    Social Security Administration: Improved Agency Coordination
    Needed for Social Security Card Enhancement Efforts (29-MAR-06,
    GAO-06-303).

    The Social Security Administration (SSA) has issued more than 430
    million Social Security numbers (SSN) and cards since the Social
    Security program began in 1935, of which an estimated 300 million
    belong to living number holders. SSNs have a key role in
    verifying individuals' authorization to work in the United
    States, but SSN cards are also vulnerable to theft and
    counterfeiting. The Intelligence Reform and Terrorism Prevention
    Act of 2004 requires that SSA consult with the Department of
    Homeland Security (DHS), form a task force, establish standards
    for safeguarding the SSN and card, and provide for implementation
    by June 2006. Concerns about unauthorized workers and the use of
    counterfeit documents led the Chairman of the House Judiciary
    Committee to ask that GAO (1) review SSA's progress to safeguard
    the SSN and enhance the card as required under the Intelligence
    Act, (2) identify key issues to be considered before enhancing
    the card, and (3) outline the range of options available to SSA
    for enhancing the card.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-06-303
        ACCNO:   A50317
      TITLE:     Social Security Administration: Improved Agency
    Coordination Needed for Social Security Card Enhancement Efforts
         DATE:   03/29/2006
      SUBJECT:   Authorization
    	     Biometrics
    	     Eligibility determinations
    	     Employment
    	     Federal social security programs
    	     Forgery
    	     Fraud
    	     Identification cards
    	     Internal controls
    	     Safeguards
    	     Social security number
    	     Standards
    	     Identity verification
    	     Counterfeiting

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    GAO-06-303

         * Results in Brief
         * Background
              * Social Security Cards and Noncitizen Employment Eligibility
              * Efforts to Enhance the Card and Drivers' Licenses
         * SSA Has Made Progress on Intelligence Act Provisions, but Sl
              * Replacement Cards Limited
              * Minimum Standards for Verifying Documents Established
              * Birth Certificates for Card Applicants under Age 1 Independe
              * Progress Made on Enumeration at Birth Process
              * Work on Death Indicators Taken and Fraud Indicators Initiate
              * SSA Has Moved Slowly to Convene the Interagency Task Force f
         * The Difficulty of Counterfeit-proofing the Card, the Role th
              * A Counterfeit-proof Social Security Card Is Difficult to Dev
              * The Card Is a Weak Link in the Employment Verification Proce
              * Real ID Act May Improve Links to the Card and Employment Eli
         * A Range of Enhancement Options Exists, and Costs Would Vary
              * Options for Enhancing Cards
                   * Adding secure features to the paper card
                   * Adding machine--readable features
                   * Adding biometric features
                   * Eliminating the card
              * Factors Affecting the Cost of Card Options
              * Issuance Options Affect Cost
                   * Mass issuance
                   * Staggered issuance
         * Conclusions
         * Recommendation for Executive Action
         * Agency Comments
         * GAO Contact
         * Staff Acknowledgments
         * GAO's Mission
         * Obtaining Copies of GAO Reports and Testimony
              * Order by Mail or Phone
         * To Report Fraud, Waste, and Abuse in Federal Programs
         * Congressional Relations
         * Public Affairs

    Report to the Chairman, Committee on the Judiciary, House of
    Representatives

    United States Government Accountability Office

    GAO

    March 2006

    SOCIAL SECURITY ADMINISTRATION

    Improved Agency Coordination Needed for Social Security Card Enhancement
    Efforts

    Social Security Administration
    GAO-06-303

    Contents

    Letter 1

    Results in Brief 3
    Background 6
    SSA Has Made Progress on Intelligence Act Provisions, but Slow Action to
    Form the Interagency Task Force May Limit Card Enhancement Efforts 9
    The Difficulty of Counterfeit-proofing the Card, the Role the Card Has in
    the Employment Verification Process, and Improvements to Drivers' Licenses
    Are Critical Issues to Consider 15
    A Range of Enhancement Options Exists, and Costs Would Vary 23
    Conclusions 32
    Recommendation for Executive Action 32
    Agency Comments 33
    Appendix I Scope and Methodology 37
    Appendix II Department of Homeland Security Form I-9 39
    Appendix III Comments from the Department of Homeland Security 42
    Appendix IV Comments from the Social Security Administration 44
    Appendix V GAO Contact and Staff Acknowledgments 49
    Related GAO Products 50

    Tables

    Table 1: Original SSNs and Replacement Social Security Cards Issued in
    Fiscal Year 2005 7
    Table 2: Social Security Administration Timeline for Implementing Social
    Security Card Enhancements 13
    Table 3: Examples of Fraudulent Social Security Card Activity 16
    Table 4: Acceptable Documents in the Employment Verification Process 18
    Table 5: Requirements for State-Issued Drivers' Licenses or ID Cards under
    the Real ID Act of 2005 22
    Table 6: Factors that Affect Costs of Enhanced Card Options 30
    Table 7: Card Issuance Options 31

    Figures

    Figure 1: Interagency Task Force Required by the Intelligence Act,
    November 2005 14
    Figure 2: Examples of Possible Social Security Card with Reverse Showing
    Magnetic Stripe and Secure Bar Code 25
    Figure 3: Examples of Biometrics-Fingerprint, Facial Recognition, and
    Photograph 27

    Abbreviations

    DHS Department of Homeland Security OIG Office of the Inspector General
    SSA Social Security Administration SSN Social Security number

    This is a work of the U.S. government and is not subject to copyright
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    its entirety without further permission from GAO. However, because this
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    separately.

    United States Government Accountability Office

    Washington, DC 20548

    March 29, 2006 March 29, 2006

    The Honorable F. James Sensenbrenner, Jr. Chairman Committee on the
    Judiciary House of Representatives The Honorable F. James Sensenbrenner,
    Jr. Chairman Committee on the Judiciary House of Representatives

    Dear Mr. Chairman: Dear Mr. Chairman:

    The Social Security Administration (SSA) has issued more than 430 million
    Social Security numbers (SSN) and cards since the Social Security program
    began in 1935. SSA uses the number to track workers' earnings and
    eligibility for Social Security benefits, while the card serves as an
    individual's record of the number. Over the years, the SSN is increasingly
    used as a unique personal identifier by government agencies and businesses
    to maintain records and by individuals to file tax returns, open bank
    accounts, apply for credit, and conduct consumer transactions. Since
    passage of the Immigration Reform and Control Act of 1986, Social Security
    cards, drivers' licenses, birth certificates, and other documents are also
    used to verify individuals' eligibility to work in the United States as
    well as apply for government benefits. However, these documents can and
    have been altered, counterfeited, or stolen to gain access to legitimate
    documents, create false identities, obtain employment, or commit financial
    crimes. The National Commission on Terrorist Attacks upon the United
    States (the 9/11 Commission) reported that all but one of the hijackers
    had acquired U.S. identification documents, some by fraud. The 9/11
    Commission recommended that the federal government strengthen the issuance
    standards for birth certificates and drivers' licenses, and subsequent
    legislation also included Social Security cards. The Social Security
    Administration (SSA) has issued more than 430 million Social Security
    numbers (SSN) and cards since the Social Security program began in 1935.
    SSA uses the number to track workers' earnings and eligibility for Social
    Security benefits, while the card serves as an individual's record of the
    number. Over the years, the SSN is increasingly used as a unique personal
    identifier by government agencies and businesses to maintain records and
    by individuals to file tax returns, open bank accounts, apply for credit,
    and conduct consumer transactions. Since passage of the Immigration Reform
    and Control Act of 1986, Social Security cards, drivers' licenses, birth
    certificates, and other documents are also used to verify individuals'
    eligibility to work in the United States as well as apply for government
    benefits. However, these documents can and have been altered,
    counterfeited, or stolen to gain access to legitimate documents, create
    false identities, obtain employment, or commit financial crimes. The
    National Commission on Terrorist Attacks upon the United States (the 9/11
    Commission) reported that all but one of the hijackers had acquired U.S.
    identification documents, some by fraud. The 9/11 Commission recommended
    that the federal government strengthen the issuance standards for birth
    certificates and drivers' licenses, and subsequent legislation also
    included Social Security cards.

    The Intelligence Reform and Terrorism Prevention Act of 2004 requires that
    SSA consult with the Department of Homeland Security (DHS) and form an
    interagency task force to establish standards to better protect the SSN
    and card from counterfeiting, tampering, alteration, and theft, and
    provide for the implementation of security requirements including
    standards for safeguarding Social Security cards from counterfeiting and
    theft by June 2006. Although SSA is responsible for issuing the card, DHS
    monitors employers who are responsible for certifying the authenticity of
    documents, such as the card, when presented as proof of eligibility to
    work. Congressional concerns about identification documents and questions
    about unauthorized workers prompted your request for us to The
    Intelligence Reform and Terrorism Prevention Act of 2004 requires that SSA
    consult with the Department of Homeland Security (DHS) and form an
    interagency task force to establish standards to better protect the SSN
    and card from counterfeiting, tampering, alteration, and theft, and
    provide for the implementation of security requirements including
    standards for safeguarding Social Security cards from counterfeiting and
    theft by June 2006. Although SSA is responsible for issuing the card, DHS
    monitors employers who are responsible for certifying the authenticity of
    documents, such as the card, when presented as proof of eligibility to
    work. Congressional concerns about identification documents and questions
    about unauthorized workers prompted your request for us to review SSA's
    efforts under the Intelligence Act.1 In response to the request, we (1)
    reviewed the progress of SSA's efforts to safeguard the SSN and enhance
    the card as required under the act, (2) identified key issues to be
    considered before enhancing the card, and (3) outlined the range of
    options available to SSA for enhancing the card.

