Equifax Workforce Solutions (a/k/a TALX Corporation, a/k/a The Work Number, a wholly owned subsidiary of Equifax Inc.) was recently awarded a federal contract by the Department of Health and Human Services (HHS) to verify the incomes, employment, and employer-sponsored health coverage status (including price) of American consumers who apply for federal tax credits to offset insurance premium costs under the Obamacare insurance mandate (as stipulated by the Patient Protection and Affordable Care Act (PPACA)).
The contract between HHS and Equifax is for an initial 12-month period, with yearly options to renew, bringing its potential value to $329.4 million over five years. As reported, “Equifax Workforce Solutions will provide information [about individuals] that is more current than what is available on federal income tax returns.” Furthermore, contract documents show that Equifax must provide income information “in real time,” usually within a second of receiving a query from the federal government.
The basic application for health coverage under Obamacare includes warnings that applicants are “signing under penalty of perjury” and consent to verify information in “databases from the Internal Revenue Service, Social Security, Department of Homeland Security, and/ or a consumer reporting agency.” This arrangement is fraught with peril for consumers. Under the PPACA health insurance mandate, all consumers must purchase this financial product; for consumers seeking tax credits through federally-run HIE’s, there are no reasonable choices or alternatives but to subject yourself to the consumer reporting agency background check / income verification process.
Likewise, the application warns, “I know that I may be subject to penalties under federal law if I intentionally provide false or untrue information.” Insofar as credit agency reports are notoriously flawed and error prone, this “perjury penalty” is a dangerous weapon to wield against applicants. (PDF Link to CMS.gov Health Insurance Exchange – Marketplace Consumer Application – Individual Short Form; PDF Link to CMS.gov Health Insurance Exchange – Marketplace Consumer Application – Family Short Form)
In 2013, a pioneering Federal Trade Commission study of the U.S. credit reporting industry found that 26% of the identified at least one potentially material error on at least one of their three major credit reports. In addition, 25% of consumers identified errors on their credit reports that might affect their credit scores. Significantly, 80% of consumers who filed credit disputes experienced some modification to their credit report.
With the aid of thousands of human resource departments and governments around the country, Equifax has built one of the deepest pools of personal information on the planet, with databases containing 190 million individual employment and salary records covering one-third of U.S. adults. How personal? The Work Number database is so detailed that it contains week-by-week paystub information dating back years for many individuals, as well as other kinds of human resources-related information, such as health care provider, whether someone has dental insurance and if they’ve ever filed an unemployment claim.
Few consumers have ever heard of Equifax Workforce Solutions. Even world-renowed privacy experts are unaware. “Are you joking? Oh my god, I’m shocked,” said privacy expert consultant Larry Ponemon, founder of the Ponemon Institute, upon learning of the existence of The Work Number credit reporting database.
Equifax Workforce Solutions sells income and employment history information about individuals to employers, banks, pre-employment screening companies, property managers, debt-collection agencies, social services agencies, and others for use in determining their eligibility for credit, employment, or other purposes. Accordingly, Equifax Workforce Solutions (a/k/a TALX Corporation, a/k/a The Work Number, a wholly owned subsidiary of Equifax Inc.), is classified as a “nationwide specialty consumer reporting agency” subject to the Fair Credit Reporting Act (FCRA). Typically, report verifications are required when a person applies for a job, leases an apartment, updates their immigration status, or applies for a loan or public aid.
All consumers are entitled to request a copy of their Equifax Workforce Solutions (a/k/a TALX Corporation, a/k/a The Work Number, a wholly owned subsidiary of Equifax Inc.) without charge once every 12 months. A Work Number “Employment Data Report” includes a copy of the information potentially given to those requesting employment information on you from The Work Number. In addition, The Work Number Employment Data Report contains a list of each time a verifier has attempted to access some or all of your data using The Work Number. Individuals must contact The Work Number directly online at www.TheWorkNumber.com; by phone at 1-866-604-6570; by fax at 1-877-879-8182; or by mail at “TALX Corporation, ATTN: EDR, 1845 Borman Ct. Suite 337, St. Louis, MO 63146.”
[Link to “Federal Business Opportunities “Solicitation Number: RFP-CMS-2013-0154 – Current Sources of Income and Employment Verification” by Agency: Department of Health and Human Services; Office: Centers for Medicare & Medicaid Services; Location: Office of Acquisition and Grants Management]
- Request Your Equifax Workforce Solutions Report – The Work Number – TALX Corporation
- Health Insurance Data Privacy in the Federal Data Services Hub
- Consumer Reporting Agency TALX Corp. Agrees to Settle FTC Charges
- Do a Total Background Check on Yourself – Annual Consumer Reporting Agencies
- “It Pays to Check Your Credit Report” Says FTC’s Bureau of Consumer Protection
- Short History of FTC Credit Report Enforcement Actions
- FTC on Your Access to Free Credit Reports – Fair Credit Reporting Act (FCRA) & the Fair and Accurate Credit Transactions Act (FACTA)
- FTC Complaint Against Ingenix Inc., a UnitedHealth Group Company (2008)