Social Security Administration: Actions Taken to Strengthen
Procedures for Issuing Social Security Numbers to Noncitizens,
but Some Weaknesses Remain (15-OCT-03, GAO-04-12).
In 2002, the Social Security Administration (SSA) issued nearly 6
million new Social Security numbers (SSNs), of which 1.3 million
were issued to noncitizens. Despite its narrowly intended
purpose, the SSN has in practice become the national identifier.
SSNs are key pieces of information in creating false identities,
underscoring the importance of issuing SSNs only to those
eligible for them and of protecting those already assigned to
individuals. The flow of noncitizens into the United States and
the accompanying number of SSNs issued to them over the last
several years add to the importance of having sound practices to
avoid issuing SSNs to those who do not qualify for them. Congress
asked GAO to describe and assess SSA's key initiatives to ensure
the appropriate issuance of SSNs to noncitizens and identify
vulnerabilities to error or fraud SSA has not yet addressed.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-04-12
ACCNO: A08705
TITLE: Social Security Administration: Actions Taken to
Strengthen Procedures for Issuing Social Security Numbers to
Noncitizens, but Some Weaknesses Remain
DATE: 10/15/2003
SUBJECT: Internal controls
Resident aliens
Social security benefits
Social security number
Strategic planning
Identity verification
Interagency relations
Fraud
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GAO-04-12
United States General Accounting Office
GAO
Report to the Chairman, Subcommittee
on Social Security, Committee on Ways and Means, House of Representatives
October 2003
SOCIAL SECURITY
ADMINISTRATION
Actions Taken to Strengthen Procedures for Issuing Social Security Numbers to
Noncitizens, but Some Weaknesses Remain
GAO-04-12
Highlights of GAO-04-12, a report to the Chairman, Subcommittee on Social
Security, Committee on Ways and Means, House of Representatives
In 2002, the Social Security Administration (SSA) issued nearly 6 million
new Social Security numbers (SSNs), of which 1.3 million were issued to
noncitizens. Despite its narrowly intended purpose, the SSN has in
practice become the national identifier. SSNs are key pieces of
information in creating false identities, underscoring the importance of
issuing SSNs only to those eligible for them and of protecting those
already assigned to individuals. The flow of noncitizens into the United
States and the accompanying number of SSNs issued to them over the last
several years add to the importance of having sound practices to avoid
issuing SSNs to those who do not qualify for them.
The Subcommittee Chairman asked GAO to describe and assess SSA's key
initiatives to ensure the appropriate issuance of SSNs to noncitizens and
identify vulnerabilities to error or fraud SSA has not yet addressed.
GAO recommends that SSA strengthen the integrity of its enumeration
policies and procedures by taking actions such as reviewing field
compliance with verification requirements for enumerating noncitizens. In
its response to GAO's draft report, SSA agreed with GAO's recommendations
and provided information on planned and current actions to address them.
October 2003
SOCIAL SECURITY ADMINISTRATION
Actions Taken to Strengthen Procedures for Issuing Social Security Numbers to
Noncitizens, but Some Weaknesses Remain
SSA Has Increased Noncitizen Verifications and Begun New Initiatives
SSA has taken steps to prevent the inappropriate assignment of SSNs to
noncitizens. SSA now requires field staff to verify noncitizens' identity
documents with the Department of Homeland Security (DHS), in addition to
continuing to require visual inspection of these documents, prior to
issuing an SSN. However, many field staff GAO interviewed are relying
heavily on DHS's verification while neglecting SSA's standard inspection
practices, even though both approaches are necessary. SSA has also
undertaken new initiatives to shift the burden of processing noncitizen
SSN applications and verifying documents from its field offices. In 2002,
SSA started implementation of a process called "Enumeration at Entry"
(EAE), which relies on State Department and DHS expertise to authenticate
information provided by SSN applicants. SSA is in the early stages of
planning to evaluate EAE with the State Department and DHS. Also, SSA
recently piloted a specialized center in Brooklyn, New York, which focuses
on enumeration and uses the expertise of DHS staff and SSA's Office of the
Inspector General investigators.
Some Areas Affecting Issuance of SSNs Not Yet Addressed
While SSA has embarked on these new initiatives, it has not tightened
controls in two key areas of its enumeration process that could be
exploited by individuals-citizens and noncitizens alike-seeking fraudulent
SSNs: the assignment of SSNs to children under age 1 and replacement
Social Security cards. SSA changed its policy to require independent
verification of birth records for U.S.-born children age 1 and over but
still only relies on visual inspection of birth documents of children
under age 1. This lack of independent verification remains an area
vulnerable to fraud. In fact, by posing as parents of newborns, GAO
investigators obtained two SSNs using counterfeit documents. SSA's policy
for replacing Social Security cards, which allows individuals to obtain up
to 52 replacement cards per year, and its documentation requirements for
U.S. citizens to obtain such cards also increase the potential for misuse
of SSNs. Of the 18 million cards issued by SSA in 2002, 12.4 million, or
69 percent, were replacements. While SSA requires noncitizens applying for
replacement cards to provide the same identity and immigration information
as if they were applying for a new SSN, its evidence requirements for
citizens are much less stringent. The ability to obtain many replacement
cards with relatively weak documentation may allow individuals to
impersonate others by using counterfeit documents to obtain SSNs for a
range of illicit uses, including selling them to noncitizens.
Original SSNs and Replacement Social Security Cards SSA Issued in Fiscal
Year 2002
Numbers in millions www.gao.gov/cgi-bin/getrpt?GAO-04-12.
Key areas U.S. citizens Noncitizens Total
To view the full product, including the scope
Original SSNs issued
4.23 1.34 5.57
and methodology, click on the link above. Replacement Social Security
Cards issued 11.45 1.00 12.45For more information, contact Barbara
Contents
Letter
Results in Brief
Background
SSA Has Increased Verifications and Launched Other Key
Initiatives, but Additional Actions Are Needed SSA's Actions to Tighten
Controls Leave Some Key Areas
Unaddressed Conclusions Recommendations Agency Comments
1
2 4
5
17 23 24 25
Appendix I Scope and Methodology
Appendix II Comments from the Social Security Administration
Appendix III GAO Contacts and Staff Acknowledgments 35
GAO Contacts 35 Staff Acknowledgments 35
Tables
Table 1: Original SSNs and Replacement Social Security Cards SSA
Issued in Fiscal Year 2002 5 Table 2: Composition of BSSCC's Staff 16
Table 3: Comparison of Identity, Age, and Citizenship
Requirements for U.S. Citizens Applying for Original SSNs
and Replacement Cards. 22
Figures
Figure 1: Required SSA Field Office Procedures for Noncitizen SSN
Applications 8 Figure 2: SSA's EAE Process for Assigning SSNs to
Immigrants Age 18 and Over 14
Abbreviations
ACM Administrative Confidential Memorandum
BSSCC Brooklyn Social Security Card Center
DHS Department of Homeland Security
EAB Enumeration at Birth
EAE Enumeration at Entry
OIG Office of the Inspector General
MES Modernized Enumeration System
MOU Memorandum of Understanding
POMS Program Operations Manual System
SAVE Systematic Alien Verification for Entitlements
SEVIS Student and Exchange Visitor Information System
SSA Social Security Administration
SSN Social Security number
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
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copyright holder may be necessary if you wish to reproduce this material
separately.