    In conducting our review, we met with officials from the Social Security
    Administration and the Department of Homeland Security. We also met with
    officials from the Government Printing Office who administer the contract
    for printing Social Security cards. We documented key issues SSA should
    consider as it proceeds with changing the Social Security card by
    interviewing officials from SSA, DHS, the American Association of Motor
    Vehicle Administrators, and state motor vehicle administrators in
    Illinois, West Virginia, and Wyoming. We selected these three states
    because they used various security features in their drivers' licensing or
    identification processes such as fingerprinting, advanced optical printing
    and inks, or holograms and other features, which already met stated or
    anticipated federal legislative requirements for improving drivers'
    licenses and identification cards. We reviewed identification initiatives
    using biometrics at the United States Visitor and Immigrant Status
    Indicator Technology program and the Transportation Security
    Administration's Registered Traveler program.2 Finally, we met with
    employer association groups identified by the U.S. Chamber of Commerce. To
    examine the range of options available to SSA for enhancing the card, we
    researched and analyzed technical literature; identified card
    technologies; interviewed biometrics technology experts, vendors, and
    industry associations; and consulted the National Institute of Standards
    and Technology. We also met with Banknote Corporation of America, the
    contractor that prints Social Security cards, to discuss advances in
    security printing techniques. We performed our work between April 2005 and
    January 2006 in accordance with generally accepted government auditing
    standards. Appendix I discusses our scope and methodology in greater
    detail.

    1As used in this report, the Intelligence Act refers to the Intelligence
    Reform and Terrorism Prevention Act of 2004, Pub. L. No. 108-458 (2004).

    2Biometrics is a technology that uses automated methods of recognizing a
    person based on analyzing physiological or behavioral characteristics such
    as fingerprints or facial features among others.

                                    Results in Brief

    The Social Security Administration has implemented several Intelligence
    Act provisions intended to help safeguard the SSN and the card, and made a
    preliminary decision to add improved security features to the card before
    convening the interagency task force that was required to develop
    safeguards for the card. SSA has implemented measures to limit the number
    of replacement cards, verify birth certificates for applicants under age
    1, and improve the application process of the Enumeration at Birth
    Program.3 SSA has also taken action to include death indicators and
    initiated action to include fraud indicators in its database.
    Additionally, SSA set eight specific tasks and timelines to develop
    safeguards for enhancing the card before reaching the statutory
    implementation date of June 17, 2006. Three tasks were expected to be
    completed before convening the interagency task force and thereby
    involving DHS-researching the range of available security features, coming
    to an internal agreement on new security features for the paper card, and
    developing a publicity campaign for the new card. SSA officials told us
    that a preliminary decision had been made to develop an improved version
    of the current paper card and issue the improved cards only to new card
    applicants. Although the card plays a significant role in verifying
    individuals' authorization to work, SSA did not consult with DHS as it
    worked for nearly a year on these three tasks. Further, SSA did not
    convene the task force until late January 2006, allowing the task force
    less than 6 months to consider critical issues that affect card
    enhancement options before new safeguards are to be established in June
    2006. SSA is required to provide for the implementation of security
    requirements by the same date. These officials told us that the agency is
    unlikely to take action beyond enhancing features of the paper card
    without specific legislative direction to do so.

    The difficulty of counterfeit-proofing the card, the role the card has in
    determining employment eligibility, and ongoing enhancements to state
    drivers' licenses and identification cards are critical issues to consider
    before enhancing the Social Security card. Counterfeit protections were
    first put on the card in 1983, but older versions of the card remain in
    circulation, and all cards, including those issued before counterfeit
    protections were put in place, are still valid. Use of these older
    versions of the card would adversely affect the intended benefits of a
    newly enhanced card. Additionally, when SSA began issuing Social Security
    cards in 1936, individuals applying for a card were not required to
    provide information useful for determining employment eligibility, such as
    evidence of age, identity, or citizenship status-not until 1978 were all
    persons required to provide this information. Since older cards never
    established employment eligibility, employers cannot be certain if
    individuals with older Social Security cards are eligible to work.
    However, the Social Security card is a key document for verifying an
    individual's authorization to work. Prior GAO work shows that the
    employment verification process is jeopardized by document and identity
    fraud, the wide array of documents that applicants can present, weak
    worksite enforcement, and flaws in the voluntary electronic verification
    system.4 To improve the employment verification process, DHS is currently
    considering reducing the number of acceptable documents permitted to
    verify employment eligibility. Further, recent legislation will require
    states to verify the Social Security numbers and legal presence of
    individuals applying for state drivers' licenses and identification
    cards---linking the estimated 250 million licenses and identification
    cards to the Social Security number and immigration documents. These
    improved licenses and identification cards could improve the employment
    verification process. However, they are not meant to prove employment
    eligibility, since states are not required to determine and note worker
    status when verifying the Social Security number with SSA and immigration
    documents with DHS.

    3Since 1989, SSA has used the voluntary Enumeration at Birth Program to
    allow parents the option of requesting SSNs for their newly born children
    at the birth facilities rather than having to visit an SSA field office.

    Once these critical issues are considered, a variety of options exist for
    enhancing the card, ranging from enhancing the paper card to adding
    machine-readable or biometric features such as photographs and
    fingerprints, to eliminating the card entirely. Additionally, the costs of
    implementing each option will vary. First, the paper card could be made
    more counterfeit-resistant with features such as the use of paper with a
    fiber content that reacts to certain chemicals or security threads similar
    to those used in U.S. paper currency. Second, the card could be plastic
    and include some machine-readable features such as a magnetic strip or
    secure bar code; employers would use automated equipment to determine an
    individual's employment eligibility status. Third, the card could include
    some form of biometrics that links the card to the cardholder, such as a
    fingerprint or a photograph. Finally, SSA could eliminate the card and
    instead issue a letter with an individual's Social Security number; in the
    absence of the card, employers could use a system such as Basic Pilot, or
    some similar system, to verify employment eligibility through SSA and DHS
    using the Social Security number or Alien number provided by the worker in
    combination with an identification document such as a driver's license.
    Each option provides different alternatives for improving the ability to
    verify employment eligibility. Choosing the type of card and the method
    for issuing new cards will have a significant effect on costs and the
    agency's workload. For example, if cards are machine-readable or require a
    fingerprint or photograph, additional infrastructure will be needed to
    obtain and read these features. Reissuing new cards to all 300 million
    current cardholders could improve the cards' counterfeit resistance and
    strengthen the card as a worker authorization document, but would be
    costly. Staggering issuance of an enhanced card to certain groups, such as
    those who change jobs, would require a lower initial investment of
    resources. Decisions about the card's role for SSA as well as in
    employment eligibility authorization will be crucial to determining the
    most cost-effective strategy for enhancing the card.

    4GAO, Immigration Enforcement: Weaknesses Hinder Employment Verification
    and Worksite Enforcement Efforts, GAO-05-813 (Washington, D.C.: Aug. 31,
    2005), and GAO, Social Security: Better Coordination among Federal
    Agencies Could Reduce Unidentified Earnings Report, GAO-05-154
    (Washington, D.C.: Feb. 4, 2005).

    As the SSA-led task force develops ways to protect the Social Security
    card, we are making a recommendation to the Secretary of Homeland Security
    and the Commissioner of Social Security to work together to resolve the
    weaknesses of the Social Security card in proving employment eligibility.

    In response to our draft report, DHS agreed that much could be done on an
    interagency basis to improve the integrity of Social Security cards and
    numbers as required under the Intelligence Act. DHS stated that
    determining what to do to make the card more secure or eliminating the
    card altogether appears to be appropriate, and DHS will continue to work
    with SSA through the interagency task force. SSA said that it agreed in
    part with our recommendation; although SSA stated that some aspects of the
    recommendation were outside the scope of what Congress provided in the
    Intelligence Act, SSA said it would continue to work with DHS on issues
    related to employment eligibility and verification. SSA also expressed
    concern that current law requires that the Social Security card be made of
    banknote paper, and thus limits the task force's consideration of
    improvements. SSA also suggests that requirements under the Real ID Act
    could be modified so that drivers' licenses could be made to reflect work
    authorization. DHS and SSA's comments are reproduced in appendixes III and
    IV.

                                       Background

    The Social Security Act of 1935 authorized a record-keeping system to help
    manage the Social Security program and resulted in the creation of the
    SSN. SSNs are now issued to most U.S. citizens at birth. They are also
    available to noncitizens 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 public benefit or service. SSA is
    responsible for paying retirement, survivors', and disability benefits to
    eligible insured persons based on their lifetime earnings in covered
    employment. SSA maintains a historical record of each worker's annual
    earnings, which are identified by the worker's name and SSN.

    Social Security Cards and Noncitizen Employment Eligibility

    Since the Social Security program began, SSA has issued over 430 million
    Social Security numbers and cards, of which an estimated 300 million
    represent living number holders.5 As shown in table 1, in fiscal year
    2005, SSA issued a total of 17.5 million SSN cards to U.S. citizens and to
    noncitizens, of which about 12.1 million were replacement cards. SSA
    issues replacement cards when individuals' cards are lost, stolen, or
    require corrections to the original card. In fiscal year 2005, SSA issued
    about 4.3 million original SSNs to U.S. citizens, of which 3.9 million
    SSNs were issued to newborns through the voluntary Enumeration at Birth
    Program. Under this program, parents can request SSNs and cards for
    newborns at hospitals and other facilities at birth. The Enumeration at
    Birth Program eases SSA's work demands in its approximately 1,300 field
    offices because parents using the Enumeration at Birth Program generally
    do not need to visit SSA field offices.

    5SSNs are assigned for the life of the number holder and remain valid
    indefinitely even after a number holder's death for the purposes of
    administering survivor benefits.

    Table 1: Original SSNs and Replacement Social Security Cards Issued in
    Fiscal Year 2005

    Numbers in millions
                                         U.S. citizens Noncitizens Overall Total
    Original SSNs and cards issued             4.28        1.12          5.40
    Replacement Social Security cards         11.27        0.81         12.08
    Total                                    15.55a       1.94a        17.48a

    Source: SSA.

    aTotals by category may not equal overall total because of rounding.

