Please share this information with the appropriate members of your staff who file service and compensation reporting forms for employees of your organization.
PURPOSE
The purpose of this program letter is to instruct employers on how to complete Form BA-3, Annual Report(s) of Creditable Compensation, Form BA-4, Report of Creditable Compensation Adjustment and Form G-440, Report Specifications Sheet for Canadian employees who do not have a United States (U.S.) social security number (SSN). This program letter replaces PL 2005-05. Please disregard information in that letter. The record formatting is outdated, and we no longer accept paper BA-3s/BA-4s. Use the information in this letter to report service and compensation for Canadian employees.
BACKGROUND
The Railroad Retirement Board (RRB) has experienced difficulties in recording and documenting earnings data for Canadian employees who reside in Canada and do not have a valid U.S. SSN but perform service in the U.S. for an employer covered under the Railroad Retirement Act (RRA) and the Railroad Unemployment Insurance Act (RUIA). The problem exists because Canadian employees cannot receive an SSN due to policy changes by the Social Security Administration in 1996.
IMPORTANT REPORTING NOTICE
As of 2005, employers can no longer report service and compensation to the RRB using pseudo numbers (i.e. numbers beginning with “999” or “000” plus the payroll number) for Canadian employees without a valid U.S. SSN. Employers are required to either report service and compensation for a Canadian employee by using a valid U.S. SSN as required by law or a Canadian Social Insurance Number (SIN). Employers should only use the Canadian SIN if the employee does not have an authorized U.S. SSN.
Employers should file reports for Canadian employees with a valid U.S. SSN in accordance with the Rail Employer Reporting Instructions (RERI) manual. Instructions on how to report earnings to the RRB in the various media formats for employees who do not have a valid U.S. SSN are explained below.
ELECTRONIC FILING FORMAT INSTRUCTIONS
To ensure proper crediting of service and compensation for Canadian employees who do not have U.S. SSNs, please take the following action:
Annual (Form BA-3):
- Enter the Canadian SIN in record positions 21-29 instead of the SSN.
- Enter ***** in record positions 118-122 instead of the daily pay rate.
- Leave record positions 146-300 blank instead of inputting the Canadian employee’s address. Use a separate Canadian address record file format to provide their addresses. This file format is available upon request from the Quality Reporting Service Center.
Adjustment (Form BA-4):
- Enter the Canadian SIN in record positions 21-29 instead of the SSN.
- Enter ***** in record positions 118-122 instead of the daily pay rate.
Accompanying Form (Form G-440):
- Complete all sections of the G-440, Report Specifications Sheet in the usual manner.
- Enter in the Remarks Section of the Form G-440 in Red Ink & Bold Print the following:
“Report Includes Canadian Social Insurance Numbers.”
FURTHER FILING INSTRUCTIONS (ERSNet)
Employers MAY file service and compensation reports for Canadian employees through the Employer Reporting System (ERS).
When filling in an individual’s service and compensation information manually:
- Enter Canadian SIN in place of U.S. SSN.
- Ensure “Not U.S. SSN” checkbox is marked.
Employers can also upload a text file that includes Canadians to the site using the file format instructions in this program letter.
Employers may NOT use the BA-6a to report Canadian addresses.
For the correct Canadian address record file format, contact the Quality Reporting Service Center.
SUBMISSION INSTRUCTIONS
We encourage employers to submit their service and compensation reports electronically, through either:
- ERSNet
- Secure/encrypted e-mail
OR
- File Transfer Protocol (FTP)
QUESTIONS
If you have any questions or concerns, please contact a Compensation Reporting Specialist by e-mail at QRSC@RRB.GOV or by telephone at (312)751-4992.