American Camp Association urges camps to abide by the Internal Revenue Service (IRS) ruling and obtain Social Security numbers for all international staff.
By law, Social Security numbers are required of J-1 international counselors and summer work travel participants. Since international staff receive pocket money and room and board in some instances, they are considered employees by the definition of the IRS. The regulations require Social Security numbers for all persons with over $2,750 in income; but, at the same time exclude certain persons required to file only federal income tax "informational returns". It is important to note that this minimum includes all money received in the United States and not just money that summer work travel participants receive from your camp. Summer work travel participants may work in other places after they have completed their camp obligation. International camp counselors may not.
International staff are subject to background checks once they apply for a Social Security number – this requirement is tied to action by the Department of Homeland Security. This background check is separate from the check they get in their home country to participate in the exchange program. This check cannot begin until the individual is physically within the United States and can add weeks on to the process of the application for a Social Security number.
Camps can pay staff without an actual number as long as the staff member has applied with the Social Security Administration. Your local Social Security office can give you a copy of the memo generated at the national level to show you are operating in good faith when your staff apply for their numbers.