    The card has also become a document used in controlling unauthorized work.
    In 1986, Congress enacted the Immigration Reform and Control Act to help
    reduce the attraction of employment to illegal aliens coming to this
    country.6 The act made it illegal for individuals and entities to
    knowingly hire, continue to employ, or recruit unauthorized workers. The
    act required employers to review documents that established newly hired
    workers' identity and eligibility to work in the United States and to sign
    statements certifying that the documents they review, such as a Social
    Security card, appear genuine and refer to the prospective worker. DHS has
    responsibility for implementing and enforcing the act and has authorized a
    combination of 27 documents that employees can choose from and provide to
    prove identity and eligibility to work. See appendix II for DHS's Form
    I-9, which contains a list of the documents used to verify employment
    eligibility.

    Efforts to Enhance the Card and Drivers' Licenses

    As uses for the SSN have grown, misuses of the number and counterfeiting
    of the card have increased. Since the SSN's creation, SSA has used the
    same basic wallet-sized card but included additional information on the
    card to meet the evolving role of the SSN. At present, there are 50 valid
    versions of the card-many of which have little or no counterfeit
    protection. On several occasions, Congress considered directing SSA to
    issue cards that were more resistant to tampering and counterfeiting. In
    1983, the Social Security Act was amended to require that the card be made
    of banknote paper and to the maximum extent practicable be a card that
    cannot be counterfeited. Later that year, SSA introduced a card with
    security features including tinted patterns that show when information is
    erased, small multicolored discs randomly placed on the paper, and special
    raised ink. Some members of Congress subsequently expressed disappointment
    that these security features did not make the card significantly more
    difficult to counterfeit and that employers could not easily determine the
    card's authenticity for employment authorization purposes. In 1996,
    Congress asked SSA to study and report on different methods for improving
    the Social Security card and develop a prototype of a
    counterfeit-resistant Social Security card. In the report, SSA provided
    several options for enhancing the card, along with estimated costs, but
    did not recommend options for implementation. In 1998, we reviewed SSA's
    estimates and agreed that a mass issuance of a more secure card would cost
    billions of dollars but concluded that alternative approaches to issuing
    new cards may provide a more cost-effective approach to verifying
    individuals' authorization to work.

    6Pub. L. No. 99-603, (1986), 8 U.S.C.S: 1324a et seq.

    Since the terrorist attacks of September 11, 2001, Congress has focused
    attention on verifying identity and protecting American forms of
    identification. In December 2004, Congress enacted the Intelligence Act,
    which required improvements to birth certificates, drivers' licenses, and
    Social Security cards. Under the act, minimum standards for birth
    certificates are to be established, such as certifications by state or
    local governments that they issued the document, the use of safety paper
    or an alternative, the use of a seal representing the issuing government
    entity and other features designed to prevent fraud. For the Social
    Security card, the act required improvements to the process for issuing
    the card and required that the Social Security Commissioner consult with
    the Secretary of Homeland Security to form a task force for the purpose of
    safeguarding Social Security cards and numbers. Within an 18-month time
    frame following the December 2004 enactment of the act, the task force is
    to establish

               o  standards for safeguarding Social Security cards from
               counterfeiting, tampering, alteration, and theft;

               o  requirements for verifying documents submitted for the issuance
               of replacement cards; and

               o  actions to increase enforcement against the fraudulent use or
               issuance of Social Security numbers and cards.

    The SSA Commissioner is to provide for the implementation of such security
    requirements by June 2006.

    In 2005, Congress enacted the Real ID Act, which, among other things
    amended the security requirements of the Intelligence Act for state
    drivers' licenses.7 Under the Real ID Act, the Secretary of Homeland
    Security must determine whether states meet certain minimum security
    requirements for drivers' licenses and personal identification cards. The
    law provides that, in order to be federally recognized, the state-issued
    card must have certain physical security features designed to prevent
    tampering, counterfeiting, or duplication, including a digital picture and
    machine-readable technology. The Real ID Act also requires individuals to
    provide evidence of their legal status to obtain a driver's license and
    provide proof of their Social Security numbers so that states can verify
    the information with SSA. Additionally, the law requires that states
    verify individuals' immigration status with DHS. Ultimately, Real ID
    prohibits federal agencies from accepting state-issued drivers' licenses
    or identification cards as identity documents unless they are determined
    to meet certain minimum security requirements.

     SSA Has Made Progress on Intelligence Act Provisions, but Slow Action to Form
             the Interagency Task Force May Limit Card Enhancement Efforts

    SSA has made progress implementing the Intelligence Act requirements
    enacted in December 2004. The agency implemented provisions for obtaining
    replacement cards, verifying birth certificates of applicants under age 1,
    and improving the application process of the Enumeration at Birth Program.
    In addition, SSA has taken actions to include death indicators and
    initiated action to include fraud indicators on Social Security records.
    In the effort to safeguard the Social Security card and number, SSA did
    not contact DHS until November 2005 to form an interagency task force, and
    the task force did not meet until late January 2006. This allows the task
    force less than 6 months to consider critical issues that affect card
    enhancement options before the establishment of security standards in June
    2006. In addition, SSA is required to provide for the implementation of
    standards for safeguarding the card and number from counterfeiting,
    tampering, alteration, and theft by the same date. Before convening the
    task force, SSA made a preliminary decision to improve the current paper
    card.

    Replacement Cards Limited

    The Intelligence Act requires that, generally, SSA limit the number of
    replacement cards it issues to individuals to 3 annually and 10 over a
    lifetime, and the act increased requirements for verifying the
    authenticity of documents presented before issuing replacement cards.
    SSA's policy prior to the Intelligence Act allowed individuals to obtain
    as many as 52 replacement cards annually, generally, requiring only proof
    of identity for U.S. citizens to receive the cards. GAO previously
    reported on the potential for fraud with SSA's replacement card policy.
    Our investigators were able to obtain 8 replacement cards in less than 6
    weeks before SSA placed a fraud alert on the SSN accounts.8 In response to
    the act, SSA reported that the agency had

    7Pub. L. No. 109-13, Emergency Supplemental Appropriations Act for
    Defense, the Global War on Terror, and Tsunami Relief, 2005, Title II,
    (2005).

               o  modified its computer system to enable monitoring the number of
               cards issued to individuals;

               o  published interim final regulations on replacement cards in the
               Federal Register on December 16, 2005;

               o  issued operating instructions for SSA employees to use in
               processing claims and conducting the daily business of the agency;
               and

               o  provided training to staff on SSA's new policy on replacement
               cards.

    Minimum Standards for Verifying Documents Established

    The Intelligence Act requires that SSA establish minimum standards for
    verifying documents or records that individuals present when applying for
    original and replacement Social Security cards other than through the
    Enumeration at Birth process. SSA reported that it had

               o  published operating instructions that describe the minimum
               standards for verifying all documents submitted for enumeration;

               o  created a new fact sheet for applicants explaining the
               Intelligence Act provisions and revised public information, such
               as brochures and pamphlets; and

               o  provided training to SSA personnel on the minimum standards for
               verifying all documents.

    8GAO, Social Security Administration: Actions Needed to Strengthen
    Processes for Issuing Social Security Numbers to Children, GAO-05-115
    (Washington, D.C.: Jan. 31, 2005).

    Birth Certificates for Card Applicants under Age 1 Independently Verified

    The act required that SSA independently verify birth certificates that
    individuals submit to establish eligibility for a Social Security number.
    Prior to the act, SSA required verification of birth certificates for
    individuals over age 1, but required only a visual inspection of birth
    certificates for children under age 1 who were assigned SSNs outside the
    Enumeration at Birth process. Both GAO and SSA's Office of the Inspector
    General (OIG) identified the potential for fraud with the verification of
    birth certificates because SSA personnel could not detect counterfeit
    birth certificates by visual inspection, and because no verification of
    documents with the issuers was required for replacement Social Security
    cards. GAO investigators posing as parents of children under age 1 used
    counterfeit birth certificates to get two SSNs for fictitious children. In
    one instance, the investigators supplied the counterfeit documents in
    person; in the other, they mailed the counterfeit documents. In both cases
    SSA staff verified the counterfeit documents as valid and SSA issued the
    SSNs and cards. SSA reported that upon enactment of the Intelligence Act,
    the agency changed its policy for verifying birth certificates for
    individuals under age 1. Specifically, SSA

               o  issued Program Operations Manual System requirements for
               independently verifying birth certificates, and

               o  provided training to SSA personnel on specific requirements for
               verifying birth certificates.

    Progress Made on Enumeration at Birth Process

    The Intelligence Act requires that SSA undertake to improve the
    application process for assigning Social Security numbers to newborns. The
    act requires that SSA improve the

               o  assignment of Social Security numbers to unnamed children,

               o  issuance of SSNs to prevent assigning more than one Social
               Security account to the same child, and

               o  system to prevent other opportunities for fraudulently
               obtaining a Social Security account number.

    Prior GAO work showed that SSA did not have sufficient internal controls
    in place to minimize fraudulent activities that could affect the
    Enumeration at Birth data that SSA uses to issue SSNs and cards.
    Additionally, the SSA OIG reported various vulnerabilities in the
    Enumeration at Birth Program and suggested that SSA provide more
    systematic oversight and management. As of our review, SSA reported that
    the agency has made systems changes to improve the Enumeration at Birth
    Program. For example, a more detailed check of the child's name will be
    made to prevent assigning SSNs to "Baby Boy" or "Baby Girl," or to issue
    two different SSNs to the same child by honoring the parents' request at
    the hospital but then honoring a second request a short time later through
    a field office with a claim of nonreceipt of the SSN through the hospital
    or an urgent need for the SSN. SSA submitted a report to Congress
    detailing these improvements in December 2005.

    The act also required that SSA conduct a study to determine the options
    for ensuring the integrity of the Enumeration at Birth Program.
    Specifically, the report must include an examination of available methods
    to reconcile hospital birth records with birth registrations submitted to
    state agencies that submit data to SSA as part of the Enumeration at Birth
    process.

    SSA reported that it asked the Inspector General to conduct the required
    study, and the Inspector General plans to deliver the study to Congress by
    June 2006.

