oversight

Social Security Administration: Actions Taken to Strengthen Procedures for Issuing Social Security Numbers to Noncitizens, but Some Weaknesses Remain

Published by the Government Accountability Office on 2003-10-15.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

               United States General Accounting Office

GAO            Report to the Chairman, Subcommittee
               on Social Security, Committee on Ways
               and Means, House of Representatives


October 2003
               SOCIAL SECURITY 

               ADMINISTRATION 

               Actions Taken to
               Strengthen
               Procedures for Issuing
               Social Security
               Numbers to
               Noncitizens, but Some
               Weaknesses Remain




GAO-04-12 

                                                October 2003


                                                SOCIAL SECURITY ADMINISTRATION

                                                Actions Taken to Strengthen Procedures
Highlights of GAO-04-12, a report to the
Chairman, Subcommittee on Social                for Issuing Social Security Numbers to
Security, Committee on Ways and Means,
House of Representatives                        Noncitizens, but Some Weaknesses
                                                Remain

In 2002, the Social Security                    SSA Has Increased Noncitizen Verifications and Begun New
Administration (SSA) issued nearly              Initiatives
6 million new Social Security                   SSA has taken steps to prevent the inappropriate assignment of SSNs to
numbers (SSNs), of which 1.3                    noncitizens. SSA now requires field staff to verify noncitizens' identity
million were issued to noncitizens.
                                                documents with the Department of Homeland Security (DHS), in addition to
Despite its narrowly intended
purpose, the SSN has in practice                continuing to require visual inspection of these documents, prior to issuing
become the national identifier.                 an SSN. However, many field staff GAO interviewed are relying heavily on
SSNs are key pieces of information              DHS's verification while neglecting SSA's standard inspection practices,
in creating false identities,                   even though both approaches are necessary. SSA has also undertaken new
underscoring the importance of                  initiatives to shift the burden of processing noncitizen SSN applications and
issuing SSNs only to those eligible             verifying documents from its field offices. In 2002, SSA started
for them and of protecting those                implementation of a process called “Enumeration at Entry” (EAE), which
already assigned to individuals.                relies on State Department and DHS expertise to authenticate information
The flow of noncitizens into the                provided by SSN applicants. SSA is in the early stages of planning to evaluate
United States and the                           EAE with the State Department and DHS. Also, SSA recently piloted a
accompanying number of SSNs
                                                specialized center in Brooklyn, New York, which focuses on enumeration
issued to them over the last several
years add to the importance of                  and uses the expertise of DHS staff and SSA’s Office of the Inspector
having sound practices to avoid                 General investigators.
issuing SSNs to those who do not
qualify for them.                               Some Areas Affecting Issuance of SSNs Not Yet Addressed
                                                While SSA has embarked on these new initiatives, it has not tightened
The Subcommittee Chairman asked                 controls in two key areas of its enumeration process that could be exploited
GAO to describe and assess SSA’s                by individuals—citizens and noncitizens alike—seeking fraudulent SSNs: the
key initiatives to ensure the                   assignment of SSNs to children under age 1 and replacement Social Security
appropriate issuance of SSNs to                 cards. SSA changed its policy to require independent verification of birth
noncitizens and identify                        records for U.S.-born children age 1 and over but still only relies on visual
vulnerabilities to error or fraud
                                                inspection of birth documents of children under age 1. This lack of
SSA has not yet addressed.
                                                independent verification remains an area vulnerable to fraud. In fact, by
                                                posing as parents of newborns, GAO investigators obtained two SSNs using
                                                counterfeit documents. SSA’s policy for replacing Social Security cards,
GAO recommends that SSA                         which allows individuals to obtain up to 52 replacement cards per year, and
strengthen the integrity of its                 its documentation requirements for U.S. citizens to obtain such cards also
enumeration policies and                        increase the potential for misuse of SSNs. Of the 18 million cards issued by
procedures by taking actions such               SSA in 2002, 12.4 million, or 69 percent, were replacements. While SSA
as reviewing field compliance with
                                                requires noncitizens applying for replacement cards to provide the same
verification requirements for
enumerating noncitizens. In its                 identity and immigration information as if they were applying for a new SSN,
response to GAO’s draft report,                 its evidence requirements for citizens are much less stringent. The ability to
SSA agreed with GAO’s                           obtain many replacement cards with relatively weak documentation may
recommendations and provided                    allow individuals to impersonate others by using counterfeit documents to
information on planned and current              obtain SSNs for a range of illicit uses, including selling them to noncitizens.
actions to address them.                        Original SSNs and Replacement Social Security Cards SSA Issued in Fiscal Year 2002
                                                 Numbers in millions
www.gao.gov/cgi-bin/getrpt?GAO-04-12.
                                                 Key areas                                      U.S. citizens   Noncitizens          Total
To view the full product, including the scope    Original SSNs issued                                   4.23            1.34          5.57
and methodology, click on the link above.
                                                 Replacement Social Security Cards issued              11.45            1.00         12.45
For more information, contact Barbara
Bovbjerg at (202) 512-7215 or                    Total                                                 15.68            2.34         18.02
bovbjergb@gao.gov.                              Source: SSA.
Contents 



Letter                                                                                      1
               Results in Brief 
                                                           2
               Background
                                                                  4
               SSA Has Increased Verifications and Launched Other Key 

                 Initiatives, but Additional Actions Are Needed                             5
               SSA’s Actions to Tighten Controls Leave Some Key Areas
                 Unaddressed                                                              17
               Conclusions                                                                23
               Recommendations                                                            24
               Agency Comments                                                            25

Appendix I     Scope and Methodology                                                      27



Appendix II    Comments from the Social Security Administration                           29



Appendix III   GAO Contacts and Staff Acknowledgments                                     35
               GAO Contacts                                                               35
               Staff Acknowledgments                                                      35


Tables
               Table 1: Original SSNs and Replacement Social Security Cards SSA
                        Issued in Fiscal Year 2002                                         5
               Table 2: Composition of BSSCC's Staff                                      16
               Table 3: Comparison of Identity, Age, and Citizenship
                        Requirements for U.S. Citizens Applying for Original SSNs
                        and Replacement Cards.                                            22


Figures
               Figure 1: Required SSA Field Office Procedures for Noncitizen SSN
                        Applications                                                        8
               Figure 2: SSA’s EAE Process for Assigning SSNs to Immigrants Age
                        18 and Over                                                       14