United States General Accounting Office Washington, DC 20548
October 15, 2003
The Honorable E. Clay Shaw, Jr.
Chairman
Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
Dear Mr. Chairman:
In fiscal year 2002, the Social Security Administration (SSA) issued
nearly
6 million new Social Security numbers (SSNs), of which 1.3 million, or
22 percent, were issued to noncitizens, a proportion that has increased in
recent years. Despite its narrowly intended purpose, the SSN has in
practice become the national identifier and is central to a range of
transactions and services associated with American life, including
obtaining a driver license, opening a bank account, and receiving health
care. For this reason, SSNs are key pieces of information in creating
false
identities. The events of September 11th underscore the importance both
of issuing SSNs only to those eligible for them and protecting those
already assigned to individuals. The flow of noncitizens into the United
States and the accompanying number of SSNs issued to this group over
the last several years add to the importance of having sound practices to
avoid issuing SSNs to those who do not qualify for them and to ensure the
identity of those who receive them. Because of your interest in this
issue,
you asked us to (1) describe and assess SSA's key initiatives to ensure
the
appropriate issuance of SSNs to noncitizens and (2) identify any
vulnerabilities to error or fraud that SSA has not yet addressed in its
procedures for issuing SSNs.
To answer your questions, we examined SSA's policies and procedures for
issuing SSNs, a process known as enumeration, and we obtained
information on key initiatives planned and undertaken to strengthen and
ensure its integrity. We collected and analyzed information on SSA's
enumeration initiatives, the results of prior internal reviews, and
studies
performed by SSA's Office of the Inspector General (OIG) and Office of
Quality Assurance. In addition, we reviewed studies and data provided by
the Department of Homeland Security1 (DHS) and the Department of State on
their specific agency processes that support SSA's noncitizen enumeration
initiatives. We also analyzed audits performed by the inspectors general
at the Departments of State and Justice. We conducted our review at SSA
headquarters in Baltimore, Maryland, and in 4 of its 10 regional
offices-Atlanta, Georgia; Chicago, Illinois; New York, New York; and San
Francisco, California-and at 16 field offices in those regions. We
selected the regional and field offices based on the following criteria:
(1) enumeration workload-the locations represented about 70 percent of
noncitizen enumerations in fiscal year 2001; (2) geographic
distribution-the various regions across the nation representing border and
inland locations; and (3) best practices-locations trying innovative
approaches to enumeration, such as the Brooklyn, New York, Social Security
Card Center (BSSCC). We also collected and analyzed data and documents on
SSA's enumeration initiatives and workloads. From our in-depth interviews
with more than 100 management and line staff, we documented officials'
perspectives on SSA's enumeration initiatives and identified areas where
vulnerabilities and gaps exist in SSA's implementation of these policies.
Also, our investigators tested SSA's enumeration practices by posing as
parents of newborns and used counterfeit documents to obtain SSNs from an
SSA field office and through the mail. We performed our work from
September 2002 through July 2003 in accordance with generally accepted
government auditing standards.
SSA has increased document verifications and developed new initiatives to
prevent the inappropriate assignment of SSNs to noncitizens. Though in
their early stages, these increased verifications and initiatives have the
potential to strengthen the integrity of SSA's enumeration process. SSA
now requires field staff to verify noncitizens' identity documents with
the DHS, in addition to continuing to require visual inspection of these
documents, prior to issuing an SSN. However, many field staff we
interviewed are relying heavily on DHS's verification while neglecting
SSA's standard inspection practices, even though both approaches are
necessary. We also found that SSA's automated system for assigning SSNs is
not designed to prevent the issuance of an SSN if field staff bypass
Results in Brief
1On March 1, 2003, those functions performed by the Immigration and
Naturalization Service related to monitoring individuals entering the
United States were transferred to the Bureau of Citizenship and
Immigration Services in the DHS.
required verification steps. SSA has also undertaken new initiatives to
shift the burden of processing noncitizen SSN applications and verifying
documents away from its field offices. In late 2002, SSA began a phased
implementation of a long-term process of redesigning how it issues SSNs to
noncitizens, called "Enumeration at Entry" (EAE). EAE relies on State
Department and DHS expertise to authenticate information provided by
applicants before they enter the country; this information is transmitted
to SSA, which then issues the SSN. Currently, EAE is limited to immigrants
age 18 and older who have the option of applying for an SSN at 1 of the
127 State Department posts worldwide that issue immigrant visas. SSA is in
the early stages of planning an evaluation of the first phase of EAE in
conjunction with the State Department and DHS. Also, SSA plans to continue
expanding the program over time to include other noncitizen groups, such
as students and exchange visitors. In addition, SSA recently piloted a
specialized center in Brooklyn, New York, which focuses exclusively on
enumeration and utilizes the expertise of DHS immigration status verifiers
and SSA's OIG investigators.
While SSA has embarked on these new initiatives, it has not tightened
controls in two key areas of its enumeration process that could be
exploited by individuals-citizens and noncitizens alike-seeking fraudulent
SSNs: the assignment of SSNs to children under age 1 and the replacement
of Social Security cards. SSA changed its policy in 2002 to require that
field staff obtain independent, third-party verification of the birth
records for U.S.-born children age 1 and over, but it left in place its
prior policy for children under age 1, which calls only for a visual
inspection of birth documents. In our field work, we found that this lack
of independent verification remains an area vulnerable to fraud. Working
in an undercover capacity by posing as parents of newborns, our
investigators were able to obtain two SSNs using counterfeit documents.
SSA's policy for replacing Social Security cards also increases the
potential for misuse of SSNs. The policy allows individuals to obtain up
to 52 replacement cards per year. Of the 18 million cards issued by SSA in
fiscal year 2002, 12.4 million, or 69 percent, were replacement cards, and
1 million of these cards were issued to noncitizens. While SSA requires
noncitizens applying for a replacement card to provide the same identity
and immigration information as if they were applying for an original SSN,
SSA's evidence requirements for citizens are much less stringent. The
ability to obtain numerous replacement SSN cards with relatively weak
documentation may allow individuals to impersonate others using
counterfeit documents to obtain SSNs for a wide range of illicit uses,
including selling them to noncitizens.
Background
The operational and policy issues that we identified in SSA's enumeration
functions could weaken the integrity of its enumeration system.