    Work on Death Indicators Taken and Fraud Indicators Initiated

    The Intelligence Act requires that SSA add death and fraud indicators to
    the systems for verifying Social Security numbers so employers and state
    agencies issuing drivers' licenses and identification cards can receive
    accurate information when verifying the SSN. Death and fraud indicators
    are "flags," or "alerts," that SSA would place on SSN accounts to warn
    inquirers that certain SSN accounts belong to a deceased person or were
    used for fraudulent purposes. SSA is required to add death indicators by
    June 17, 2006, and fraud indicators by December 17, 2007. SSA reported
    that the agency currently maintains death information in its records and
    has added state death information to its verifications as of March 6,
    2006. SSA reported that it has begun to discuss what steps are needed but
    has not yet drafted guidance for handling fraud indicators.

    SSA Has Moved Slowly to Convene the Interagency Task Force for Safeguarding the
    Card

    The Intelligence Act requires that SSA consult with DHS and form an
    interagency task force to safeguard Social Security cards and numbers.
    Under the act, the task force has 18 months to establish standards for
    preventing counterfeiting, tampering, alteration, and theft. During the
    first 12 months since enactment, SSA has conducted research on enhancement
    options, come to a preliminary internal agreement on the features a newly
    enhanced card might have, and discussed what type of publicity campaign is
    needed to promote an enhanced paper Social Security card. However, SSA did
    not consult with DHS about the formulation of an interagency task force
    until November 2005, and the task force did not meet until late January
    2006, allowing the task force less than 6 months before security standards
    are to be established in June 2006. SSA is required to provide for
    implementation of the new safeguards by the same date. Prior to consulting
    with DHS on forming the interagency task force, SSA made a preliminary
    decision to enhance security features for the paper card. According to
    SSA, the agency wanted to have an approach to present to the task force
    once it convened. Table 2 shows the timeline SSA has set for implementing
    tasks related to card enhancement.

    Table 2: Social Security Administration Timeline for Implementing Social
    Security Card Enhancements

    Intelligence Reform and Terrorism Prevention Act passed           12/17/04
    Task name                                                   Start   Finish
    Research and benchmarkinga                                 1/3/05  8/16/05
    SSA internal agreement on new security features for SSN
    cards                                                     8/18/05 12/16/05
    Develop publicity campaignb                               8/18/05 12/16/05
    Interagency task force agreement on new security
    features                                                 12/19/05  3/17/06
    Prepare new contract for SSN card                         3/20/06  6/16/06
    Provide SSA systems support for changes                   3/20/06  6/16/06
    Finalize SSA publicity campaign                           3/20/06  6/16/06
    Report to Congress                                        6/17/06  6/17/06

    Source: SSA.

    aResearch and benchmarking were not completed as of February 3, 2006 to
    allow for coordination with the Document Security Alliance regarding card
    enhancement options.

    bThe publicity campaign has been discussed but is not yet complete. SSA
    noted that these timelines are internal guidelines with room built in to
    allow for slippage, but the agency fully expects to meet the legislated
    completion date of June 17, 2006.

    SSA officials told us that they expect the interagency task force to
    include representation from DHS and several other agencies. According to
    SSA, the task force's first meeting in January 2006 addressed the
    Intelligence Act requirement to establish standards for verifying
    documents submitted to obtain replacement cards. SSA reported that the
    task force will address other requirements of the Intelligence Act, such
    as enhancements to the Social Security card in future meetings. While the
    task force has broad latitude to address issues relative to the Social
    Security card, information SSA and DHS provided at the time of our review
    does not indicate that the task force will address the role of the card in
    verifying employment eligibility. According to SSA, final agreements on
    the new features to add to the card will be made based partly on results
    from work being performed by the Document Security Alliance, a group of
    experts on document security with representatives from industry and
    government agencies. Figure 1 shows the task force membership and
    structure as proposed by SSA.

    Figure 1: Interagency Task Force Required by the Intelligence Act,
    November 2005

     The Difficulty of Counterfeit-proofing the Card, the Role the Card Has in the
    Employment Verification Process, and Improvements to Drivers' Licenses Are
                              Critical Issues to Consider

    The Social Security card is a critical federal government document that is
    used in daily American life, and understanding what is needed to protect
    the card is essential to enhancement efforts. Critical issues to consider
    include the difficulty of developing and maintaining a counterfeit-proof
    card, the role the card has in the employment verification process, and
    new requirements of state drivers' licenses and identification cards that
    provide links to the card and immigration documents and could help improve
    the employment verification process.

    A Counterfeit-proof Social Security Card Is Difficult to Develop and Maintain

    In the past 30 years the Social Security number and card have become
    critical to daily functions in the United States, such as filing tax
    returns, opening bank accounts, applying for credit, conducting consumer
    transactions, and obtaining employment. As uses for the number and card
    have grown, demand for counterfeit cards has risen. In testimony before
    Congress, SSA's Assistant Deputy Commissioner for Disability and Income
    Security Programs (Program Policy) stated that when the Social Security
    program began, no special efforts were needed to prevent the Social
    Security card from being counterfeited, but as the card's use expanded and
    technology improved, counterfeiting became a concern. According to the
    Assistant Deputy Commissioner, SSA has incorporated a number of security
    features to make the card counterfeit-resistant since 1983, but the
    expertise of counterfeiters and the wide availability of state-of-the-art
    technology make it increasingly difficult to develop and maintain a
    document that cannot be counterfeited.9 Table 3 describes four examples of
    fraudulent Social Security card activity.

    9Testimony of the 109th Congress, Social Security Testimony before
    Congress, November 1, 2005, Statement of Frederick G. Streckewald,
    Assistant Deputy Commissioner, Office of Disability and Income Security
    Programs (Program Policy), before the House Committee on Ways and Means,
    Subcommittee on Social Security.

    Table 3: Examples of Fraudulent Social Security Card Activity

    Document fraud: Law enforcement officials investigating an alleged case of
    document fraud in the state of Maryland in December 2005 expressed concern
    that technology has improved so much that it is difficult to identify
    counterfeit documents. These officials arrested an individual for
    allegedly selling a fake Social Security card and an immigration document
    (resident alien card) for about $250 to a law enforcement official posing
    as an undocumented immigrant. According to the law enforcement report, two
    passport-sized photographs were provided so that a resident alien card
    could be made, along with a Social Security card, both of which were ready
    in 3 days.
    Document fraud: In testimony before the House Committee on Ways and Means
    in November 2005, the Deputy Inspector General for SSA stated that
    investigators had apprehended an individual who used counterfeit
    immigration documents to obtain over 600 valid Social Security numbers to
    sell to undocumented immigrants at a price of $1,000 to $2,000. In
    addition, this person had multiple Social Security cards and photocopies
    of cards. Counterfeit Social Security cards and activities have also
    involved U.S. citizens.
    Identity and mail fraud: The SSA Inspector General reported in August 2005
    that a university professor was indicted on 33 counts of mail fraud for
    posing as a parent and using students' personal information to obtain
    Social Security cards, credit cards, and birth certificates.a
    Identity and document fraud: The Deputy Inspector General testified that
    in August 2005, one individual was sentenced to 18 months' incarceration
    for submitting more than 200 applications for Social Security numbers for
    fictitious children using fraudulent birth certificates and other
    falsified documents. The individual used two identities, one of which
    belonged to a person who had been dead for a year.

    Source:Montgomery County, Maryland Police Department and SSA Inspector
    General.

    aOffice of the Inspector General, Social Security Administration,
    Universities' Use of Social Security Numbers as Student Identifiers in
    Region VI, A-06-05-15100 (August 2005).

    Although the card is now used as documentation for government and
    nongovernment functions, the card was never intended as a personal
    identification document and does not establish the person presenting the
    card as the person whose name and SSN appear on the card. According to
    SSA, while the card has some counterfeit-resistant features, it does not
    contain information that would allow the card to be used as proof of
    identity. In its 1997 Report to Congress on Options for Enhancing the
    Social Security Card, SSA reported that

    "The only way the Social Security card can, with certainty, assure that
    the bearer of the card is the assigned number holder is if the number
    holder's identifying information, picture, fingerprint, or biometric
    identifier is on the card itself. Then, someone needing assurance the card
    bearer is the assigned number holder could perform a visual comparison
    with the number holder's picture or identifying information, or an
    electronic comparison to a biometric identifier stored on the Social
    Security card."

    SSA reported that linking the number holder to the card would entail
    collecting and maintaining biometric data, a step the agency reported
    would be costly for the agency and complicated for the public. Although
    the technology has advanced since the 1997 SSA report, the agency
    maintains that the same principles of cost and complexity apply. The
    ability to tie the card to the cardholder could assist SSA in reducing the
    number of instances in which wages are not credited to the correct Social
    Security account and assist DHS in its efforts to confirm the immigration
    status of nonimmigrants.

    The Card Is a Weak Link in the Employment Verification Process

    The Social Security card is commonly presented as a document to prove
    authorization to work. As part of the employment verification process, job
    applicants can choose from a list of 27 documents that employers then use
    to verify identity and employment eligibility. Employers are required to
    certify on DHS's Form I-9 that they have examined the documents presented,
    and that the documents appear genuine and relate to the person presenting
    them. As shown in table 4, documents from three categories may be used to
    establish identity and employment eligibility. See appendix II for Form
    I-9.