               Page i                               GAO-04-12 Issuing Social Security Numbers
Abbreviations

ACM               Administrative Confidential Memorandum 

BSSCC             Brooklyn Social Security Card Center 

DHS               Department of Homeland Security 

EAB               Enumeration at Birth 

EAE               Enumeration at Entry 

OIG               Office of the Inspector General 

MES               Modernized Enumeration System 

MOU               Memorandum of Understanding 

POMS              Program Operations Manual System 

SAVE              Systematic Alien Verification for Entitlements 

SEVIS             Student and Exchange Visitor Information System 

SSA               Social Security Administration 

SSN               Social Security number 





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Page ii                                       GAO-04-12 Issuing Social Security Numbers
United States General Accounting Office
Washington, DC 20548




                                   October 15, 2003 


                                   The Honorable E. Clay Shaw, Jr. 

                                   Chairman 

                                   Subcommittee on Social Security 

                                   Committee on Ways and Means 

                                   House of Representatives 


                                   Dear Mr. Chairman: 


                                   In fiscal year 2002, the Social Security Administration (SSA) issued nearly

                                   6 million new Social Security numbers (SSNs), of which 1.3 million, or 

                                   22 percent, were issued to noncitizens, a proportion that has increased in

                                   recent years. Despite its narrowly intended purpose, the SSN has in 

                                   practice become the national identifier and is central to a range of 

                                   transactions and services associated with American life, including 

                                   obtaining a driver license, opening a bank account, and receiving health 

                                   care. For this reason, SSNs are key pieces of information in creating false

                                   identities. The events of September 11th underscore the importance both 

                                   of issuing SSNs only to those eligible for them and protecting those 

                                   already assigned to individuals. The flow of noncitizens into the United 

                                   States and the accompanying number of SSNs issued to this group over 

                                   the last several years add to the importance of having sound practices to 

                                   avoid issuing SSNs to those who do not qualify for them and to ensure the 

                                   identity of those who receive them. Because of your interest in this issue, 

                                   you asked us to (1) describe and assess SSA’s key initiatives to ensure the 

                                   appropriate issuance of SSNs to noncitizens and (2) identify any 

                                   vulnerabilities to error or fraud that SSA has not yet addressed in its 

                                   procedures for issuing SSNs. 


                                   To answer your questions, we examined SSA’s policies and procedures for 

                                   issuing SSNs, a process known as enumeration, and we obtained 

                                   information on key initiatives planned and undertaken to strengthen and

                                   ensure its integrity. We collected and analyzed information on SSA’s 

                                   enumeration initiatives, the results of prior internal reviews, and studies 

                                   performed by SSA’s Office of the Inspector General (OIG) and Office of 

                                   Quality Assurance. In addition, we reviewed studies and data provided by 





                                   Page 1                                 GAO-04-12 Issuing Social Security Numbers
                   the Department of Homeland Security1 (DHS) and the Department of State
                   on their specific agency processes that support SSA’s noncitizen
                   enumeration initiatives. We also analyzed audits performed by the
                   inspectors general at the Departments of State and Justice. We conducted
                   our review at SSA headquarters in Baltimore, Maryland, and in 4 of its
                   10 regional offices—Atlanta, Georgia; Chicago, Illinois; New York, New
                   York; and San Francisco, California—and at 16 field offices in those
                   regions. We selected the regional and field offices based on the following
                   criteria: (1) enumeration workload—the locations represented about
                   70 percent of noncitizen enumerations in fiscal year 2001; (2) geographic
                   distribution—the various regions across the nation representing border
                   and inland locations; and (3) best practices—locations trying innovative
                   approaches to enumeration, such as the Brooklyn, New York, Social
                   Security Card Center (BSSCC). We also collected and analyzed data and
                   documents on SSA’s enumeration initiatives and workloads. From our in-
                   depth interviews with more than 100 management and line staff, we
                   documented officials’ perspectives on SSA’s enumeration initiatives and
                   identified areas where vulnerabilities and gaps exist in SSA’s
                   implementation of these policies. Also, our investigators tested SSA’s
                   enumeration practices by posing as parents of newborns and used
                   counterfeit documents to obtain SSNs from an SSA field office and
                   through the mail. We performed our work from September 2002 through
                   July 2003 in accordance with generally accepted government auditing
                   standards.


                   SSA has increased document verifications and developed new initiatives to
Results in Brief   prevent the inappropriate assignment of SSNs to noncitizens. Though in
                   their early stages, these increased verifications and initiatives have the
                   potential to strengthen the integrity of SSA’s enumeration process. SSA
                   now requires field staff to verify noncitizens’ identity documents with the
                   DHS, in addition to continuing to require visual inspection of these
                   documents, prior to issuing an SSN. However, many field staff we
                   interviewed are relying heavily on DHS’s verification while neglecting
                   SSA’s standard inspection practices, even though both approaches are
                   necessary. We also found that SSA’s automated system for assigning SSNs
                   is not designed to prevent the issuance of an SSN if field staff bypass



                   1
                    On March 1, 2003, those functions performed by the Immigration and Naturalization
                   Service related to monitoring individuals entering the United States were transferred to the
                   Bureau of Citizenship and Immigration Services in the DHS.




                   Page 2                                         GAO-04-12 Issuing Social Security Numbers
required verification steps. SSA has also undertaken new initiatives to shift
the burden of processing noncitizen SSN applications and verifying
documents away from its field offices. In late 2002, SSA began a phased
implementation of a long-term process of redesigning how it issues SSNs
to noncitizens, called “Enumeration at Entry” (EAE). EAE relies on State
Department and DHS expertise to authenticate information provided by
applicants before they enter the country; this information is transmitted to
SSA, which then issues the SSN. Currently, EAE is limited to immigrants
age 18 and older who have the option of applying for an SSN at 1 of the
127 State Department posts worldwide that issue immigrant visas. SSA is
in the early stages of planning an evaluation of the first phase of EAE in
conjunction with the State Department and DHS. Also, SSA plans to
continue expanding the program over time to include other noncitizen
groups, such as students and exchange visitors. In addition, SSA recently
piloted a specialized center in Brooklyn, New York, which focuses
exclusively on enumeration and utilizes the expertise of DHS immigration
status verifiers and SSA’s OIG investigators.