Accordingly, we are making several recommendations intended to strengthen
SSA's policies and procedures for issuing SSNs to noncitizens and citizens
and to enhance SSA's coordination and deployment of new initiatives in
this area. In its response to our draft report, SSA agreed with our
recommendations and provided information on planned and current actions
that they believe address them. (SSA's comments are reproduced in appendix
II.) In particular, SSA discussed its efforts to assess field office staff
compliance with its verification requirements as part of its ongoing
enumeration quality reviews, to assess the accuracy of the EAE process,
and to develop options to improve the integrity of its policies for
issuing replacement Social Security cards.
The Social Security Act of 1935 authorized the SSA to establish a
record-keeping system to help manage the Social Security program and
resulted in the creation of the SSN. SSA uses the SSN as a means to track
workers' earnings and eligibility for Social Security benefits. Through a
process known as "enumeration," each person receives a unique number,
which is used for the work and retirement benefit record for the Social
Security program. Today, SSNs are issued to most U.S. citizens, and they
are also available to noncitizens2 lawfully admitted to the United States
with permission to work. Lawfully admitted noncitizens may also qualify
for an SSN for nonwork purposes when a federal, state, or local law
requires that they have an SSN to obtain a particular welfare benefit or
service. SSA must obtain documentary evidence from such applicants
regarding their age, identity, U.S. citizenship, immigration status, and
if they were previously assigned an SSN. SSA's 1,333 field offices'
primary enumeration responsibilities include interviewing such applicants
for both original and replacement Social Security cards, reviewing
identity and immigration documents, verifying immigration and work status
with the DHS and State, and keying information into the agency's automated
enumeration system.
In fiscal year 2002, SSA issued approximately 5.6 million original SSNs
and 12.4 million replacement cards. As shown in table 1, most of the
agency's enumeration workload involves U.S. citizens who generally receive
SSNs
2For our review, we classified noncitizens as (1) immigrants (individuals
who come to the United States to reside permanently, e.g., the alien
spouse of a U.S. citizen) and (2) nonimmigrants (individuals who come to
the U.S. temporarily, e.g., students and visitors).
at birth via states' and certain jurisdictions' birth registration process
facilitated by hospitals.3 However, the bulk of original SSNs issued by
SSA's field offices are for noncitizens. These offices also process
requests for replacement cards-for both citizens and noncitizens.
Table 1: Original SSNs and Replacement Social Security Cards SSA Issued in
Fiscal Year 2002
Numbers in millions
Key areas U.S. citizens Noncitizens Total
Original SSNs issued 4.23a 1.34 5.57
Replacement Social Security cards 11.45 1.00 12.45
issued
Total 15.68 2.34 18.02
SSA Has Increased Verifications and Launched Other Key Initiatives, but
Additional Actions Are Needed
Source: SSA.
aOf the 4.23 million SSNs issued to U.S. citizens in fiscal year 2002, 3.8
million (about 89 percent) were issued under SSA's Enumeration at Birth
(EAB) process, which is not part of the field office workload.
Following the events of September 11, 2001, SSA began taking steps to
place a greater emphasis on improving the integrity of the enumeration
process. For example, to launch these efforts, the Commissioner
established an in-house response team to identify ways to prevent fraud
and formed a task force with the State Department and DHS to formalize and
expedite collaboration on various initiatives designed to improve the
verification of information furnished by noncitizen SSN applicants.
SSA has increased document verifications and begun other new initiatives
to prevent the inappropriate assignment of SSNs to noncitizens, but
additional actions are needed to strengthen the integrity of the process.
SSA now requires third-party verification of all noncitizen documents with
DHS and State prior to issuing an SSN. This verification is required in
addition to existing requirements to inspect documents in-house. However,
many field staff we interviewed are relying heavily on the third-party
verification, while neglecting SSA's in-house practices for verifying
identity documents. SSA has also undertaken new initiatives to shift the
3Under a process called Enumeration at Birth hospitals send birth
registration data to a state or local bureau of vital statistics, where it
is put into a database. SSA accepts the data captured during the birth
registration process as evidence of age, identity, and citizenship and
assigns the child an SSN without further parental involvement.
burden of processing noncitizen applications away from its field offices.
In October 2002, SSA began implementing the first phase of a long-term
process to redesign how it issues SSNs to noncitizens, called "Enumeration
at Entry" (EAE). Under this initiative, State and DHS experts screen SSN
applicants before they enter the United States. SSA is in the early stages
of developing a timetable to evaluate the effectiveness of EAE as well as
to assess the potential for future expansion to other noncitizen groups.
SSA also recently piloted a specialized center in Brooklyn, New York, to
focus exclusively on enumeration and to bring on board expertise from DHS
as well as to utilize SSA's own Inspector General.
SSA Has Stepped Up Document Verification, but Some Weaknesses Exist
SSA has increased document verifications by requiring independent
third-party verification of documents for all noncitizens with the issuing
agency-namely DHS and State-prior to issuing an SSN. This process- called
"collateral verification"4-involves field office staff performing an
on-line query to DHS's Systematic Alien Verification for Entitlements
(SAVE)5 database to verify the immigration and work status of noncitizens.
If the information is not available in SAVE, field staff must mail a
request to DHS seeking verification. In conjunction with this
verification, SSA field staff are required to visually inspect the
immigration and identity documents presented by applicants. SSA has issued
several directives and produced a training video for field offices to
reinforce the policy of making visual inspections of applicant documents
with a variety of forensic tools. These include using an ultraviolet
light, called a "black light," to verify the presence of embedded security
features and comparing documents against sample DHS documents and security
guidelines contained in a binder maintained in each field office.
SSA has also stepped up its verification of documents for foreign students
seeking SSNs, by requiring them to show proof of their full-time
enrollment. However, SSA still does not require its field staff to verify
this information or letters from the school stating that the student is
authorized to work-with the school.6 SSA also does not require that
students actually have a job to qualify for an SSN, only that they have
been authorized by their school to work on campus.7
4As of September 2002, "collateral verification" is now required for all
noncitizens. Under SSA's prior policy, it was only required for those who
have been in the country more than 30 days.
5The SAVE system is the only available data source on the immigration
status of noncitizens. We are aware of limitations in DHS's SAVE data but
have not conducted an independent assessment of the quality of the records
in that system. The Justice Department's Office of the Inspector General
has issued several reports that questioned the reliability, accuracy, and
management controls over nonimmigrant data in the SAVE system. (See
"Immigration and Naturalization Service Monitoring of Nonimmigrant
Overstays," Rept. No. I-97-08, Sept. 1997; "Follow-Up Report On INS
Efforts To Improve The Control Of Nonimmigrant Overstays," Rept. No.