    Table 4: Acceptable Documents in the Employment Verification Process

                List A                  List B                   List C

    Documents that establish Documents that         Documents that establish
    both identity and        establish identity     employment eligibility
    employment eligibility
                                (a document from this  (a document from this
    (only one document from  category must be used  category must be used with
    this category needed)    with one from List C)  one from List B)
    (1) U.S. passport        (1) Driver's license   (1) U.S. Social Security
                                or ID card issued by a card issued by SSA
                                state or U.S.
                                possession
    (2) Unexpired foreign    (2) ID card issued by  (2) Certification of birth
    passport                 federal, state, or     abroad issued by the State
                                local governments      Department
    (3) Permanent Resident   (3) School ID card     (3) Original or certified
    card or Alien            with a photograph      copy of a birth
    Registration Receipt                            certificate issued by a
    card with photograph                            state, county, etc.
                                                       bearing an official seal
    (4) Unexpired Temporary  (4) Voter's            (4)Native American tribal
    Resident card            registration card      document
    (5) Unexpired Employment (5) U.S. military card (5) U.S. citizen ID card
    Authorization card       or draft record
    (6) Unexpired reentry    (6) Military           (6) ID card for use of
    permit                   dependent's ID card    resident citizen in the
                                                       United States
    (7) Unexpired refugee    (7) U.S. Coast Guard   (7) Unexpired employment
    travel document          Merchant Mariner's     authorization document
                                card                   issued by DHS
    (8) Unexpired employment (8) Native American
    authorization document   tribal document
    issued by DHS with a
    picture
                                (9) Driver's license
                                issued by a Canadian
                                government authority
                                (10) School record or
                                report card
                                (11) Clinic, doctor or
                                hospital record
                                (12) Day-care or
                                nursery school record

    Source: Department of Homeland Security.

    While the employment verification process relies on a variety of documents
    to establish identity, the role of the Social Security card in proving
    authority to work has limitations. Millions of existing cardholders have
    not proven their employment eligibility status to SSA, because SSA did not
    begin requiring identification documents from all persons until 1978.
    According to SSA, at the inception of the Social Security program, all
    SSNs were assigned and cards issued based solely on information provided
    by the applicant. In 1971, SSA began requiring evidence of identity from
    individuals age 55 and over who were applying for an original number and
    Social Security card. From the first issuance of the Social Security
    number and card until evidence of identity was first required, SSA issued
    over 194 million SSNs and cards. SSA first required that noncitizens show
    evidence of age, identity, and status in 1974, by which time SSA had
    issued another 26 million original SSNs and cards. In his testimony, the
    SSA Deputy Commissioner stated that in 1974, the agency began to annotate
    its records to show the issuance of SSNs to noncitizens for nonwork
    purposes because the agency was concerned that individuals might use SSNs
    assigned for purposes other than work to obtain unauthorized employment.
    Beginning in 1978, SSA required all SSN applicants to provide evidence of
    age, identity, and United States citizenship or noncitizen status, by
    which time SSA had issued about 253 million original SSNs and cards. In
    1982 SSA began printing the legend, "NOT VALID For Employment," on the
    cards of noncitizens not authorized to work.

    To reduce the instances of fraudulent activity associated with documents
    used in the employment verification process, both SSA and Homeland
    Security offer employers voluntary electronic verification of information
    on the Social Security card and immigration documents. However, in August
    2005, GAO reported several weaknesses in the current employment
    verification process.10 The wide array of documents permitted leaves the
    employment verification process vulnerable to fraud. Various studies show
    that document fraud (use of counterfeit documents) and identity fraud
    (fraudulent use of valid documents or information belonging to others)
    have made it difficult for employers to accurately verify individuals'
    eligibility to work. In its 1997 report to Congress, the U.S. Commission
    on Immigration Reform noted that the widespread availability of false
    documents made it easy for unauthorized workers to obtain jobs in the
    United States. Prior GAO work shows that the problems with document and
    identity fraud undermine the employment verification process. For example,
    in 1999 we reported that large numbers of unauthorized workers either
    fraudulently used valid documents that belong to others or presented
    counterfeit documents as evidence of employment eligibility.11 In 2004, we
    reported that unauthorized workers were able to use false documents to
    illegally gain entry to secure areas of critical infrastructure sites,
    such as airports, nuclear power plants, and military bases. To improve the
    employment verification process, DHS reported it is considering reducing
    the number of acceptable documents permitted to verify employment
    eligibility.

    10 GAO-05-813 .

    11GAO, Illegal Aliens: Significant Obstacles to Reducing Unauthorized
    Alien Employment Exist, GAO/GGD-99-33 (Washington, D.C.: Apr. 2, 1999).

    DHS has made worksite enforcement a relatively low priority, given the
    other immigration enforcement programs that compete for DHS resources.
    Since the terrorist attacks of September 11, 2001, DHS has focused its
    investigative resources on national security, and worksite enforcement has
    focused on identifying and removing unauthorized workers from critical
    infrastructure sites such as airports and nuclear power plants. However,
    fraudulent use of SSNs among immigrants remains a problem. In September
    2005, the SSA Inspector General reported that some nonimmigrants may
    remain in the United States and continue working without DHS
    authorization,12 while others leave the country, and in their absence,
    someone else may use these individuals' SSNs to obtain employment. Using a
    universe of about 800,000 nonimmigrants that SSA enumerated in fiscal year
    2000, the Inspector General estimated that about 32,000 nonimmigrants
    continued working after their immigration status expired or someone else
    may have used their SSNs to work after they left the country. 13

    DHS has a voluntary "Basic Pilot" program where employers can choose to
    verify employment eligibility electronically, but few employers
    participate, and technological flaws hinder the program's effectiveness.
    Most of the nation's approximately 5.6 million employer firms rely on
    visual examination of documents individuals present, while about 5,500
    employer firms signed up to participate in Basic Pilot as of March 2006.14
    Basic Pilot enables employers to verify Social Security numbers with SSA
    and work authorization and immigration status with DHS. Basic Pilot shows
    promise for detecting document fraud, but if an unauthorized worker
    presents valid documentation that belongs to another person who is
    authorized to work, Basic Pilot may verify the individual as
    work-authorized. If the use of Basic Pilot expands, some unresolved
    problems, such as delays in data entry and timely verification, will need
    to be resolved.

    12A nonimmigrant is a foreign-born individual who is granted temporary
    admission to the United States for a specific purpose, such as students
    and temporary workers.

    13Office of Inspector General, Social Security Administration, Impact of
    Nonimmigrants Who Continue Working after Their Immigration Status Expires,
    A-08-05-15073 (September 2005).

    14This indicates the number of businesses that have signed memorandums of
    understanding with DHS and is not indicative of the number of active
    participants.

    Real ID Act May Improve Links to the Card and Employment Eligibility
    Determinations, but Limitations Exist

    Improvements to state drivers' licenses and identification cards, as a
    result of the Real ID Act, may help the government's ability to identify
    individuals and establish better links to the Social Security card and
    employment eligibility determinations. The Real ID Act will require that
    the estimated 250 million state drivers' licenses and identification cards
    have a biometric such as a digital photo; physical security features, such
    as a special hologram, to prevent tampering, counterfeiting, or
    duplication; and a common machine-readable technology. Before issuing
    drivers' licenses and identification cards, states will be required to
    verify the Social Security numbers and legal presence of applicants. While
    licenses and identification cards are meant to prove identification, under
    the new law states are not required to establish employment eligibility
    and will not be checking worker status as they verify the Social Security
    number with SSA and immigration documents with DHS. Beginning 3 years
    after the date of enactment, a federal agency may not accept a state's
    driver's license or identification card for any official purpose, unless
    the state meets certain requirements. Table 5 shows the key requirements
    of the Real ID Act.

    Table 5: Requirements for State-Issued Drivers' Licenses or ID Cards under
    the Real ID Act of 2005

    Minimum issuance standards  Applicant must present evidence and have
                                   verified

                                      o  Photo identification or nonphoto
                                      identification with full legal name and
                                      date of birth on the document
                                      o  Date of birth
                                      o  Proof of valid SSN or verification that
                                      the person is not eligible for one
                                      o  Address of principal residence
    Minimum document            The driver's license must contain
    information standards
                                      o  Full legal name
                                      o  Date of birth
                                      o  Gender
                                      o  Driver's license or identification
                                      number
                                      o  Digital photo of the person
                                      o  Address of principal residence
                                      o  Security features meant to prevent
                                      counterfeiting, tampering, or duplication
                                      o  Common machine-readable technology with
                                      defined data elements
    Evidence of lawful status   A state shall require that a person provide
                                   valid documentary evidence that the person

                                      o  Is a citizen or national of the United
                                      States
                                      o  Is an alien lawfully admitted for
                                      permanent or temporary residence in the
                                      United States
                                      o  Has conditional permanent resident
                                      status in the United States
                                      o  Has an approved application for asylum
                                      in the United States or has entered into
                                      the United States in refugee status
                                      o  Has a pending application for asylum in
                                      the United States
                                      o  Has a pending or approved application
                                      for temporary protected status in the
                                      United States
                                      o  Has approved deferred action status
                                      o  Has a pending application for adjustment
                                      of status to that of an alien lawfully
                                      admitted for permanent residence in the
                                      United States
                                      o  Has a valid, unexpired nonimmigrant visa
                                      or nonimmigrant visa status for entry into
                                      the United States
    Temporary drivers' licenses Temporary drivers' licenses and identification
    and identification cards    cards will only be accepted by federal
                                   agencies if they

                                      o  Are valid only during the time in which
                                      the individual is authorized to reside in
                                      the United States or, if there is no
                                      definite end to the period of authorized
                                      stay, a period of 1 year
                                      o  Clearly display that the license has
                                      been temporarily issued and plainly display
                                      the expiration date
                                      o  With respect to a temporary driver's
                                      license or temporary identification card,
                                      may only be renewed upon presentation of
                                      valid documentary evidence that the status
                                      has been extended by the Department of
                                      Homeland Security

    Source: Real ID Act.

              A Range of Enhancement Options Exists, and Costs Would Vary

    A range of options exists for enhancing the Social Security card, and
    these options provide different levels of counterfeit protection and
    capacity to verify employment eligibility. Options range from adding
    counterfeit-resistant features to the paper card, adding machine-readable
    features such as a magnetic stripe or bar code, and adding biometric
    features such as photographs and fingerprints, to eliminating the card
    entirely. Currently, the cost of providing a card to a cardholder is
    approximately $25, and the cost of some of these options will be higher.15
    The total cost of enhancing the card will be significantly affected by how
    many people are issued new cards and the time frame for distribution.
    Options for distribution include providing enhanced cards only to new
    cardholders, reissuing cards to all of the 300 million estimated
    cardholders, or staggering issuance by providing cards to new cardholders
    and to individuals who change jobs. The options that we describe below are
    not intended to be an all-inclusive listing of options available to
    enhance the security of the card, but provide a framework of approaches
    for doing so.

