Watch out for Social Security 'no-match' letters: How to respond.

• Position: Nuts & Bolts

They're baaaaack! After a seven-year hiatus, the Social Security Administration this year has begun sending notices to employers (and third-party payroll companies) that submit a Form W-2 containing Social Security numbers (SSNs) and names that do not match in the agency's records.

These so-called no-match letters are not new. The letters started in 1993, and they helped uncover and resolve clerical errors on W-2s and agency records (misspelled names, SSNs with transposed numbers, etc.). But they also help the government identify employees and employers that were using fraudulent information to hide the undocumented status of workers.

"Make no mistake about, this letter can open a Pandora's box of I-9 compliance issues, with no easy answers or resolutions," says attorney John Fay, president of LawLogix in Phoenix.

No-match letters have been challenged in courts and, depending on an administration's stomach for battle, they have risen and fallen in favor. The Obama administration stopped sending them in 2012.

WHAT'S NEW The Trump administration has resumed sending nomatch letters, with the ambitious goal of mailing 225,000 notices every two weeks. It is using the letters to help enforce the president's Buy American, Hire American executive order. This spring, the SSA will be comparing 2018 W-2 tax form data to its records and informing employers when there is a discrepancy.

SSA no-match letters will be sent out for any discrepancy found on W-2 forms, whether or not the employer uses the government's online E-Verify employment eligibility verification system.

Instead of a no-match letter, employers using E-Verify may receive a similar Tentative Nonconformation notice when entering information into that system. That notice indicates a discrepancy between I-9 information and the SSA's information.

HOW TO COMPLY A no-match letter provides specific guidance on what employers should do and which agencies to contact online and via phone. (Find a sample no-match letter at www.theHRSpecialist.com/nomatchsample.)

Once the employer is on notice, the compliance clock starts ticking.

The employer must correct its records if they are in error within 60 days. If the name on an employee's Social Security card is incorrect, it is his or her responsibility to correct it by contacting the SSA. This should be resolved within 60 days.

Complying with ICE and IER. A no-match letter does not indicate that anyone necessarily did anything wrong. It merely flags a...