I-2002-006, April 2002; and "Immigration and Naturalization Service's
Ability to Provide Timely and Accurate Alien Information to the Social
Security Administration," Rept. No. I-2003-001, Nov. 2002.)
6Schools accredited by DHS may issue letters authorizing foreign students
to work without notifying DHS or obtaining DHS approval.
7As of our report's issuance, SSA was also seeking authority to require
that students already have an on-campus job before an SSN may be issued.
Figure 1. Required SSA Field Office Procedures for Noncitizen SSN Applications
Source: GAO based on SSA information.
aSSA's procedures call for its staff to refer these cases to SSA's Office
of Inspector General for further review.
Despite SSA's actions to strengthen its processes for issuing SSNs to
noncitizens, some weaknesses exist.
o Field staff rely heavily on SAVE verifications, with the result that
many neglect to perform required in-house, visual inspection of documents
in conjunction with the SAVE verification. Although field office staff can
check the immigration and identity status of an individual through SAVE,
that does not ensure that the documents presented by the applicant are
valid. The agency's only way of detecting whether documents by themselves
are counterfeit is through visual inspections. However, our interviews
with front-line field staff who perform enumeration work in four SSA
regions indicated a potential erosion in the traditional practice of
visually inspecting documents due to an increasing reliance on the SAVE
database. Over a third said they do not routinely use the black light to
verify the authenticity of applicants' immigration documents, and only one
in five staffers we interviewed said they regularly used SSA's
confidential manual of security guidelines and sample documents (known as
the Administrative Confidential Memorandum (ACM)) to check documents
submitted by applicants. Many field staff we interviewed said that the ACM
was not readily accessible; several said they did not know where it was
located in their office. In addition, staff in several offices told us
that their black light did not always work. Since SSA field office staff
are the only persons who actually see the noncitizen's documents, it is
critical that they make use of all available tools to ensure the
authenticity of those documents.8 Nevertheless, more than a fourth of the
field staff we interviewed told us that using the SAVE database to verify
immigration status made visual inspections of documents unnecessary.
o SSA's automated enumeration system allows field staff to bypass key
verification steps and still issue an SSN. Recent improvements to SSA's
automated computer system for assigning SSNs, known as the Modernized
Enumeration System (MES), have not eliminated several weaknesses that
would allow for a breach of security. MES does not contain separate and
distinct fields for field staff to record their use of each of the
required verification procedures. Furthermore, it is possible for staff to
process an SSN application without keying information into MES on the
evidence they have reviewed and accepted. Under this situation, there is
no consistent means for SSA to verify and review what verifications field
staff actually did perform when they processed an SSN application. SSA
8When SSA field office staff question the authenticity of a noncitizen's
documents, they submit photocopies of those documents to DHS to be
verified.
officials told us that they are aware of this problem, but due to budget
reasons, they have yet to develop a formal plan to address it.
o Another automation-related weakness concerns SSA field staff use of
DHS's SAVE system. When field staff perform a SAVE verification, the SAVE
system generates a unique reference number. However, it is possible to
enter a made-up SAVE reference number without having actually verified an
individual's status. This ability to bypass the SAVE system represents an
internal control weakness in SSA's noncitizen enumeration process. SSA
officials told us that it may be possible to modify SAVE so that after SSA
staff successfully verify an individual's immigration status, proof of
that verification would be automatically entered into the MES application,
creating an audit trail. However, SSA officials noted that such a
modification would require creating an interface between DHS's SAVE system
and SSA's MES, and they have not yet fully explored this possibility.
o Verification for foreign students attending U.S. schools also remains
problematic. SSA recently revised its rules to require that students
provide evidence of full-time enrollment at an accredited educational
institution. However, field office staff are not required to verify either
the full-time enrollment or the work authorization letters with the
educational institution. Most field staff we interviewed told us they do
not verify work authorization letters unless they appear questionable. One
staffer told us she assumes a letter is authentic if it is "on
high-quality paper." In addition, managers in two SSA field offices told
us they were unclear about SSA's requirements for enumerating noncitizen
students. A recent investigation by SSA's OIG uncovered a ring of 32
foreign students in four states who used forged work authorization letters
to obtain SSNs. Those students were either indicted for criminal offenses
or taken into DHS custody. However, an unknown number of other students
associated with this ring had already obtained illegal SSNs with forged
work authorization letters. A foreign student Web site that we found
highlights the inconsistencies in SSA's enumeration practices and
advocates that students seeking SSNs "shop around" for offices that are
more likely to grant an application.
"If you are not authorized to work, ask your Foreign Student Advisor for
help. Sometimes they can give you a letter to the SSA stating that you
need a SSN for on-campus employment. Here's a sample letter. If you can't
get this letter at least get a certificate of attendance, preferably
addressed to the Social Security Administration. Sometimes SSA clerks
don't really read these letters, they just look at them. [Emphasis added]
Go to your local SSA office and ask them if you can get a SSN. Regulations
in different offices are different, so try going to several different SSA
offices (this approach
works with many large bureaucracies, like banks and phone companies).
[Emphasis added] Sometimes it even depends on a clerk you talk to. If they
accept your application it means you'll get the number. If they don't
accept it, it isn't recorded anywhere and you can try as many times as you
like." [Emphasis added]
Source: Withheld.
Forged work authorization letters are not the only avenues for fraud in
the enumeration of noncitizen students. Both managers and field office
staff told us that SSA's policy on enumerating students was open to fraud
because it requires only that the student be "authorized to work on
campus," and not that the student actually be working, or even have a job
offer. One district manager, saying that enumerating noncitizen students
for on-campus jobs is "fraught with the potential for fraud," cited
schools operating out of storefronts that nevertheless issued work
authorization letters for students, claiming the students were working "on
campus." According to SSA policy, these students are entitled to receive
SSNs. In addition, one regional official even described schools selling
work authorization letters to students who wished to get SSNs.
SSA headquarters officials said that they were aware of weaknesses
associated with enumerating foreign students and were working on improving
the integrity of these processes. For example, SSA is exploring gaining
access to DHS's foreign student tracking database, the Student and
Exchange Visitor Information System (SEVIS), which would permit the agency
to check if a noncitizen student is enrolled full-time in an accredited
school.9 In addition, SSA officials told us that the agency is in the
process of exploring options to address these weaknesses, such as
requiring foreign students to prove that they actually have an on-campus
job.
SSA Has Begun a Long-Term Initiative to Enumerate Noncitizens before They
Enter the Country
SSA is in the early stages of a long-term process of redesigning how it
issues SSNs to noncitizens, which it calls the "Enumeration at Entry"
(EAE) project. SSA considers EAE to be an essential component of its fraud
prevention efforts that will curtail its current dependence on visually
inspecting and verifying documents that are easily forged or misused.