    Options for Enhancing Cards

      Adding secure features to the paper card

    There are a wide range of features that could be added to the current
    paper card to make it more counterfeit-resistant. According to Government
    Printing Office officials and other industry experts, these features could
    include such improvements as printing a hidden image that appears when the
    card is tilted to the light, changing the paper content of the card to
    include fiber that reacts to certain chemicals, and incorporating various
    security features currently used on currency, such as a security thread in
    the paper. Government Printing Office officials and industry experts
    report that these are relatively inexpensive changes that would help
    protect the card by rendering obsolete many of the counterfeit techniques
    currently used. Adopting these types of changes to the current card would
    be the least disruptive to SSA operations and to cardholders.

      Adding machine--readable features

    Adding machine--readable features such as a magnetic stripe or secure bar
    code feature could offer some measure of security of the card, though some
    experts question the value of this option. Machine--readable technology
    varies in the amount and type of information that can be included on the
    card. For example, a card with a magnetic stripe similar to those on
    credit and debit cards may contain the information currently displayed on
    the Social Security card plus the individual's work status. A secure bar
    code can also store identifying information such as a photograph or
    fingerprint. Much like the process to verify credit cards,
    machine-readable technology combines the security of counterfeit-resistant
    features on the card with features that can be read and verified by an
    external device. Employers and SSA would rely on machines to read the
    cards, thus adding another step to assess the cards' validity and protect
    the cards from counterfeiting. See figure 2 for a possible SSN card
    showing a magnetic stripe and a secure bar code.

    15Based on fiscal year 2004 data.

    Figure 2: Examples of Possible Social Security Card with Reverse Showing
    Magnetic Stripe and Secure Bar Code

    The main change to the card would be the introduction of machine- readable
    technology. The primary advantage of machine--readable technology is that
    it combines the security of counterfeit-resistant features with those that
    can be read by an external device. The use of machine-readable features
    could be useful as part of DHS's employment eligibility authorization
    process. Current DHS guidelines state that an employer has to review
    documents provided by new employees to prove their eligibility to work and
    make a reasonable determination as to the validity of documents presented.
    Use of machine-readable features would take the burden off employers to
    make a determination that the card that is presented is valid. Due to the
    large number of documents that can be presented, including the many
    versions of the Social Security card, employers are often ill equipped to
    determine if documents are valid. A secure card with machine-readable
    features could also be used by SSA or other programs in determining the
    validity of the card and eligibility for benefits.

    Card technology experts have noted that certain machine-readable
    technology offers little protection against counterfeiting. For example,
    magnetic stripe technology is relatively easy to counterfeit with
    inexpensive equipment that is widely available. Other industry experts
    stated that even though the data included in a secure bar code may be
    encrypted, or coded so that the data cannot be read by unauthorized
    persons, the data may still be copied in its encrypted form and included
    on a counterfeit card.

      Adding biometric features

    A highly secure card could incorporate biometric security features to
    effectively establish an individual's identity and backup systems to
    authenticate an individual's eligibility for benefits or work status.
    Biometric features cover a wide range of technologies that can be used to
    verify a person's identity by measuring or analyzing his or her
    characteristics. Some widely used and well-known biometric features
    include fingerprints, which uses distinct ridges of the fingertips to
    establish an individual's identity, and digital pictures, which are
    commonly used in drivers' licenses. These digital pictures support facial
    recognition, which electronically compares facial features in the digital
    pictures with those of the individual. Biometric cards would be made of
    plastic or other durable material and could incorporate smart card
    technologies.16 See figure 3 for examples of biometrics that might be used
    on a Social Security card's front or reverse sides depending on the card's
    design.

    16Smart cards are plastic devices about the size of a credit card that use
    integrated circuit chips to store and process data.

    Figure 3: Examples of Biometrics-Fingerprint, Facial Recognition, and
    Photograph

    Biometrics-enhanced cards could be supported by a central SSA database to
    store the biometric information to verify the identity of an individual.
    Storing identifying information on a central system would provide
    additional protection if some of the physical security features used on
    the card are able to be counterfeited. For example, many motor vehicle
    administrations maintain central databases to compare stored photos with
    those of individual renewing a driver's license. The ability to make
    similar verifications to a centralized database could also establish if
    individuals are eligible to work in the United States. The biometric
    feature could also be stored only on the card, but some industry experts
    indicate that data stored only on the card are far more vulnerable to
    fraud than data in a centrally located database of identifying
    information.17 However, experts also caution that a centralized database
    has its own set of security concerns, which will require a risk assessment
    to determine the most cost-effective solution for storing biometric data.
    For example, techniques would need to be developed to ensure that
    biometric information provided to the centralized database actually
    represents the individual, and a method would need to be implemented to
    handle the inevitable situations where the information in the central
    database did not agree with information provided. Prior GAO work on
    biometrics outlines the strengths and concerns raised with the use of
    biometric technology.18

    An additional consideration in using biometrics on the Social Security
    card is determining when a biometric can first be captured from a
    cardholder, as in the case of fingerprints or a picture or the need to
    update the biometric in the case of a photograph. This may require SSA to
    issue a temporary card through the Enumeration at Birth process and then
    issue a card with a biometric at some other time, such as when the
    individual reaches adulthood or enters the workforce. Depending on the
    biometric selected, such as a digital picture, SSA would also need to
    reissue the card at intervals to update these data.

    A biometric Social Security card could raise general privacy concerns
    about the card becoming a national identification card. A new Social
    Security card with a biometric identifier issued to all number holders
    could create a central database capable of identifying 300 million
    individuals. A system that stores biometrics related to individuals'
    identity may raise concerns about how the government would use and protect
    the data. The Privacy Act of 1974 limits federal agencies' collection,
    use, and disclosure of personal information, such as fingerprints and
    photographs. While the act includes exemptions for law enforcement and
    national security purposes, representatives of civil liberties groups and
    privacy experts have expressed concerns regarding the adequacy of
    protections for security, data sharing, identity theft, and other
    identified uses of biometric data and the potential intrusiveness of such
    an approach. Additional concerns focus on the ease of using biometrics and
    their effect on the ability of the agency to complete its mission.

    17American Association of Motor Vehicle Administrators officials have
    pointed out that the combination of a number of security features raises
    the overall level of security of a card or document.

    18GAO, Information Security: Challenges in Using Biometrics, GAO-03-1137T
    (Washington, D.C.: Sept. 9, 2003).

      Eliminating the card

    Finally, another approach would be to eliminate Social Security cards
    entirely and use other, more secure documents to prove employment
    eligibility. Under a no Social Security card option, each person who is
    assigned an SSN would receive a letter, not a card, with an SSN on it.
    Like the current card, the letter would record the number assigned and
    provide individuals with a written record of their number. Eliminating the
    Social Security card would mean that the card itself would not be used as
    documentation for obtaining government benefits, and the burden of finding
    a means to secure the card would be removed. Changing from a card to a
    letter would not require that SSA deviate from its current issuance
    process,19 which would save SSA the time, inconvenience, and many of the
    costs associated with issuing an enhanced card. Documentation of an
    individual's identity could be tied to other documents such as a driver's
    license and require some link between the SSN and drivers' licenses, which
    are currently undergoing improvements, or other identity documents.

    Factors Affecting the Cost of Card Options

    The current cost of issuing an original or replacement Social Security
    card is approximately $25. This includes approximately 4 cents for the
    banknote paper card, and as table 6 shows, to enumerate an applicant, SSA
    needs to interview applicants, verify documents such as birth certificates
    with the agencies that issued them, and determine work eligibility status.
    Including additional features on the card would increase the cost of the
    card. For example, in 1997, SSA reported that the cost of the current
    Social Security card document was 5 cents; a plastic card with security
    features was 12 cents; a plastic card with a picture was 14 cents; and a
    plastic card with a magnetic stripe was 22 cents. According to SSA, these
    costs have likely decreased somewhat since its 1997 estimate. But this
    estimate also showed that processing costs accounted for the bulk of
    issuance costs for most options it considered. SSA's processing costs
    would increase if additional features were included on the card. In 2004,
    SSA estimated that the cost of obtaining a number holder's picture and
    biometric identifier would add 5 minutes, or $3.50, to the cost of issuing
    a card. Adding machine-readable or biometric features to the card would
    also require additional equipment in SSA's approximately 1,300 field
    offices, and employers and other users would also need equipment if they
    were expected to read features on the card. Further, biometric features
    would likely require cardholders to have their biometric information
    updated at periodic intervals-greatly affecting the number of cards
    cardholders would receive in their lifetime and long-term card issuance
    costs.

    19SSA currently has numerous means of establishing an individual's
    identity. These include verifying the individual's identity by asking
    open-ended questions and confirming this information with information
    previously provided in SSA's records. If there are questions about the
    individual's identity, SSA staff may request identification documents,
    check telephone directories, or contact persons or organizations who may
    know the individual. They are not constrained by any single document or
    question.

    Table 6: Factors that Affect Costs of Enhanced Card Options

                                             New         New    Periodic updates
                             Determine   equipment at equipment    needed from
                            employment    SSA field    at job   cardholder at SSA
    Card options        eligibilitya    offices      sites     field offices
    Unchanged paper           X
    card
    Machine-Readable          X            X           X

    (paper or plastic)
    Biometric                 X            X           X             X
    No card-letter to         X
    notify assigned SSN

    Source: GAO.

    aThis includes interviewing applicants and verifying documents

    Issuance Options Affect Cost

    Specific costs for each card option are not yet available. However,
    issuing 300 million enhanced cards at the current cost of approximately
    $25 each is costly, but maintaining the current method of issuing cards
    and permitting older versions of cards to remain valid would do little to
    stem counterfeiting or help employers determine whether applicants are
    eligible to work. Permitting older versions is cost-effective for SSA,
    since new cards have to be issued only to new applicants and people
    needing replacement cards. About 17 million new and replacement cards are
    issued annually. Table 7 shows three card issuance options, including the
    number of cardholders requiring new cards.