While SSA has embarked on these new initiatives, it has not tightened
controls in two key areas of its enumeration process that could be
exploited by individuals—citizens and noncitizens alike—seeking
fraudulent SSNs: the assignment of SSNs to children under age 1 and the
replacement of Social Security cards. SSA changed its policy in 2002 to
require that field staff obtain independent, third-party verification of the
birth records for U.S.-born children age 1 and over, but it left in place its
prior policy for children under age 1, which calls only for a visual
inspection of birth documents. In our field work, we found that this lack of
independent verification remains an area vulnerable to fraud. Working in
an undercover capacity by posing as parents of newborns, our
investigators were able to obtain two SSNs using counterfeit documents.
SSA’s policy for replacing Social Security cards also increases the
potential for misuse of SSNs. The policy allows individuals to obtain up to
52 replacement cards per year. Of the 18 million cards issued by SSA in
fiscal year 2002, 12.4 million, or 69 percent, were replacement cards, and
1 million of these cards were issued to noncitizens. While SSA requires
noncitizens applying for a replacement card to provide the same identity
and immigration information as if they were applying for an original SSN,
SSA’s evidence requirements for citizens are much less stringent. The
ability to obtain numerous replacement SSN cards with relatively weak
documentation may allow individuals to impersonate others using
counterfeit documents to obtain SSNs for a wide range of illicit uses,
including selling them to noncitizens.



Page 3                                 GAO-04-12 Issuing Social Security Numbers
             The operational and policy issues that we identified in SSA’s enumeration
             functions could weaken the integrity of its enumeration system.
             Accordingly, we are making several recommendations intended to
             strengthen SSA’s policies and procedures for issuing SSNs to noncitizens
             and citizens and to enhance SSA’s coordination and deployment of new
             initiatives in this area. In its response to our draft report, SSA agreed with
             our recommendations and provided information on planned and current
             actions that they believe address them. (SSA's comments are reproduced
             in appendix II.) In particular, SSA discussed its efforts to assess field
             office staff compliance with its verification requirements as part of its
             ongoing enumeration quality reviews, to assess the accuracy of the EAE
             process, and to develop options to improve the integrity of its policies for
             issuing replacement Social Security cards.


             The Social Security Act of 1935 authorized the SSA to establish a record-
Background   keeping system to help manage the Social Security program and resulted
             in the creation of the SSN. SSA uses the SSN as a means to track workers’
             earnings and eligibility for Social Security benefits. Through a process
             known as “enumeration,” each person receives a unique number, which is
             used for the work and retirement benefit record for the Social Security
             program. Today, SSNs are issued to most U.S. citizens, and they are also
             available to noncitizens2 lawfully admitted to the United States with
             permission to work. Lawfully admitted noncitizens may also qualify for an
             SSN for nonwork purposes when a federal, state, or local law requires that
             they have an SSN to obtain a particular welfare benefit or service. SSA
             must obtain documentary evidence from such applicants regarding their
             age, identity, U.S. citizenship, immigration status, and if they were
             previously assigned an SSN. SSA’s 1,333 field offices’ primary enumeration
             responsibilities include interviewing such applicants for both original and
             replacement Social Security cards, reviewing identity and immigration
             documents, verifying immigration and work status with the DHS and State,
             and keying information into the agency’s automated enumeration system.

             In fiscal year 2002, SSA issued approximately 5.6 million original SSNs and
             12.4 million replacement cards. As shown in table 1, most of the agency’s
             enumeration workload involves U.S. citizens who generally receive SSNs



             2
              For our review, we classified noncitizens as (1) immigrants (individuals who come to the
             United States to reside permanently, e.g., the alien spouse of a U.S. citizen) and (2)
             nonimmigrants (individuals who come to the U.S. temporarily, e.g., students and visitors).




             Page 4                                        GAO-04-12 Issuing Social Security Numbers
                     at birth via states’ and certain jurisdictions’ birth registration process
                     facilitated by hospitals.3 However, the bulk of original SSNs issued by
                     SSA’s field offices are for noncitizens. These offices also process requests
                     for replacement cards—for both citizens and noncitizens.

                     Table 1: Original SSNs and Replacement Social Security Cards SSA Issued in Fiscal
                     Year 2002

                         Numbers in millions
                         Key areas                                           U.S. citizens      Noncitizens           Total
                                                                                            a
                         Original SSNs issued                                          4.23               1.34         5.57
                         Replacement Social Security cards issued                     11.45               1.00        12.45
                         Total                                                        15.68               2.34        18.02
                     Source: SSA.
                     a
                     Of the 4.23 million SSNs issued to U.S. citizens in fiscal year 2002, 3.8 million (about 89 percent)
                     were issued under SSA’s Enumeration at Birth (EAB) process, which is not part of the field office
                     workload.


                     Following the events of September 11, 2001, SSA began taking steps to
                     place a greater emphasis on improving the integrity of the enumeration
                     process. For example, to launch these efforts, the Commissioner
                     established an in-house response team to identify ways to prevent fraud
                     and formed a task force with the State Department and DHS to formalize
                     and expedite collaboration on various initiatives designed to improve the
                     verification of information furnished by noncitizen SSN applicants.


                     SSA has increased document verifications and begun other new initiatives
SSA Has Increased    to prevent the inappropriate assignment of SSNs to noncitizens, but
Verifications and    additional actions are needed to strengthen the integrity of the process.
                     SSA now requires third-party verification of all noncitizen documents with
Launched Other Key   DHS and State prior to issuing an SSN. This verification is required in
Initiatives, but     addition to existing requirements to inspect documents in-house.
                     However, many field staff we interviewed are relying heavily on the third-
Additional Actions   party verification, while neglecting SSA’s in-house practices for verifying
Are Needed           identity documents. SSA has also undertaken new initiatives to shift the



                     3
                      Under a process called Enumeration at Birth hospitals send birth registration data to a
                     state or local bureau of vital statistics, where it is put into a database. SSA accepts the data
                     captured during the birth registration process as evidence of age, identity, and citizenship
                     and assigns the child an SSN without further parental involvement.