9Presently, DHS's SEVIS database does not track foreign student on-campus
employment or work authorization. DHS has expressed interest in adding
that information to the data gathered on noncitizen students, but has no
immediate plans to do so.
Under EAE, SSA entered into Memoranda of Understanding (MOU) with State
and DHS for those agencies to assist SSA by obtaining and examining, as
part of immigration processing, all of the information SSA needs to assign
SSNs to immigrants after they enter the United States.10 Since its start
in 2002, EAE has grown from 3 sites in 3 countries to all 127 State posts
worldwide that issue immigrant visas. Currently, EAE is available only to
immigrants age 18 or older who are seeking permanent residence in the
United States, and it is not used for temporary visitors such as students
and exchange visitors. According to SSA, the current phase of EAE will
o improve integrity of the enumeration process by ending field staff
dependence on immigration documents that can be forged or misused by
noncitizens attempting to fraudulently acquire SSNs;
o improve overall government efficiency by eliminating duplication of
data collection by SSA, State, and DHS;
o create financial savings of approximately $5.13 million annually;11 and
o provide a one-stop service for noncitizen SSN applicants, whereby
noncitizens can apply for an immigrant visa and an SSN on the same
application prior to entering the United States.
The EAE process is depicted in figure 2 and begins when an immigrant
applies for a visa at one of State's visa-issuing posts around the world
and continues when the immigrant later arrives at a U.S. port of entry
where DHS performs various immigration and security checks. The process
ends when SSA electronically screens the information provided by DHS for
errors and assigns the individual an SSN.
10Representatives of the Immigration and Naturalization Service (INS) [INS
was transferred to DHS in 2003] and SSA signed a MOU in October 2002 and
December 2002, respectively. SSA also has a 1996 MOU with State.
11SSA's estimated savings are based on a projection of 400,000 immigrants
availing themselves of EAE once the current phase is fully implemented.
SSA calculated the savings by multiplying 400,000 by $13.48 (the SSA field
office unit cost for processing an SSN application) resulting in $5.39
million from which SSA subtracted $263,000 of yearly costs SSA pays DHS
for processing SSN information under EAE. This resulted in an annual
savings estimate of $5.13 million.
During the first 7 months that SSA began receiving records under EAE-
November 2002 through May 2003-SSA reported assigning 9,627 original SSNs
and 5,501 replacement cards12 to immigrants who applied at one of the
State Department's worldwide visa-issuing posts. To date, SSA is having
problems with the accuracy and completeness of the automated EAE records
received, resulting in the agency's need to correct the errors, including
contacting the applicant after he or she enters the country. Problems
include the use of abbreviated data (e.g., using Ma for Maria); the
incorrect use of country codes (e.g., PHI instead of PHL for the
Philippines); and, in some instances, missing data fields (e.g., the city,
state, and zip code of the applicant's place of birth). SSA officials said
that the three agencies have begun working to correct these problems and
anticipate having them resolved in the near future.
12As part of the visa application process, State consulate officials also
ask immigrants who already have an SSN, if they would like SSA to send
them a replacement Social Security card.
Figure 2: SSA's EAE Process for Assigning SSNs to Immigrants Age 18 and Over
According to SSA officials, the agency intends to evaluate the initial
phase of EAE in conjunction with the State Department and DHS after it has
been in full operation for at least a year or at a mutually agreed upon
time. SSA is also planning to begin discussions with DHS and State on
expanding the process to other noncitizen groups, such as students and
exchange visitors. SSA officials told us that, as additional groups of
noncitizens are phased in, it expects to further reduce its field office
enumeration workload. Currently, SSA officials said that they are only in
the early stages of developing a timetable to estimate either when the
agencies would start to evaluate the first phase of EAE or when it would
begin discussions on EAE expansion. SSA officials noted that the expansion
of EAE to nonimmigrant groups, such as students or exchange visitors,
would probably take longer and be more challenging because of the
diversity of the populations and differences in State, DHS, and SSA
information systems and business processes. For example, according to SSA
and DHS officials, the process for transmitting information on groups
other than legal permanent residents13 is not fully automated.
SSA Is Piloting a Specialized Enumeration Center
In November 2002, SSA established a pilot center in Brooklyn, New York, to
specialize in enumeration (now known as the Brooklyn Social Security Card
Center, or BSSCC) wherein its staff is assisted by in-house DHS staff and
focuses full time on enumeration and verification. In addition, SSAOIG
employees are on call to assist the BSSCC's staff. The center provides
citizens and noncitizens residing in Brooklyn a one-stop location for
applying for SSNs and replacement Social Security cards and is the only
location where residents of Brooklyn can receive such services. If a
Brooklyn resident visits one of SSA's 12 Brooklyn offices other than the
BSSCC to apply for a SSN or a replacement card, they are referred to the
center for assistance. As of April 2003, the BSSCC had processed a total
of 44,000 Social Security cards, with 18,000 of those for noncitizens. SSA
officials plan to use this centralized and specialized location to prevent
the inappropriate issuance of SSNs and to expand the concept to other
locations.
According to SSA and DHS officials, a major benefit of the BSSCC is its
specialized personnel and the immediate, on-site verification of documents
submitted by applicants for SSNs and replacement cards. SSA officials told
13Legal permanent residents are immigrants who have been granted
permission to live and work permanently in the United States.
us that the enumeration center staff would become more specialized and
skilled at identifying fraudulent documents as they perform only
enumeration duties. In addition, on-site DHS staff who verify documents
(called status verifiers) have access to DHS databases not available to
SSA staff, and their presence is expected to improve DHS response time and
accelerate the verification of applicant documents. (See table 2 for the
composition of BSSCC's staff.) Also, SSA's New York regional officials
told us that they have experienced a reduced enumeration workload for the
12 neighboring SSA field offices. These officials also told us that the
use of one location for enumeration would increase SSA's control over SSNs
and reduce the issuance of duplicate cards. For example, having only one
center where citizens and noncitizens residing in the service area were
required to apply for SSNs and replacement cards might eliminate the
opportunity for individuals to "shop around" various SSA field offices in
the region, using fraudulent documents in order to obtain an SSN.
Table 2: Composition of BSSCC's Staff Providing agency Type of staff Number of
staff
SSA Manager
Operations supervisor
Management support specialist
Service representative
Teleservice representative
Claims representative
DHS Status verifiera
Total
Source: SSA.
Note: SSA-OIG's New York Office agents are on call to support the BSSCC at
the request of BSSCC's manager.
aDHS initially provided two status verifiers for the BSSCC; as of June
2003, DHS reconsidered the need for these staff and had removed one of
them.