    Table 7: Card Issuance Options

                                                          Document used to prove
                                                          employment eligibility
                            Cards issued in the initial  Old cards Only new cards
    Issuance options                       12 months    valid       valid
    Current issuance                                      X
    process                              18 milliona
    Mass issuance                        300 million                  X
    Staggered issuance                   45 millionb                  X

    Source: GAO analysis of SSA data.

    aTotal rounded to next million.

    bThis figure represents the approximately 34 million people who SSA
    estimates change jobs annually, 5.4 million original Social Security cards
    issued annually, and SSA's estimate of 6 million individuals who would
    request replacement cards under this option.

      Mass issuance

    While mass reissuance of Social Security cards to all 300 million Social
    Security number holders would ensure a more effective tool for
    establishing employment eligibility, mass issuance could cost billions of
    dollars. Number holders would need to be notified through costly mass
    mailings that they would need to come to an SSA field office with
    appropriate documentation to obtain their new card, and field offices
    would need to be staffed and equipped to verify the identity of the number
    holders and issue the cards. To help ease the strain on SSA field offices
    and resources, costs for a mass issuance could be phased in over several
    years.

      Staggered issuance

    Staggering issuance of an enhanced Social Security card to new hires or
    individuals who change jobs could help increase the likelihood that the
    card is a valid document in the worker verification process and help
    reduce the cost of a mass issuance. Under this issuance option, only an
    enhanced card would be permitted for determining employment eligibility.
    As a result, the 34 million workers who change jobs each year would need
    to obtain an enhanced card. In addition, SSA issues approximately 5
    million cards to new cardholders annually. Further, SSA has estimated that
    this option would include about half, or 6 million, of the replacement
    cards issued annually. Therefore, staggering issuance to job changers and
    new cardholders would result in a total of about 45 million enhanced cards
    issued during the first year of an enhanced card issuance.

                                      Conclusions

    Congress has long recognized that the Social Security card is vulnerable
    to misuse and has considered various approaches to minimizing this
    vulnerability and securing the card against counterfeiting. However, with
    50 valid versions, many of which lack any counterfeit protections, the
    card is difficult to counterfeit-proof completely, making it an element in
    identity theft and benefit program fraud, as well as an ineffective tool
    in verifying employment authorization. We recognize that the Intelligence
    Reform and Terrorism Prevention Act does not, specifically, require SSA to
    establish safeguards for the card for the purposes of employment
    eligibility, but the act intends for SSA to establish standards for
    safeguarding the card from fraudulent use. In doing so, SSA is thus far
    considering card protection solely within the context of the Social
    Security program; the agency is not currently planning to address card
    protection as part of the broader question of the card's role in
    employment verification or the potential impact of other identification
    advances such as the new state driver's license requirements on the use of
    the card.

    While DHS is represented on the SSA-led task force to address card
    protection, the task force has been convened late in SSA's card
    enhancement process, only a few months before SSA must provide for
    implementing new card safeguards. This approach allows little time to
    involve DHS in addressing the scope of critical issues affecting the role
    of the card. Yet DHS's ongoing reevaluation of which documentation
    represents acceptable proof of employment authorization is clearly
    relevant to the card's role and the types of security elements that might
    be warranted. It is important that the card's role in the employment
    eligibility documentation process not be overlooked in SSA's work on
    enhancements. Although consideration of this issue may not be specified in
    law, broader thinking about the card's use and security could mitigate the
    need to revisit card enhancement issues in the future.

                          Recommendation for Executive Action

    As the SSA-led task force develops ways to protect the Social Security
    card, it is important that the card meets the needs of DHS in the
    employment verification process; therefore, we recommend that

               o  the Secretary of Homeland Security and the Commissioner of
               Social Security work together to resolve the weaknesses of the
               Social Security card in proving employment eligibility.
               Specifically, they should consider the millions of cards that do
               not prove employment eligibility, the inability to tie the card to
               the cardholder, flaws in the voluntary employment verification
               system, improvements to identification cards by the Real ID Act,
               and the current ease of counterfeiting the card.

                                    Agency Comments

    The Department of Homeland Security and the Social Security Administration
    provided comments on a draft of this report.

    In its response, DHS agreed that much could be done on an interagency
    basis to improve the integrity of Social Security cards and numbers, as
    required by the Intelligence Reform and Terrorism Prevention Act of 2004.
    In addition, DHS agreed with SSA's decision to link the role of the card
    with verifying employment eligibility later in the task force's
    deliberative process. DHS stated that determining what to do to make the
    card more secure, or eliminating the card altogether, appears to be the
    appropriate task at this stage and DHS will continue to work with SSA
    through the interagency task force. DHS's comments are reprinted in
    appendix III. We also received technical comments, which we incorporated
    where appropriate.

    In SSA's response to our recommendation, SSA agreed in part, although it
    stated that some aspects of the recommendation are outside the scope of
    what Congress provided in the Intelligence Act. But otherwise SSA is
    continuing to work with DHS on issues related to employment eligibility
    and verification through the Basic Pilot program. While we assessed SSA's
    implementation of the Intelligence Act provisions, we also studied the
    role of the Social Security card and number in the context of employment
    verification. We recognize that the Intelligence Act does not specifically
    state that the task force is to establish safeguards for the card for the
    purposes of employment eligibility. However, the act was broadly written
    and provides sufficient authority to address such issues, given the act's
    requirement to consult with DHS to form an interagency task force. Our
    work showed major flaws with the Social Security card's role in the
    employment verification process, which raises concern when SSA did not
    involve DHS early enough in the process to fully consider its input to
    card enhancement decisions. That is why we recommended that SSA and DHS
    work together more closely to resolve the weaknesses of the Social
    Security card in proving employment eligibility.

    SSA states that the Intelligence Act requires SSA to have a plan for
    implementation by June 2006 and that the agency is on target to develop a
    plan for implementation by June 2006. While developing a plan for
    implementation is certainly consistent with the Intelligence Act's
    mandate, we do not view the Commissioner's responsibilities under the law
    to be limited solely to developing a plan. Specifically, the Intelligence
    Act requires that "Not later than 18 months after the date of enactment of
    this Act, the task force shall establish, and the Commissioner shall
    provide for the implementation of, security requirements,
    including-standards for safeguarding social security cards from
    counterfeiting, tampering, alteration, and theft."

    SSA further notes that our report has various references to SSA moving
    slowly and is not convening the task force until a time so late in the
    process that successful implementation would be nearly impossible. We
    believe our report accurately characterizes SSA's actions to date. The
    Intelligence Act requires that SSA consult with DHS and form an
    interagency task force to establish standards to better protect the SSN
    and card. Instead of having the task force direct efforts to establish
    safeguards for the SSN and card, SSA studied card enhancement options for
    nearly 1 year and made a preliminary decision without task force input. By
    the time SSA convened the task force, the group had less than 6 months to
    study and establish standards for safeguarding the card.

    SSA stated that current law requires that the card be made of banknote
    paper, and as a result, the task force was technically limited to
    improvements to the paper card. We believe that SSA and the task force, as
    stewards of the Social Security card, have a responsibility to ensure that
    the most appropriate enhancements to the card are considered. Although the
    law requires that the card be made of banknote paper, the Intelligence Act
    does not prohibit SSA or the task force from recommending legislative
    changes to better prevent tampering, alteration, and counterfeiting.

    SSA characterized the report as having an overarching theme that suggests
    the use of an enhanced card would address weaknesses in employment
    eligibility and enforcement, which SSA cites as beyond the scope of its
    mission and more in line with DHS's primary missions. SSA states that
    attempting to make the card meet a purpose for which it was not crafted
    would deflect valuable resources from the Social Security program.
    According to SSA, the report should make the point that a new, more secure
    card tailored to proving employment eligibility would do little good if
    not accompanied by other significant changes in the workplace enforcement
    arena. SSA stated that to expend considerable resources to develop a card
    to confirm employment eligibility that is used by a few employers would
    seem an injudicious use of government resources. We agree that these are
    critical issues to consider.

    SSA also noted that because the Real ID Act requires states to use a DHS
    verification system for noncitizens, it would be an easy next step to
    reflect work authorization on drivers' licenses if Congress wanted to do
    so. We believe that SSA's suggestion for modifications to the Real ID Act
    requirements for drivers' licenses and identification cards is important
    to the broader discussion on safeguards and represents yet another example
    of a critical issue that DHS and SSA should consider in the deliberation
    on card enhancements. SSA states that our claim that SSA is not planning
    to address card protection as part of employment verification or the
    potential impact of changes required by the Real ID Act to drivers'
    licenses is not true. SSA stated that it is working with DHS and the
    American Association of Motor Vehicle Administrators on matters of joint
    interest. We are encouraged by SSA's comments that the agency is working
    with DHS and the American Association of Motor Vehicle Administrators.
    However, we have asked SSA and DHS to provide information on the task
    force initiative but they have not provided the information we requested.

    SSA indicated that it found our report title misleading, stating that the
    majority of the report focuses on one purpose of enhancement-employment
    eligibility verification. We disagree; our report title accurately
    reflects the need for SSA to coordinate with DHS in its card enhancement
    efforts and our recommendation that the agencies do so. Besides employment
    eligibility, our report describes SSA's efforts to implement the
    Intelligence Act and outlines options for enhancing the Social Security
    card.

    Finally, because our report is concerned with counterfeiting, SSA stated
    that it would be prudent to protect its content by limiting distribution.
    We disagree. While our report describes examples involving counterfeit
    cards, the information in our report is readily available publicly in
    prior reports published by SSA and, most recently, in a November 2005
    testimony by an SSA official before the House Committee on Ways and Means,
    Subcommittee on Social Security. However, we have made changes to some
    language in the report to address SSA's concerns. SSA's comments are
    reprinted in appendix IV. SSA also provided technical comments, which we
    incorporated where appropriate.