                     Page 5                                               GAO-04-12 Issuing Social Security Numbers
burden of processing noncitizen applications away from its field offices. In
October 2002, SSA began implementing the first phase of a long-term
process to redesign how it issues SSNs to noncitizens, called
“Enumeration at Entry” (EAE). Under this initiative, State and DHS
experts screen SSN applicants before they enter the United States. SSA is
in the early stages of developing a timetable to evaluate the effectiveness
of EAE as well as to assess the potential for future expansion to other
noncitizen groups. SSA also recently piloted a specialized center in
Brooklyn, New York, to focus exclusively on enumeration and to bring on
board expertise from DHS as well as to utilize SSA’s own Inspector
General.




Page 6                                GAO-04-12 Issuing Social Security Numbers
SSA Has Stepped Up           SSA has increased document verifications by requiring independent third-
Document Verification, but   party verification of documents for all noncitizens with the issuing
Some Weaknesses Exist        agency—namely DHS and State—prior to issuing an SSN. This process—
                             called “collateral verification”4—involves field office staff performing an
                             on-line query to DHS’s Systematic Alien Verification for Entitlements
                             (SAVE)5 database to verify the immigration and work status of noncitizens.
                             If the information is not available in SAVE, field staff must mail a request
                             to DHS seeking verification. In conjunction with this verification, SSA field
                             staff are required to visually inspect the immigration and identity
                             documents presented by applicants. SSA has issued several directives and
                             produced a training video for field offices to reinforce the policy of making
                             visual inspections of applicant documents with a variety of forensic tools.
                             These include using an ultraviolet light, called a “black light,” to verify the
                             presence of embedded security features and comparing documents against
                             sample DHS documents and security guidelines contained in a binder
                             maintained in each field office.

                             SSA has also stepped up its verification of documents for foreign students
                             seeking SSNs, by requiring them to show proof of their full-time
                             enrollment. However, SSA still does not require its field staff to verify this
                             information or letters from the school stating that the student is
                             authorized to work—with the school.6 SSA also does not require that
                             students actually have a job to qualify for an SSN, only that they have been
                             authorized by their school to work on campus.7



                             4
                              As of September 2002, “collateral verification” is now required for all noncitizens. Under
                             SSA’s prior policy, it was only required for those who have been in the country more than
                             30 days.
                             5
                              The SAVE system is the only available data source on the immigration status of
                             noncitizens. We are aware of limitations in DHS’s SAVE data but have not conducted an
                             independent assessment of the quality of the records in that system. The Justice
                             Department’s Office of the Inspector General has issued several reports that questioned the
                             reliability, accuracy, and management controls over nonimmigrant data in the SAVE
                             system. (See “Immigration and Naturalization Service Monitoring of Nonimmigrant
                             Overstays,” Rept. No. I-97-08, Sept. 1997; “Follow-Up Report On INS Efforts To Improve
                             The Control Of Nonimmigrant Overstays,” Rept. No. I-2002-006, April 2002; and
                             “Immigration and Naturalization Service’s Ability to Provide Timely and Accurate
                             Alien Information to the Social Security Administration,” Rept. No. I-2003-001, Nov.
                             2002.)
                             6
                              Schools accredited by DHS may issue letters authorizing foreign students to work without
                             notifying DHS or obtaining DHS approval.
                             7
                              As of our report’s issuance, SSA was also seeking authority to require that students
                             already have an on-campus job before an SSN may be issued.



                             Page 7                                         GAO-04-12 Issuing Social Security Numbers
Figure 1. Required SSA Field Office Procedures for Noncitizen SSN Applications



                                                                           SSA Field Office

                                                         Noncitizen submits application
                                                         for SSN and is interviewed
                                                         by service representative



                                                SSA Field Office Staff Verify Information Using 3 Required Tools

                     1. Check documents under                      2. Compare documents to samples             3. Verify immigration/
                        black light for                               and security guidelines                     work status in
                        erasures,                                     in Administrative                           DHS's SAVE
                        watermarks,                                   Confidential                                database
                        and DHS inks                                  Memorandum




                                        Applicant information                                       Applicant information/docu­
                                        or documents cannot                                         ments verified visually and
                                        be verified visually                                        in SAVE; application sent to
                                        and in SAVE                                                 SSA headquarters

                                            SSN denied a


                                         End of process
                                                                                                                    Checks if
                                                                                                                    applicant
                                                                                                                    has already been
                                                                                                                    issued an SSN

                                                                                                                   If no conflict, SSN
                                                                                                                   is issued and
                                                                                               SSA Headquarters    mailed to applicant


                                                                                             End of process




Source: GAO based on SSA information.
                                                          a
                                                           SSA’s procedures call for its staff to refer these cases to SSA’s Office of Inspector General for further
                                                          review.




                                                          Page 8                                                GAO-04-12 Issuing Social Security Numbers
     Despite SSA’s actions to strengthen its processes for issuing SSNs to
     noncitizens, some weaknesses exist.

•	   Field staff rely heavily on SAVE verifications, with the result that many
     neglect to perform required in-house, visual inspection of documents in
     conjunction with the SAVE verification. Although field office staff can
     check the immigration and identity status of an individual through SAVE,
     that does not ensure that the documents presented by the applicant are
     valid. The agency’s only way of detecting whether documents by
     themselves are counterfeit is through visual inspections. However, our
     interviews with front-line field staff who perform enumeration work in
     four SSA regions indicated a potential erosion in the traditional practice of
     visually inspecting documents due to an increasing reliance on the SAVE
     database. Over a third said they do not routinely use the black light to
     verify the authenticity of applicants’ immigration documents, and only one
     in five staffers we interviewed said they regularly used SSA’s confidential
     manual of security guidelines and sample documents (known as the
     Administrative Confidential Memorandum (ACM)) to check documents
     submitted by applicants. Many field staff we interviewed said that the ACM
     was not readily accessible; several said they did not know where it was
     located in their office. In addition, staff in several offices told us that their
     black light did not always work. Since SSA field office staff are the only
     persons who actually see the noncitizen’s documents, it is critical that they
     make use of all available tools to ensure the authenticity of those
     documents.8 Nevertheless, more than a fourth of the field staff we
     interviewed told us that using the SAVE database to verify immigration
     status made visual inspections of documents unnecessary.

