Untitled Texas Attorney General Opinion, GA-0914

Texas Board of Physical Therapy Examiners seeks to share licensees' SSNs with the Federation of State Boards of Physical Therapy (FSBPT), a private nonprofit licensing-authorities group.
FSBPT maintains a national disciplinary and licensure database and administers an national licensing exam requiring SSNs from applicants.
Board currently provides Texas licensee information to FSBPT but not licensees' SSNs.
Requester argues sharing SSNs would aid disciplinary information exchange and cheating-detection efforts.
Occupations Code § 59.001 makes SSNs of licensees confidential; Public Information Act restricts disclosure by a governmental body.
Agency relies on intergovernmental-disclosure exceptions but concludes FSBPT is not a governmental agency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May the Board disclose SSNs to FSBPT?	Maline: sharing aids enforcement and exam integrity.	Board: no statutory authorization; FSBPT private entity; would violate § 59.001 and PIA.	Not authorized; SSNs cannot be disclosed to FSBPT.
May the Board disclose the last four digits of SSNs to FSBPT?	Maline: partial SSN disclosure could be acceptable for privacy concerns.	Confidentiality of SSNs extends to any portion; statute does not allow partial disclosure.	Not authorized to disclose last four digits.

Pub. Util. Comm'n of Tex. v. City Pub. Serv. Bd., 53 S.W.3d 310 (Tex. 2001) (agency powers limited to express/implied functions; intragovernmental transfers lack disclosure impact)
FM Props. Operating Co. v. City of Austin, 22 S.W.3d 868 (Tex. 2000) (statutory authorization required; cannot infer authority to disclose personal information)