    We are sending copies of this report to the Secretary of Homeland Security
    and the Commissioner of the Social Security Administration 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

    Please contact me at (202) 512-7215 or bovbjergb@gao.gov if you or your
    staff have any questions about this report. Contact points for our Offices
    of Congressional Relations and Public Affairs may be found on the last
    page of this report. GAO staff that made major contributions to this
    report are listed in appendix V.

    Sincerely yours,

    Barbara D. Bovbjerg Director, Education, Workforce, and Income Security
    Issues

    Appendix I: Scope and Methodology Appendix I: Scope and Methodology

    The Chairman of the of the House Committee on the Judiciary asked us to
    review the Social Security Administration's (SSA) efforts to implement
    provisions of the Intelligence Reform and Terrorism Prevention Act of 2004
    for safeguarding the Social Security number (SSN) and enhancing the Social
    Security card. The Chairman also asked that we identify key issues to be
    considered before enhancing the Social Security card and that we outline
    the range of options available to SSA for enhancing Social Security cards.

    To address the Chairman's request, we met with officials from SSA
    headquarters in Baltimore, Maryland, to review the agency's progress in
    implementing provisions of the Intelligence Act. We reviewed key
    initiatives planned and undertaken to strengthen SSA's enumeration
    processes and SSA's plans for enhancing the Social Security card. We also
    reviewed SSA's schedule for implementing the card enhancement provision of
    the act and documented SSA's progress in meeting other provisions
    contained in the legislation. In order to gain an understanding of the
    policies, procedures, and issues related to the current employment
    verification process, we met with officials from the Department of
    Homeland Security (DHS) in Washington, D.C. We discussed the current Form
    I-9 procedures and the role of employers in reviewing employment
    eligibility documents, as well as DHS's Basic Pilot system used to
    determine the employment eligibility of certain prospective employees.

    To identify key issues to be considered before enhancing the Social
    Security card, we consulted the GAO body of work on the integrity of the
    SSN, our work on immigration enforcement and problems reported in the
    employment verification process, and work the SSA Office of the Inspector
    General and selected law enforcement agencies had performed in these
    areas. We contacted law enforcement officials involved in an alleged
    document fraud case in Montgomery County, Maryland. We examined concerns
    raised regarding the integrity of the SSN and card with respect to
    counterfeiting, and reported document and identity fraud with the
    requirements of the employment verification process. We also reviewed SSA
    documents including agency testimonies before Congress and the 1997 SSA
    report entitled Social Security Administration: Report To Congress On
    Options for Enhancing the Social Security Card to document flaws in the
    card and its ability to serve as proof of employment eligibility. We
    studied the new federal legislative requirements for states' drivers'
    licenses and identification cards included in the Real ID Act. We
    contacted DHS, the American Association of Motor Vehicle Administrators in
    Arlington, Virginia, and state motor vehicle administrations in Chicago,
    Illinois; Charleston, West Virginia; and Cheyenne, Wyoming, to discuss
    security features used in drivers' licenses and the implication of changes
    to drivers' licenses as a result of the Real ID Act. We selected these
    three states because they used various security features in their driver's
    licensing or identification processes such as fingerprinting, advanced
    optical printing and inks, or holograms and other features, which already
    meet stated or anticipated requirements of the Real ID Act.

    To identify the range of options available to SSA for enhancing the card,
    we researched and analyzed technical literature and identified various
    technology experts and industry associations. We held discussions with
    technology experts in the metropolitan Washington, D.C., area at the
    National Institute of Standards and Technology, International Biometrics
    Industry Association, AC Technology, Mitretek Systems, and the Smart Card
    Alliance to discuss the range of card options and available security
    features, their feasibility for use on the Social Security card, and
    privacy and other concerns. Through these discussions we developed a
    framework of options available to enhance the security of the card.

    Because the current legislation governing the Social Security card
    requires that the card be made of banknote paper, we also obtained
    information on card improvements suitable to a paper format. We met with
    officials from the Government Printing Office, in Washington, D.C., who
    administer the contract for printing Social Security cards and Banknote
    Corporation of America in Browns Summit, North Carolina, the contractor
    that prints Social Security cards, to discuss advances in security
    printing techniques.

    We reviewed identification initiatives using biometrics at the United
    States Visitor and Immigrant Status Indicator Technology program and the
    Transportation Security Administration Registered Traveler program in DHS
    in Washington, D.C. Finally, we met with employer association groups
    identified by the U.S. Chamber of Commerce in Washington, D.C., to discuss
    the impact of potential changes to the Social Security card on the
    business community.

    We performed our work between April 2005 and January 2006 in accordance
    with generally accepted government auditing standards.

    Appendix II: Department of Homeland Security Form I-9 Appendix II:
    Department of Homeland Security Form I-9

    Note: While DHS has removed the Certificate of United States Citizenship
    and Certification of Naturalization as acceptable List A documents that
    establish both identity and employment eligibility, it has not updated the
    Form I-9.

    Appendix III: Comments from the Department of Homeland Security Appendix
    III: Comments from the Department of Homeland Security

    Appendix IV: Comments from the Social Security Administration Appendix IV:
    Comments from the Social Security Administration

    Appendix V: A Appendix V: GAO Contact and Staff Acknowledgments

    GAO Contact

    Barbara D. Bovbjerg (202) 512-7215 or bovbjergb@gao.gov

    Staff Acknowledgments

    In addition to the contact named above, Blake Ainsworth, Assistant
    Director; Daniel Bertoni, Assistant Director; Jacqueline Harpp; Jeff
    Bernstein; Jeremie Greer; Roger Thomas; and Tovah Rom made key
    contributions to this report.

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    in Initial Privacy Notices, but Has Recently Taken Steps to More Fully
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    Electronic Government: Progress in Promoting Adoption of Smart Card
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    Technology Assessment: Using Biometrics for Border Security. GAO-03-174 .
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    Social Security Numbers: Government Benefits from SSN Use but Could
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    Social Security: Government and Commercial Use of the Social Security
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    Social Security: Mass Issuance of Counterfeit-Resistant Cards Expensive,
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    Immigration Control: A New Role for the Social Security Card. GAO/HRD-88-4
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    (130458)

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    Highlights of GAO-06-303 , a report to the Chairman, Committee on the
    Judiciary, House of Representatives

    March 2006

    SOCIAL SECURITY ADMINISTRATION

    Improved Agency Coordination Needed for Social Security Card Enhancement
    Efforts

    The Social Security Administration (SSA) has issued more than 430 million
    Social Security numbers (SSN) and cards since the Social Security program
    began in 1935, of which an estimated 300 million belong to living number
    holders. SSNs have a key role in verifying individuals' authorization to
    work in the United States, but SSN cards are also vulnerable to theft and
    counterfeiting. The Intelligence Reform and Terrorism Prevention Act of
    2004 requires that SSA consult with the Department of Homeland Security
    (DHS), form a task force, establish standards for safeguarding the SSN and
    card, and provide for implementation by June 2006. Concerns about
    unauthorized workers and the use of counterfeit documents led the Chairman
    of the House Judiciary Committee to ask that GAO (1) review SSA's progress
    to safeguard the SSN and enhance the card as required under the
    Intelligence Act, (2) identify key issues to be considered before
    enhancing the card, and (3) outline the range of options available to SSA
    for enhancing the card.

    What GAO Recommends

    As the SSA-led task force works to protect the Social Security card, GAO
    recommends that DHS and SSA work together to resolve the card's weaknesses
    in proving employment eligibility. DHS agreed but SSA agreed in part,
    stating that aspects of the recommendation are beyond the Intelligence Act
    scope.

    SSA has implemented several provisions of the Intelligence Act intended to
    help safeguard the SSN and card, but slow action to form the interagency
    task force may limit card enhancement efforts. SSA has implemented
    measures to limit the number of replacement cards, verify birth
    certificates for applicants under age 1, and improve the Enumeration at
    Birth process. SSA has taken action to include death indicators and
    initiated work on fraud indicators for Social Security accounts in its
    database. SSA set specific tasks and timelines to address card enhancement
    options and made a preliminary decision to improve the current paper card
    and issue the improved cards only to new card applicants. Although the
    card plays a significant role in verifying individuals' authorization to
    work, SSA did not consult DHS about these initial tasks or the formation
    of the interagency task force until November 2005 and did not convene the
    task force until late January 2006. This allows less than 6 months for the
    task force to consider critical issues that affect card enhancements
    before establishing new safeguards.

    The difficulty of counterfeit-proofing the card, the role the card has in
    determining employment eligibility, and ongoing enhancements to state
    drivers' licenses and identification cards are critical issues to consider
    before enhancing the Social Security card. Counterfeit protections were
    first added in 1983 but older versions of the card remain valid. Millions
    of older cards never established employment eligibility because SSA did
    not require that everyone present evidence of age, identity, or
    citizenship status until 1978. Prior GAO work shows that the employment
    verification process is jeopardized by document and identity fraud, the
    wide array of documents that can be used, weak worksite enforcement, and
    flaws in the voluntary electronic verification system. DHS is currently
    considering reducing the number of acceptable documents used to verify
    employment eligibility. Changes to drivers' licenses and identification
    cards under the Real ID Act will improve verification of identity in the
    employment process, since states must verify the SSN and legal presence
    upon application. However, states are not required to check or note
    employment eligibility.

    Once these critical issues are considered, a variety of options exist for
    enhancing the Social Security card, ranging from enhancing the paper card,
    to adding machine-readable or biometric features such as photographs and
    fingerprints, to eliminating the card entirely. Additionally, the costs of
    implementing each option will vary. Each option provides different
    alternatives for improving the ability to verify employment eligibility.
    The type of card and distribution method chosen will have a significant
    effect on costs and the agency's workload. For example, if cards require a
    fingerprint or photograph, additional infrastructure will be required to
    obtain these features; reissuing new cards to the estimated 300 million
    living cardholders or staggering issuance to certain groups, such as those
    who change jobs, would require a different investment of resources.
    However, decisions about the card's role will be crucial in determining
    costs.
    *** End of document. ***