•	   SSA’s automated enumeration system allows field staff to bypass key
     verification steps and still issue an SSN. Recent improvements to SSA’s
     automated computer system for assigning SSNs, known as the Modernized
     Enumeration System (MES), have not eliminated several weaknesses that
     would allow for a breach of security. MES does not contain separate and
     distinct fields for field staff to record their use of each of the required
     verification procedures. Furthermore, it is possible for staff to process an
     SSN application without keying information into MES on the evidence
     they have reviewed and accepted. Under this situation, there is no
     consistent means for SSA to verify and review what verifications field staff
     actually did perform when they processed an SSN application. SSA



     8
      When SSA field office staff question the authenticity of a noncitizen’s documents, they
     submit photocopies of those documents to DHS to be verified.




     Page 9                                         GAO-04-12 Issuing Social Security Numbers
     officials told us that they are aware of this problem, but due to budget
     reasons, they have yet to develop a formal plan to address it.

•	   Another automation-related weakness concerns SSA field staff use of
     DHS’s SAVE system. When field staff perform a SAVE verification, the
     SAVE system generates a unique reference number. However, it is possible
     to enter a made-up SAVE reference number without having actually
     verified an individual’s status. This ability to bypass the SAVE system
     represents an internal control weakness in SSA’s noncitizen enumeration
     process. SSA officials told us that it may be possible to modify SAVE so
     that after SSA staff successfully verify an individual’s immigration status,
     proof of that verification would be automatically entered into the MES
     application, creating an audit trail. However, SSA officials noted that such
     a modification would require creating an interface between DHS’s SAVE
     system and SSA’s MES, and they have not yet fully explored this
     possibility.

•	   Verification for foreign students attending U.S. schools also remains
     problematic. SSA recently revised its rules to require that students provide
     evidence of full-time enrollment at an accredited educational institution.
     However, field office staff are not required to verify either the full-time
     enrollment or the work authorization letters with the educational
     institution. Most field staff we interviewed told us they do not verify work
     authorization letters unless they appear questionable. One staffer told us
     she assumes a letter is authentic if it is “on high-quality paper.” In addition,
     managers in two SSA field offices told us they were unclear about SSA’s
     requirements for enumerating noncitizen students. A recent investigation
     by SSA’s OIG uncovered a ring of 32 foreign students in four states who
     used forged work authorization letters to obtain SSNs. Those students
     were either indicted for criminal offenses or taken into DHS custody.
     However, an unknown number of other students associated with this ring
     had already obtained illegal SSNs with forged work authorization letters. A
     foreign student Web site that we found highlights the inconsistencies in
     SSA’s enumeration practices and advocates that students seeking SSNs
     “shop around” for offices that are more likely to grant an application.

     “If you are not authorized to work, ask your Foreign Student Advisor for help. Sometimes
     they can give you a letter to the SSA stating that you need a SSN for on-campus
     employment. Here’s a sample letter. If you can’t get this letter at least get a certificate of
     attendance, preferably addressed to the Social Security Administration. Sometimes SSA
     clerks don’t really read these letters, they just look at them. [Emphasis added]

     Go to your local SSA office and ask them if you can get a SSN. Regulations in different
     offices are different, so try going to several different SSA offices (this approach




     Page 10                                          GAO-04-12 Issuing Social Security Numbers
                        works with many large bureaucracies, like banks and phone companies). [Emphasis added]
                        Sometimes it even depends on a clerk you talk to. If they accept your application it means
                        you’ll get the number. If they don’t accept it, it isn’t recorded anywhere and you can
                        try as many times as you like.” [Emphasis added]

                        Source: Withheld.



                        Forged work authorization letters are not the only avenues for fraud in the
                        enumeration of noncitizen students. Both managers and field office staff
                        told us that SSA’s policy on enumerating students was open to fraud
                        because it requires only that the student be “authorized to work on
                        campus,” and not that the student actually be working, or even have a job
                        offer. One district manager, saying that enumerating noncitizen students
                        for on-campus jobs is “fraught with the potential for fraud,” cited schools
                        operating out of storefronts that nevertheless issued work authorization
                        letters for students, claiming the students were working “on campus.”
                        According to SSA policy, these students are entitled to receive SSNs. In
                        addition, one regional official even described schools selling work
                        authorization letters to students who wished to get SSNs.

                        SSA headquarters officials said that they were aware of weaknesses
                        associated with enumerating foreign students and were working on
                        improving the integrity of these processes. For example, SSA is exploring
                        gaining access to DHS’s foreign student tracking database, the Student and
                        Exchange Visitor Information System (SEVIS), which would permit the
                        agency to check if a noncitizen student is enrolled full-time in an
                        accredited school.9 In addition, SSA officials told us that the agency is in
                        the process of exploring options to address these weaknesses, such as
                        requiring foreign students to prove that they actually have an on-campus
                        job.


SSA Has Begun a Long-   SSA is in the early stages of a long-term process of redesigning how it
Term Initiative to      issues SSNs to noncitizens, which it calls the “Enumeration at Entry”
Enumerate Noncitizens   (EAE) project. SSA considers EAE to be an essential component of its
                        fraud prevention efforts that will curtail its current dependence on visually
before They Enter the   inspecting and verifying documents that are easily forged or misused.
Country

                        9
                         Presently, DHS’s SEVIS database does not track foreign student on-campus employment
                        or work authorization. DHS has expressed interest in adding that information to the data
                        gathered on noncitizen students, but has no immediate plans to do so.




                        Page 11                                       GAO-04-12 Issuing Social Security Numbers
     Under EAE, SSA entered into Memoranda of Understanding (MOU) with
     State and DHS for those agencies to assist SSA by obtaining and
     examining, as part of immigration processing, all of the information SSA
     needs to assign SSNs to immigrants after they enter the United States.10
     Since its start in 2002, EAE has grown from 3 sites in 3 countries to all
     127 State posts worldwide that issue immigrant visas. Currently, EAE is
     available only to immigrants age 18 or older who are seeking permanent
     residence in the United States, and it is not used for temporary visitors
     such as students and exchange visitors. According to SSA, the current
     phase of EAE will

•	   improve integrity of the enumeration process by ending field staff
     dependence on immigration documents that can be forged or misused by
     noncitizens attempting to fraudulently acquire SSNs;

•	   improve overall government efficiency by eliminating duplication of data
     collection by SSA, State, and DHS;

•    create financial savings of approximately $5.13 million annually;11 and

•	   provide a one-stop service for noncitizen SSN applicants, whereby
     noncitizens can apply for an immigrant visa and an SSN on the same
     application prior to entering the United States.