SSA and DHS officials have made some revisions to the BSSCC's staffing
plan. SSA's draft design plan for the center included on-site DHS
investigators, who are experts in identifying fraudulent documents, as
well as SSA-OIG investigators. However, after discussions with SSA, DHS
agreed to provide status verifier staff in the BSSCC, who have access to
DHS databases not available to SSA staff but do not have the technical
expertise to authenticate and identify fraudulent documents. DHS's
decision to place status verifiers in the BSSCC, rather than more
specialized investigators, who are skilled at authenticating and
identifying
fraudulent documents, may diminish SSA's ability to detect fraudulent
documents. Presently the main function of the one status verifier
colocated with SSA staff, is to check DHS databases that are unavailable
to SSA staff, rather than to authenticate documents. Furthermore, SSA's
OIG employees, at one time physically based at the center, are now
available only on an on call basis to assist the BSSCC staff.
Thus far, SSA has encountered workload issues involving returned mail
processed through the BSSCC. According to SSA officials, the postal
service returns mailed Social Security cards processed through the center
as undeliverable at a higher than usual rate for other field offices. SSA
officials told us the mailing errors might be occurring due to problems
associated with a high frequency of similar names for noncitizens who use
the center. However, they have not yet evaluated the returned mail issue
and other performance issues associated with the enumeration center.
According to SSA officials, the BSSCC is operating on a trial basis for a
period of 1 year during which SSA plans to evaluate its effectiveness. SSA
officials told us that they will conduct two studies to evaluate the
center: (1) SSA and DHS are to study if the center is serving the needs of
SSA and if it is cost-effective for DHS to provide on-site status
verifiers and (2) SSA will perform a separate assessment of the center,
which may address issues such as trends in applicants' submission of
fraudulent documents to obtain SSNs.14 However, SSA officials told us that
a consideration of the long-term feasibility of the enumeration center in
relation to SSA's other initiatives to improve the integrity of issuing
SSNs to noncitizens-for example, EAE, is not part of their analysis. This
is a key issue considering that SSA's progress in implementing and
expanding the EAE initiative, whereby noncitizens apply for SSNs prior to
entering the United States, could influence the number of additional card
centers needed, or mitigate the need for such centers altogether in the
long term.
Although SSA is undertaking a number of initiatives specifically
addressing the enumeration of noncitizens, it has not addressed two areas
that are especially vulnerable to fraud by citizens and noncitizens alike:
the assignment of Social Security numbers to children under age 1 and the
replacement of Social Security cards. Although SSA changed its policy in
2002 to require third-party verification of the birth records of U.S.-born
14As of the completion of our audit work, SSA has not yet finalized this
evaluation plan.
SSA's Actions to Tighten Controls Leave Some Key Areas Unaddressed
citizens over age 1, it left in place its prior policy for children under
age 1 that calls only for a visual inspection of birth records. SSA's
policy for replacing Social Security cards allows individuals to obtain up
to 52 replacements a year with no lifetime limit and allows U.S. citizens
to obtain replacement cards with less documentation than an original SSN.
Of the 18 million cards issued by SSA in fiscal year 2002, 12.4 million,
or 69 percent, were replacement cards. Some field staff we interviewed
told us that despite their reservations about individuals who have sought
replacement cards in "excessive" numbers, SSA policy required them to
issue the cards.
Process for Assigning Social Security Numbers to Children under Age 1
Creates Fraud Opportunities
The implementation of SSA's policy of assigning SSNs to children under age
1 may create opportunities for individuals with criminal intent to use
false or stolen birth records to obtain an SSN. While the majority of
newborns in fiscal year 2002 received SSNs at birth through a hospital
registration processes that SSA calls Enumeration-at-Birth (EAB),15 the
parents of about 368,000 U.S.-born children under age 18 applied for an
SSN for their children at field offices using their own birth evidence
documents.16 In 2002, SSA began requiring field offices to verify these
birth records for U.S. citizens age 1 or older with a state or local
bureau of vital statistics. However, SSA exempted records for children
under age 1 from this policy. According to SSA, it excluded children under
age 1 from its third-party verification requirements to limit potential
service disruptions to these applicants due to possible delays in entry of
birth information by some state or local bureaus of vital statistics.
Parents or guardians often need an SSN for their child soon after birth so
they can claim the child as a dependent for tax purposes or because an SSN
is required for such purposes as opening a bank account or applying for
government services.
SSA's decision to verify most birth certificates had been prompted by an
SSA OIG finding that, despite training and guidance, field staff were
15Of the 4.2 million SSNs issued to U.S. citizens in fiscal year 2002,
about 89 percent, or 3.8 million, were issued under SSA's EAB process.
Under EAB, hospitals send birth registration data to a state or local
bureau of vital statistics where it is put into a database. SSA accepts
the data from the birth registration process as evidence of age, identity,
and citizenship and assigns the child an SSN without further parental
involvement.
16SSA does not maintain data on the actual number of children enumerated
outside of the EAB process each year.
unable, by themselves, to detect counterfeit birth certificates.17 In one
case, individuals posing as parents of infants were able to obtain over
1,000 new SSNs based on fraudulent birth certificates.18 Also, the OIG
reported that, without means to independently verify the authenticity of
out-of-state birth certificates, field office staff were less likely to
question this documentation.
We found that SSA's policy to exempt birth records for children under age
1 from third-party verification has left the enumeration process open to
fraud. During our fieldwork, we found an example of a noncitizen who
submitted a counterfeit birth certificate in support of an SSN application
for a fictitious U.S.-born child under age 1. In this case, the SSA field
office employee identified the counterfeit state birth certificate by
comparing it with an authentic one. However, SSA staff acknowledged that
if a counterfeit out-of-state birth certificate had been used, SSA would
likely have issued the SSN because of staff unfamiliarity with the
specific features of the numerous state birth certificates.
Indeed, we were able to prove the ease with which individuals can obtain
SSNs by exploiting SSA's current processes. Working in an undercover
capacity, our investigators were able to obtain two SSNs for children
under age 1 by using counterfeit documents. By posing as parents of
newborns, they obtained the first SSN by applying in person at a SSA field
office using a counterfeit birth certificate; they obtained the second SSN
by submitting the counterfeit birth record via the mail. In both cases,
SSA staff verified our counterfeit documents as being valid. SSA officials
told us that the agency plans to re-evaluate its policy for enumerating
children under age 1 but has no specific time frame for doing so. The
officials also acknowledged that a challenge facing the agency is to
strike a better balance between serving the needs of the public and
ensuring SSN integrity.
SSA Policy on Replacing Social Security Cards Invites Abuse
SSA's policy for replacing Social Security cards, which allows individuals
to obtain up to 52 replacement cards per year; as well as its
documentation requirements for U.S. citizens to obtain replacement cards,
whereby U.S.
17SSA Office of the Inspector General, Procedures for Verifying
Evidentiary Documents Submitted with Original Social Security Number
Applications, A-08-98-41009 (Sept. 2000).
