CCLP testifies in support of ITINs for non-educational opportunities

CCLP testifies in support of ITINs for non-educational opportunities

by Annie Martínez and Milena Tayah| Mar 2, 2026

Equity work, Legislative Updates, Research and Policy Analysis, Testimony

On February 26, 2026, Milena Tayah provided testimony to the House State, Civic, Military, & Veterans Affairs Committee in support of House Bill 26-1143, Non-Employment Educational Opportunities Background Check Information. The bill addresses the background check barrier for educational opportunities (e.g., clinical nursing practice, mental health and social science internships, and pre-professional apprenticeships). Instead of prohibiting the request for a Social Security number (SSN) for non-employment educational opportunities, this bill would require that an Individual Taxpayer Identification Number (ITIN) be allowed in lieu of a Social Security Number (SSN) when required for these background checks. This testimony was written by Annie Martínez.

Chair Willford, Vice Chair Clifford, members of the committee,

My name is Milena Tayah, and I am speaking on behalf of Annie Martínez at Colorado Center on Law and Policy in support of HB26-1143. CCLP is a nonprofit, nonpartisan organization advancing the rights of every Coloradan.

This bill is straightforward: when an entity requires a SSN to run a background check for a non-employment educational opportunity like a required clinical placement, unpaid internship, or volunteer role-it must also accept an ITIN instead.

From CCLP's perspective, we see no concerns with the approach HB26-1143 takes. It is narrowly tailored, it keeps safety standards intact, and it includes clear exceptions for circumstances where an SSN is genuinely required by state or federal law, by accreditation or compliance programs, by grant requirements, or limited financial-authorization circumstances.

Importantly, the bill does not change what screenings are required and it does not touch employment-based background checks. It focuses only on non-employment educational experiences that are often required for graduation or licensure in health-related programs.

The practical problem is that some entities have adopted "SSN-only" onboarding policies even though background checks can be completed without an SSN, including through name-based or fingerprint-based checks. The result is an unnecessary barrier that blocks qualified students from completing clinical requirements, even when there are viable safety-preserving alternatives. Patient safety is paramount, but collecting SSNs as a default for volunteers and trainees is not shown to be legally required or uniquely reliable in the circumstances considered under this bill.

From an equity and workforce perspective, this bill matters because it removes a paperwork barrier that disproportionately impacts people who lawfully lack SSNs-without advancing patient safety. And it strengthens Colorado's pipeline into high-need health professions by allowing students to complete the training their programs already require.

For these reasons, we respectfully ask for a "yes" vote on HB26-1143.

Recent articles

CCLP testifies in opposition of Earned-Wage Access Services

Feb 20, 2026

CCLP provides comments on the PUC's proposed new rules

Feb 19, 2026

CCLP testifies against Direct Primary Care cost-shift onto Medicaid patients

Feb 18, 2026

Lessons from the Public Health Emergency Unwind in Colorado

Feb 17, 2026