     The EAE process is depicted in figure 2 and begins when an immigrant
     applies for a visa at one of State’s visa-issuing posts around the world and
     continues when the immigrant later arrives at a U.S. port of entry where
     DHS performs various immigration and security checks. The process ends
     when SSA electronically screens the information provided by DHS for
     errors and assigns the individual an SSN.




     10
       Representatives of the Immigration and Naturalization Service (INS) [INS was transferred
     to DHS in 2003] and SSA signed a MOU in October 2002 and December 2002, respectively.
     SSA also has a 1996 MOU with State.
     11
       SSA’s estimated savings are based on a projection of 400,000 immigrants availing
     themselves of EAE once the current phase is fully implemented. SSA calculated the savings
     by multiplying 400,000 by $13.48 (the SSA field office unit cost for processing an SSN
     application) resulting in $5.39 million from which SSA subtracted $263,000 of yearly costs
     SSA pays DHS for processing SSN information under EAE. This resulted in an annual
     savings estimate of $5.13 million.




     Page 12                                       GAO-04-12 Issuing Social Security Numbers
During the first 7 months that SSA began receiving records under EAE—
November 2002 through May 2003—SSA reported assigning 9,627 original
SSNs and 5,501 replacement cards12 to immigrants who applied at one of
the State Department’s worldwide visa-issuing posts. To date, SSA is
having problems with the accuracy and completeness of the automated
EAE records received, resulting in the agency’s need to correct the errors,
including contacting the applicant after he or she enters the country.
Problems include the use of abbreviated data (e.g., using Ma for Maria);
the incorrect use of country codes (e.g., PHI instead of PHL for the
Philippines); and, in some instances, missing data fields (e.g., the city,
state, and zip code of the applicant’s place of birth). SSA officials said that
the three agencies have begun working to correct these problems and
anticipate having them resolved in the near future.




12
 As part of the visa application process, State consulate officials also ask immigrants who
already have an SSN, if they would like SSA to send them a replacement Social Security
card.




Page 13                                        GAO-04-12 Issuing Social Security Numbers
Figure 2: SSA’s EAE Process for Assigning SSNs to Immigrants Age 18 and Over




                                       Page 14                                 GAO-04-12 Issuing Social Security Numbers
                          According to SSA officials, the agency intends to evaluate the initial phase
                          of EAE in conjunction with the State Department and DHS after it has
                          been in full operation for at least a year or at a mutually agreed upon time.
                          SSA is also planning to begin discussions with DHS and State on
                          expanding the process to other noncitizen groups, such as students and
                          exchange visitors. SSA officials told us that, as additional groups of
                          noncitizens are phased in, it expects to further reduce its field office
                          enumeration workload. Currently, SSA officials said that they are only in
                          the early stages of developing a timetable to estimate either when the
                          agencies would start to evaluate the first phase of EAE or when it would
                          begin discussions on EAE expansion. SSA officials noted that the
                          expansion of EAE to nonimmigrant groups, such as students or exchange
                          visitors, would probably take longer and be more challenging because of
                          the diversity of the populations and differences in State, DHS, and SSA
                          information systems and business processes. For example, according to
                          SSA and DHS officials, the process for transmitting information on groups
                          other than legal permanent residents13 is not fully automated.


SSA Is Piloting a         In November 2002, SSA established a pilot center in Brooklyn, New York,
Specialized Enumeration   to specialize in enumeration (now known as the Brooklyn Social Security
Center                    Card Center, or BSSCC) wherein its staff is assisted by in-house DHS staff
                          and focuses full time on enumeration and verification. In addition, SSA­
                          OIG employees are on call to assist the BSSCC’s staff. The center provides
                          citizens and noncitizens residing in Brooklyn a one-stop location for
                          applying for SSNs and replacement Social Security cards and is the only
                          location where residents of Brooklyn can receive such services. If a
                          Brooklyn resident visits one of SSA’s 12 Brooklyn offices other than the
                          BSSCC to apply for a SSN or a replacement card, they are referred to the
                          center for assistance. As of April 2003, the BSSCC had processed a total of
                          44,000 Social Security cards, with 18,000 of those for noncitizens. SSA
                          officials plan to use this centralized and specialized location to prevent the
                          inappropriate issuance of SSNs and to expand the concept to other
                          locations.

                          According to SSA and DHS officials, a major benefit of the BSSCC is its
                          specialized personnel and the immediate, on-site verification of documents
                          submitted by applicants for SSNs and replacement cards. SSA officials told



                          13
                           Legal permanent residents are immigrants who have been granted permission to live and
                          work permanently in the United States.




                          Page 15                                     GAO-04-12 Issuing Social Security Numbers
us that the enumeration center staff would become more specialized and
skilled at identifying fraudulent documents as they perform only
enumeration duties. In addition, on-site DHS staff who verify documents
(called status verifiers) have access to DHS databases not available to SSA
staff, and their presence is expected to improve DHS response time and
accelerate the verification of applicant documents. (See table 2 for the
composition of BSSCC’s staff.) Also, SSA’s New York regional officials
told us that they have experienced a reduced enumeration workload for
the 12 neighboring SSA field offices. These officials also told us that the
use of one location for enumeration would increase SSA’s control over
SSNs and reduce the issuance of duplicate cards. For example, having only
one center where citizens and noncitizens residing in the service area were
required to apply for SSNs and replacement cards might eliminate the
opportunity for individuals to “shop around” various SSA field offices in
the region, using fraudulent documents in order to obtain an SSN.

Table 2: Composition of BSSCC’s Staff

    Providing agency             Type of staff                                   Number of staff
    SSA                          Manager                                                            1
                                 Operations supervisor                                               1
                                 Management support specialist                                       1
                                 Service representative                                             6
                                 Teleservice representative                                          9
                                 Claims representative                                              15
    DHS                          Status verifiera                                                   1
    Total                                                                                           34
Source: SSA.

Note: SSA-OIG’s New York Office agents are on call to support the BSSCC at the request of
BSSCC’s manager.
a
 DHS initially provided two status verifiers for the BSSCC; as of June 2003, DHS reconsidered the
need for these staff and had removed one of them.