18SSA Office of the Inspector General, Management Advisory Report: Using
Social Security Numbers to Commit Fraud, A-08-99-42002 (May 28, 1999).
citizens can obtain replacement cards with less documentation than an
original SSN, also increases the potential for misuse of SSNs. Of the 18
million cards issued by SSA in fiscal year 2002, 12.4 million, or 69
percent, were replacement cards, and 1 million of these cards were issued
to noncitizens.
SSA field staff we interviewed told us that despite their reservations
regarding individuals seeking high numbers of replacement cards, they are
required under SSA policy to issue the cards. For example, one field
staffer spoke of replacement card applicants who already have made
numerous requests and continue to make new requests.19 Furthermore, many
of the field office staff and managers we spoke with acknowledged that the
current policy weakens the integrity of SSA's enumeration process.
In September 2001, SSA's OIG reported numerous cases in which SSA had
issued replacement cards where potential misuse existed, such as multiple
individuals working under a single name and SSN. 20 For example, the OIG
found that SSA issued 23 replacement cards to a 19-year-old male who had
$113,000 in earnings from 24 employers in 19 states during 1999. In
another case, SSA had issued 12 replacement cards to a 25-year-old male
with a suspect work history: $106,000 in earnings from 12 employers in 8
states and over $10,000 in earnings under his SSN but under a different
name in 1999; $83,000 earnings from 10 employers in 1998; and $60,000 in
earnings from 13 employers in 1997. The OIG concluded, "It is highly
improbable that in 1 year an individual could work for multiple employers
in numerous states and earn significant income from traditionally low
paying jobs, such as those in the agriculture and service industries."
Beyond SSA's policy on providing 52 replacement cards per year, its
identity and document requirements for providing such cards to citizens
could further threaten SSN integrity. While SSA requires noncitizens
applying for a replacement card to provide the same identity and
immigration information as if they were applying for an original SSN,
SSA's evidence requirements for citizens are much less stringent. (See
19SSA's automated system shows field staff how many times an individual
has applied for a replacement card, which office processed the
application, and when it was processed.
20SSA Office of the Inspector General, Replacement Social Security Number
Cards: Opportunities to Reduce the Risk of Improper Attainment and Misuse,
A-08-00-10061 (Sept. 2001).
table 3.) Citizens are not required to prove their U.S. citizenship and
can apply for a replacement card without photograph identification, using
documentation such as a school report card, church membership record, or a
life insurance policy. This represents a vulnerability in the application
process due to the ease with which identity documents, especially those
without photographs, can be forged. Thus, an individual could easily
impersonate a legitimate SSN cardholder to obtain large numbers of
replacement cards for a wide range of illicit uses, including selling them
to noncitizens.
Table 3: Comparison of Identity, Age, and Citizenship Requirements for
U.S. Citizens Applying for Original SSNs and Replacement Cards.
Original SSN requirements Replacement card requirements
Proof of identity
(Any one or a combination of the following)
o Driver's license
o U.S. passport
o School ID card
o School record
o School report card
o Marriage or divorce record
o Adoption record
o Health insurance card (except Medicare card)
o Life insurance policy
o Clinic, hospital, or doctor records
o Church membership or confirmation record
Proof of identity
Same as for an original SSN.
Proof of age Proof of age
(Any one or a combination of the following) Only required if there is a
discrepancy between the date of birth on
o U.S. birth certificate the application and the evidence presented with
the application.
o Religious record established before age 5 showing age
o Notification of birth registration
Proof of U.S. citizenship
(Any one of the following)
o U.S. passport
o U.S. birth certificate
o Religious record recorded in the U.S. within 3 months after birth
o Certificate of naturalization
o Certificate of citizenship
o Adoption finalization papers
o Other document that establishes a U.S. place of birth or U.S.
citizenship
Proof of U.S. citizenship
Not necessary.
Source: GAO analysis of SSA's enumeration procedures.
Note: The above lists are not all-inclusive and differ for children under
age 1.
In our audit work, we identified Web sites and publications that give
"how-to" guidance and design samples to assist individuals in making
counterfeit documents that can be used in support of an application for
either a new SSN or a replacement card, such as school cards, baptismal
certificates, and hospital records. In addition, one guide offered tips on
getting SSNs through the mail using such counterfeit documents.
"Generally, there are two ways that one can receive a [... ] social
security number. Through the mail or in-person at the local social
security office. I would suggest that you try to do everything through the
mail...In my opinion,...you should never go to the SS office in person.
[Emphasis added] Obviously, if there is a problem with your documents and
you need to walk away from the process, with a mail drop, you simply close
it and walk away. There is no more connection to you, but to be fair, I
have never heard of a problem at the SSN office."
Source: Withheld.
SSA officials told us the agency is considering limiting the number of
replacement cards to 2 per year and 10 cards over an individual's
lifetime, with certain exceptions for name changes, administrative errors,
and hardship. However, SSA officials cautioned that while support exists
for this change within the agency, some advocacy groups, such as those
representing the homeless and mentally ill, oppose such a limit. At the
completion of our audit work, it was unclear whether SSA would address the
weaknesses in its document requirements for providing replacement cards to
citizens. Until SSA changes its policy in this area, there will be an
increased chance that both citizens and noncitizens seeking to
fraudulently obtain SSNs may target this vulnerable area.
SSA has made substantial progress toward strengthening its processes for
issuing SSNs to noncitizens through initiatives that involve improvements
to old procedures as well as broad new approaches. Indeed, the agency has
taken a step it has never before attempted by requiring that the
immigration and work status of every noncitizen applicant be verified
through an independent third-party source before an SSN is issued.
However, without further systems improvements and staff compliance with
all prescribed verification procedures, this initiative may not
sufficiently prevent the issuance of SSNs to individuals seeking to
fraudulently obtain them.
Beyond changes to its verification procedures, SSA's ability to
corroborate the immigration status and identity information of noncitizen
applicants may be further enhanced by newly implemented initiatives such
as EAE and the BSSCC. SSA's collaboration with the Departments of State
and Homeland Security through the EAE initiative brings additional
resources to bear on noncitizen applications. However, because this
program represents a considerable change to the enumeration process, it
merits a thorough evaluation to overcome operational problems and to
identify
Conclusions
changes that may be needed before it is expanded to other noncitizen
groups.
Similarly, specialized enumeration centers that combine the expertise of
SSA and DHS examiners have the potential to better deter SSN fraud and
identity theft, as well as improve the timeliness and accuracy of the
service SSA provides. Because EAE will not be fully realized for many
years, the enumeration center concept may also represent a viable
near-term strategy for concentrating expertise in key geographic regions
to process SSNs for applicants already in the country. However, a
comprehensive evaluation of the effectiveness of the BSSCC, as well as an
assessment of the long-term viability of additional centers in the face of
future EAE expansion are needed to help SSA think more strategically about
how it can be best positioned to ensure the integrity of its enumeration
process.
