Colorado Might Ban SSN Requirements for Unpaid Internships and Clinicals

What This Bill Actually Does

Right now, if you want to be an unpaid intern, a hospital volunteer, or a nursing student doing a clinical rotation, the organization running the program will likely run a background check on you. This makes sense—organizations need to protect vulnerable populations. But many of these places automatically ask for a Social Security Number (SSN) as part of that screening, even though state and federal bureaus can run robust fingerprint and name-based checks without one. House Bill 26-1143 says that if an organization runs a background check for a non-employment-based educational opportunity, they cannot force you to provide an SSN if you can provide an Individual Taxpayer Identification Number (ITIN) instead.

The bill specifically targets unpaid roles that act as mandatory stepping stones into the workforce. We're talking about unpaid internships, pre-apprenticeships, volunteer positions, and the clinical experiences that healthcare students need to graduate and get licensed. The covered entities are broad, pulling in state colleges, local district colleges, K-12 schools, 501(c)(3) nonprofits, and licensed healthcare facilities—everything from major hospitals to urgent care centers and telemedicine providers. The legislative goal here is to remove barriers for individuals who legally lack an SSN, ensuring their immigration status isn't the hurdle that blocks them from completing their education and contributing to the economy.

But the bill isn't a blanket ban; lawmakers carved out a few pragmatic exceptions. An entity can still demand an SSN if it's strictly required by state or federal law, tied to specific government grant compliance, or needed for accreditation rules that mandate checking a specific government database. They can also require an SSN if the unpaid role involves handling the organization's money and the bank refuses to accept an ITIN to verify authorized signers. Finally, if the background check uses fingerprints, the organization must follow existing state privacy laws for employers.

What It Means for You

If you are a student, a parent of an aspiring professional, or someone looking to break into a new field through volunteering, this bill directly protects your access to career-building opportunities. Currently, some incredibly sharp, hard-working Coloradans hit a brick wall right before graduation because their degree requires a clinical rotation or internship, and the host organization insists on an SSN for the background check. If HB26-1143 passes, as long as you have an ITIN, you can pass that background check and get your foot in the door.

This is especially critical for health-related academic programs. Colorado desperately needs more nurses, techs, and medical professionals. If you're an international student or an immigrant legally lacking an SSN, this legislation ensures you won't be blocked from finishing your degree and getting licensed. It essentially tells institutions that safety and criminal history matter, but the specific string of digits you use to prove your identity shouldn't arbitrarily derail your career. Remember, this doesn't mean you skip the background check—you still have to pass it—it just means you are allowed to take it.

Here is what you should consider doing right now:

• Check your program requirements: If you are a student heading into clinicals or required internships next year, find out now what documentation your host sites typically require.
• Get your ITIN sorted: If you don't have an SSN but need an ITIN to take advantage of this potential new rule, start that paperwork with the IRS now—it can take weeks or months to process.
• Make your voice heard: Reach out to the House State, Civic, Military, & Veterans Affairs Committee and let them know how this barrier has impacted you, your classmates, or your local workforce.

What It Means for Your Business

If you operate a hospital, medical clinic, 501(c)(3) nonprofit, or an educational institution, you need to pay close attention to your background check protocols. Under HB26-1143, if you take on unpaid interns, volunteers, or clinical students, you will be legally required to accept an Individual Taxpayer Identification Number (ITIN) in lieu of an SSN for their background screenings. This applies to a huge swath of the healthcare and nonprofit sectors. However, the bill explicitly states that it does not apply to actual employment positions—if you are hiring a W-2 employee, your existing SSN requirements remain untouched.

The stakes for ignoring this new standard are high. The bill hands enforcement power to the Attorney General and establishes strict civil penalties: a $2,000 fine for your first violation, and a $5,000 fine for every subsequent violation. Because the bill includes a safety clause, it will take effect immediately upon the Governor's signature, applying to all contracts and background checks requested on or after that date. That means you won't have a generous six-month grace period to update your HR manuals or renegotiate contracts with your third-party background check vendors.

Here is what you need to do this week to prepare:

• Call your background check vendor: Ask them point-blank if their software and screening processes can currently accept and process ITINs in place of SSNs for non-employment checks.
• Audit your intake forms: Look at the applications your nonprofit or clinic uses for volunteers and interns. If 'SSN' is a mandatory, hard-coded field, prepare an IT action plan to update those forms.
• Review your bank's policies: If your unpaid interns or volunteers handle financial transactions or assets, check if your financial institution requires an SSN for authorized signers, as this triggers one of the bill's key exemptions.

Follow the Money

Because this bill was just introduced, we don't have the official nonpartisan Fiscal Note yet. However, we can map out exactly where the money flows based on the text. The primary financial impact will be on the state's Department of Law (the Attorney General's office), which is tasked with investigating complaints and filing civil actions against entities that refuse to accept ITINs. We will likely see a request for an appropriation to cover the administrative and legal costs of enforcement.

On the revenue side, any fines collected—$2,000 for a first offense and $5,000 for subsequent offenses—won't just disappear into the state's General Fund. The bill explicitly directs the State Treasurer to credit these penalties directly to the Immigration Legal Defense Fund. For local governments, K-12 school districts, and state colleges, the financial hit will only materialize if they fail to update their HR and onboarding systems and get hit with penalties.

Where This Bill Stands

HB26-1143 is fresh out of the gate. It was introduced in the House on February 4, 2026, and assigned to the House State, Civic, Military, & Veterans Affairs Committee. It's sponsored by Representatives Naquetta Ricks and Junie Joseph, alongside Senator Mike Weissman.

Because it deals with removing systemic barriers for immigrant populations and touches on backend administrative regulations for major healthcare and nonprofit entities, expect a healthy, detailed debate in committee. Proponents will argue it's an economic imperative to get qualified workers through their training pipelines, while business and institutional groups might express concern over the immediate implementation timeline and vendor capabilities. If you care about this legislation, keep a close eye on the committee calendar for the first hearing date—that will be your window to submit written or in-person testimony.