SSA and DHS officials have made some revisions to the BSSCC’s staffing
plan. SSA’s draft design plan for the center included on-site DHS
investigators, who are experts in identifying fraudulent documents, as well
as SSA-OIG investigators. However, after discussions with SSA, DHS
agreed to provide status verifier staff in the BSSCC, who have access to
DHS databases not available to SSA staff but do not have the technical
expertise to authenticate and identify fraudulent documents. DHS’s
decision to place status verifiers in the BSSCC, rather than more
specialized investigators, who are skilled at authenticating and identifying


Page 16                                             GAO-04-12 Issuing Social Security Numbers
                    fraudulent documents, may diminish SSA’s ability to detect fraudulent
                    documents. Presently the main function of the one status verifier co­
                    located with SSA staff, is to check DHS databases that are unavailable to
                    SSA staff, rather than to authenticate documents. Furthermore, SSA’s OIG
                    employees, at one time physically based at the center, are now available
                    only on an on call basis to assist the BSSCC staff.

                    Thus far, SSA has encountered workload issues involving returned mail
                    processed through the BSSCC. According to SSA officials, the postal
                    service returns mailed Social Security cards processed through the center
                    as undeliverable at a higher than usual rate for other field offices. SSA
                    officials told us the mailing errors might be occurring due to problems
                    associated with a high frequency of similar names for noncitizens who use
                    the center. However, they have not yet evaluated the returned mail issue
                    and other performance issues associated with the enumeration center.

                    According to SSA officials, the BSSCC is operating on a trial basis for a
                    period of 1 year during which SSA plans to evaluate its effectiveness. SSA
                    officials told us that they will conduct two studies to evaluate the center:
                    (1) SSA and DHS are to study if the center is serving the needs of SSA and
                    if it is cost-effective for DHS to provide on-site status verifiers and (2) SSA
                    will perform a separate assessment of the center, which may address
                    issues such as trends in applicants’ submission of fraudulent documents to
                    obtain SSNs.14 However, SSA officials told us that a consideration of the
                    long-term feasibility of the enumeration center in relation to SSA’s other
                    initiatives to improve the integrity of issuing SSNs to noncitizens—for
                    example, EAE, is not part of their analysis. This is a key issue considering
                    that SSA’s progress in implementing and expanding the EAE initiative,
                    whereby noncitizens apply for SSNs prior to entering the United States,
                    could influence the number of additional card centers needed, or mitigate
                    the need for such centers altogether in the long term.


                    Although SSA is undertaking a number of initiatives specifically
SSA’s Actions to    addressing the enumeration of noncitizens, it has not addressed two areas
Tighten Controls    that are especially vulnerable to fraud by citizens and noncitizens alike:
                    the assignment of Social Security numbers to children under age 1 and the
Leave Some Key      replacement of Social Security cards. Although SSA changed its policy in
Areas Unaddressed   2002 to require third-party verification of the birth records of U.S.-born


                    14
                         As of the completion of our audit work, SSA has not yet finalized this evaluation plan.




                    Page 17                                            GAO-04-12 Issuing Social Security Numbers
                          citizens over age 1, it left in place its prior policy for children under age
                          1 that calls only for a visual inspection of birth records. SSA’s policy for
                          replacing Social Security cards allows individuals to obtain up to
                          52 replacements a year with no lifetime limit and allows U.S. citizens to
                          obtain replacement cards with less documentation than an original SSN.
                          Of the 18 million cards issued by SSA in fiscal year 2002, 12.4 million, or
                          69 percent, were replacement cards. Some field staff we interviewed told
                          us that despite their reservations about individuals who have sought
                          replacement cards in “excessive” numbers, SSA policy required them to
                          issue the cards.


Process for Assigning     The implementation of SSA’s policy of assigning SSNs to children under
Social Security Numbers   age 1 may create opportunities for individuals with criminal intent to use
to Children under Age 1   false or stolen birth records to obtain an SSN. While the majority of
                          newborns in fiscal year 2002 received SSNs at birth through a hospital
Creates Fraud             registration processes that SSA calls Enumeration-at-Birth (EAB),15 the
Opportunities             parents of about 368,000 U.S.-born children under age 18 applied for an
                          SSN for their children at field offices using their own birth evidence
                          documents.16 In 2002, SSA began requiring field offices to verify these birth
                          records for U.S. citizens age 1 or older with a state or local bureau of vital
                          statistics. However, SSA exempted records for children under age 1 from
                          this policy. According to SSA, it excluded children under age 1 from its
                          third-party verification requirements to limit potential service disruptions
                          to these applicants due to possible delays in entry of birth information by
                          some state or local bureaus of vital statistics. Parents or guardians often
                          need an SSN for their child soon after birth so they can claim the child as a
                          dependent for tax purposes or because an SSN is required for such
                          purposes as opening a bank account or applying for government services.

                          SSA’s decision to verify most birth certificates had been prompted by an
                          SSA OIG finding that, despite training and guidance, field staff were




                          15
                           Of the 4.2 million SSNs issued to U.S. citizens in fiscal year 2002, about 89 percent, or 3.8
                          million, were issued under SSA’s EAB process. Under EAB, hospitals send birth
                          registration data to a state or local bureau of vital statistics where it is put into a database.
                          SSA accepts the data from the birth registration process as evidence of age, identity, and
                          citizenship and assigns the child an SSN without further parental involvement.
                          16
                           SSA does not maintain data on the actual number of children enumerated outside of the
                          EAB process each year.




                          Page 18                                           GAO-04-12 Issuing Social Security Numbers
                          unable, by themselves, to detect counterfeit birth certificates.17 In one
                          case, individuals posing as parents of infants were able to obtain over
                          1,000 new SSNs based on fraudulent birth certificates.18 Also, the OIG
                          reported that, without means to independently verify the authenticity of
                          out-of-state birth certificates, field office staff were less likely to question
                          this documentation.

                          We found that SSA’s policy to exempt birth records for children under age
                          1 from third-party verification has left the enumeration process open to
                          fraud. During our fieldwork, we found an example of a noncitizen who
                          submitted a counterfeit birth certificate in support of an SSN application
                          for a fictitious U.S.-born child under age 1. In this case, the SSA field office
                          employee identified the counterfeit state birth certificate by comparing it
                          with an authentic one. However, SSA staff acknowledged that if a
                          counterfeit out-of-state birth certificate had been used, SSA would likely
                          have issued the SSN because of staff unfamiliarity with the specific
                          features of the numerous state birth certificates.