Finally, SSA's substantial efforts may be undercut by other
vulnerabilities that remain unaddressed. As SSA closes off many avenues of
unauthorized access to SSNs, perpetrators of fraud will likely shift their
strategies to less protected areas. In particular, SSA's policies for
enumerating children under age 1 and providing replacement cards may well
invite such activity, unless they, too, are modified.
To strengthen the integrity of SSA's policies and procedures for
enumerating noncitizens, we recommend that the Commissioner of Social
Security take the following actions:
o Perform systematic reviews of field office compliance with
verification requirements for enumerating noncitizens and identify
corrective actions needed to ensure maximum effectiveness of this process.
o Enhance the Modernized Enumeration System to prevent staff from
issuing SSNs without following required verification procedures.
o Develop and implement a structured evaluation plan to assess the
initial operation of the EAE initiative and identify SSA, State
Department, and DHS business process changes needed to expand EAE to
additional groups of noncitizens. For the initial phase of EAE, this
evaluation should determine the accuracy of SSN issuance decisions and
causes of operational weaknesses. To assist SSA in moving forward on EAE
expansion, the assessment should identify categories of noncitizens to
which EAE can and should be expanded as well as additional data
Recommendations
collection and changes to automated systems that will be needed by all
three participating agencies.
o Evaluate the BSSCC to assess the feasibility of expansion to other
locations and interaction with SSA's other initiatives to improve the
integrity of SSN issuance to noncitizens. This should include an
assessment of the (1) need and role of possible future centers in relation
to the agency's plans to expand EAE; (2) accuracy of SSN issuance
decisions, its value as a fraud detection and prevention tool, and its
impact on surrounding field office workloads; and (3) the costs and
benefits of how such centers would function without DHS staff on-site.
o Revise its requirement for verification of the birth records of U.S.
citizens who apply for an SSN to require third-party verification of the
birth records of children under age 1.
o Reassess SSA's policies for issuing replacement Social Security cards
and develop options for deterring abuse in this area.
Agency Comments
We obtained written comments on a draft of this report from the
Commissioner of SSA. SSA's comments are reproduced in appendix II. SSA
agreed with our recommendations to strengthen its policies and procedures
for issuing SSNs to noncitizens and citizens alike and to enhance
coordination and deployment of new initiatives in this area. SSA also
provided information on planned and current actions that it believes
address our recommendations. In particular, SSA discussed its efforts to
assess field office staff compliance with its verification requirements as
part of its ongoing enumeration quality reviews, to assess the accuracy of
the EAE process, and to develop options to improve the integrity of its
policies for issuing replacement Social Security cards. SSA also provided
technical comments on our draft report, which we incorporated where
appropriate.
We are sending copies of this report to the Commissioner of SSA, the
Secretary of Homeland Security, the Secretary of State, and other
interested parties. Copies will also be made available to others upon
request. In addition, the report will be available at no charge on GAO's
Web site at http://www.gao.gov. If you have any questions concerning this
report, please call me on (202) 512-7215. Key contributors to this report
are listed in appendix III.
Sincerely yours,
Barbara D. Bovbjerg Director, Education, Workforce, and Income Security
Issues
Appendix I: Scope and Methodology
The Chairman, Subcommittee on Social Security, House Committee on Ways and
Means asked us to describe and assess the Social Security Administration's
(SSA) initiatives to ensure the appropriate issuance of Social Security
Numbers (SSNs) to noncitizens and to identify vulnerabilities to error or
fraud SSA has not yet addressed. To address the Chairman's questions, we
examined SSA's enumeration policies and procedures and obtained
information on key initiatives planned and undertaken to strengthen SSA's
processes to ensure the integrity of the enumeration process. We also
reviewed SSA's current noncitizen enumeration processes to identify areas
where existing and recent changes to its Program Operations Manual System
(POMS) were not being followed or the POMS guidance was not sufficient to
ensure the integrity of the enumeration process. We collected and analyzed
implementing documentation and available performance data on the
timeliness, accuracy, and workload impacts for key noncitizen enumeration
initiatives, including Enumeration at Entry (EAE), Collateral
Verification, and Enumeration Centers. We analyzed the results of prior
reviews and studies performed by SSA's Office of the Inspector General
(OIG) and Office of Quality Assurance. In addition, we reviewed studies
and data provided by the Department of Homeland Security (DHS) and
Department of State on their specific agency processes that support SSA's
noncitizen enumeration initiatives. We also analyzed our prior reports,
related documents, and audits performed by the Inspectors General at the
Departments of State and Justice. We conducted our review at SSA
headquarters in Baltimore, Maryland, and in 4 of its 10 regional offices-
Atlanta, Georgia; Chicago, Illinois; New York, New York; and San
Francisco, California (and at 17 field offices in those regions). We
selected the regional and field offices based on the following criteria
(1) enumeration workload-the locations represented about 70 percent of
noncitizen enumerations in 2001; (2) geographic distribution-the regions
are dispersed across the nation, representing border and inland locations;
and (3) best practices-locations trying innovative approaches to
enumeration, such as the Brooklyn, New York, Social Security Card Center
(BSSCC). We also collected and analyzed data and documents on SSA's
enumeration initiatives and workloads.
We documented officials' perspectives on SSA's enumeration initiatives and
identified areas where vulnerabilities and gaps exist in SSA's
implementation of these policies from our in-depth interviews with more
than 100 management and line staff. From our analysis of documents and
data obtained during fieldwork, we were able to identify significant
problems and issues associated with implementing these initiatives.
Furthermore, we identified best practices developed at the regional or
Appendix I: Scope and Methodology
local levels that have the potential to improve the integrity of SSN
issuance to noncitizens nationally. Also, our investigators tested SSA's
enumeration practices by posing as parents of newborns and used
counterfeit documents to obtain SSNs from an SSA field office and though
the mail. We performed our work from September 2002 through July 2003 in
accordance with generally accepted government auditing standards.
Appendix II: Comments from the Social Security Administration
Appendix II: Comments from the Social Security Administration
Appendix II: Comments from the Social Security Administration
Appendix II: Comments from the Social Security Administration
Appendix II: Comments from the Social Security Administration
Appendix II: Comments from the Social Security Administration
Appendix III: GAO Contacts and Staff Acknowledgments
GAO Contacts
Staff Acknowledgments
(130201)
Barbara Bovbjerg, (202) 512-7215
Daniel Bertoni, (202) 512-5988
Anthony J. Wysocki, (202) 512-6016
In addition to those named above, the following team members made key
contributions to this report throughout all aspects of its development:
Patricia M. Bundy, William E. Hutchinson, Eileen Peguero, and Jill D.
Yost. In addition, Susan C. Bernstein, Andrew O'Connell, and Roger J.
Thomas made contributions to this report.
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