digit identification numbers for Alternative Certification employees, many of whom were foreign nationals without social security numbers. Initially, the district used "999", a prefix not used by the Social Security Administration for permanent Social Security Numbers, as the prefix for the temporary numbers. The district used this practice to generate paychecks for employees until a permanent social security number was issued.
In late 2003, in an effort to improve the district's ability to assign and track temporary social security numbers, the prefix was changed by staff to "111", to "112" in 2004, and to "200" in 2005, not knowing that the Social Security Administration commonly assigns these prefixes to residents of New York and Pennsylvania.
Although the independent investigation noted issues with the internal protocol which allowed a small number of temporary social security numbers to be reported to outside agencies, the report concluded that there was no evidence that the district or any of its employees knowingly or maliciously tried to interfere with the application for, or receipt of the permanent social security numbers, and no evidence that prefix formatting was changed by the district to mimic real social security numbers.
The district has stopped using temporary numbers and has instead opted to advance the timeline on the visa application process to allow foreign national applicants to apply for a permanent social security number before arriving in Dallas for their alternative certification orientation.
"We are pleased that this investigation has been completed," said Superintendent of Schools Michael Hinojosa. "A system has been put in place to alleviate these issues, and we can now return to the important work of educating our students to be college and workforce ready."