                          Indeed, we were able to prove the ease with which individuals can obtain
                          SSNs by exploiting SSA’s current processes. Working in an undercover
                          capacity, our investigators were able to obtain two SSNs for children
                          under age 1 by using counterfeit documents. By posing as parents of
                          newborns, they obtained the first SSN by applying in person at a SSA field
                          office using a counterfeit birth certificate; they obtained the second SSN
                          by submitting the counterfeit birth record via the mail. In both cases, SSA
                          staff verified our counterfeit documents as being valid. SSA officials told
                          us that the agency plans to re-evaluate its policy for enumerating children
                          under age 1 but has no specific time frame for doing so. The officials also
                          acknowledged that a challenge facing the agency is to strike a better
                          balance between serving the needs of the public and ensuring SSN
                          integrity.

SSA Policy on Replacing   SSA’s policy for replacing Social Security cards, which allows individuals
Social Security Cards     to obtain up to 52 replacement cards per year; as well as its documentation
Invites Abuse             requirements for U.S. citizens to obtain replacement cards, whereby U.S.



                          17
                           SSA Office of the Inspector General, Procedures for Verifying Evidentiary Documents
                          Submitted with Original Social Security Number Applications, A-08-98-41009 (Sept.
                          2000).
                          18
                           SSA Office of the Inspector General, Management Advisory Report: Using Social
                          Security Numbers to Commit Fraud, A-08-99-42002 (May 28, 1999).




                          Page 19                                     GAO-04-12 Issuing Social Security Numbers
citizens can obtain replacement cards with less documentation than an
original SSN, also increases the potential for misuse of SSNs. Of the
18 million cards issued by SSA in fiscal year 2002, 12.4 million, or
69 percent, were replacement cards, and 1 million of these cards were
issued to noncitizens.

SSA field staff we interviewed told us that despite their reservations
regarding individuals seeking high numbers of replacement cards, they are
required under SSA policy to issue the cards. For example, one field
staffer spoke of replacement card applicants who already have made
numerous requests and continue to make new requests.19 Furthermore,
many of the field office staff and managers we spoke with acknowledged
that the current policy weakens the integrity of SSA’s enumeration
process.

In September 2001, SSA’s OIG reported numerous cases in which SSA had
issued replacement cards where potential misuse existed, such as multiple
individuals working under a single name and SSN. 20 For example, the OIG
found that SSA issued 23 replacement cards to a 19-year-old male who had
$113,000 in earnings from 24 employers in 19 states during 1999. In another
case, SSA had issued 12 replacement cards to a 25-year-old male with a
suspect work history: $106,000 in earnings from 12 employers in 8 states
and over $10,000 in earnings under his SSN but under a different name in
1999; $83,000 earnings from 10 employers in 1998; and $60,000 in earnings
from 13 employers in 1997. The OIG concluded, “It is highly improbable
that in 1 year an individual could work for multiple employers in
numerous states and earn significant income from traditionally low paying
jobs, such as those in the agriculture and service industries.”

Beyond SSA’s policy on providing 52 replacement cards per year, its
identity and document requirements for providing such cards to citizens
could further threaten SSN integrity. While SSA requires noncitizens
applying for a replacement card to provide the same identity and
immigration information as if they were applying for an original SSN,
SSA’s evidence requirements for citizens are much less stringent. (See



19
 SSA’s automated system shows field staff how many times an individual has applied for a
replacement card, which office processed the application, and when it was processed.
20
 SSA Office of the Inspector General, Replacement Social Security Number Cards:
Opportunities to Reduce the Risk of Improper Attainment and Misuse, A-08-00-10061
(Sept. 2001).




Page 20                                      GAO-04-12 Issuing Social Security Numbers
table 3.) Citizens are not required to prove their U.S. citizenship and can
apply for a replacement card without photograph identification, using
documentation such as a school report card, church membership record,
or a life insurance policy. This represents a vulnerability in the application
process due to the ease with which identity documents, especially those
without photographs, can be forged. Thus, an individual could easily
impersonate a legitimate SSN cardholder to obtain large numbers of
replacement cards for a wide range of illicit uses, including selling them to
noncitizens.




Page 21                                 GAO-04-12 Issuing Social Security Numbers
Table 3: Comparison of Identity, Age, and Citizenship Requirements for U.S. Citizens Applying for Original SSNs and
Replacement Cards.

 Original SSN requirements                                                         Replacement card requirements
 Proof of identity                                                                 Proof of identity
 (Any one or a combination of the following)                                       Same as for an original SSN.
 • Driver’s license
 • U.S. passport
 • School ID card
 • School record
 • School report card
 • Marriage or divorce record
 • Adoption record
 • Health insurance card (except Medicare card)
 • Life insurance policy
 • Clinic, hospital, or doctor records
 • Church membership or confirmation record

 Proof of age                                                                      Proof of age
 (Any one or a combination of the following)                                       Only required if there is a discrepancy between the date of birth on
 • U.S. birth certificate                                                          the application and the evidence presented with the application.
 • Religious record established before age 5 showing age
 • Notification of birth registration

 Proof of U.S. citizenship                                                         Proof of U.S. citizenship
 (Any one of the following)                                                        Not necessary.
 • U.S. passport
 • U.S. birth certificate
 • 	 Religious record recorded in the U.S. within 3 months after
     birth
 • Certificate of naturalization
 • Certificate of citizenship
 • Adoption finalization papers
 • 	 Other document that establishes a U.S. place of birth or U.S.
     citizenship

Source: GAO analysis of SSA’s enumeration procedures.


Note: The above lists are not all-inclusive and differ for children under age 1.


                                                        In our audit work, we identified Web sites and publications that give “how-
                                                        to” guidance and design samples to assist individuals in making
                                                        counterfeit documents that can be used in support of an application for
                                                        either a new SSN or a replacement card, such as school cards, baptismal
                                                        certificates, and hospital records. In addition, one guide offered tips on
                                                        getting SSNs through the mail using such counterfeit documents.




                                                        Page 22                                           GAO-04-12 Issuing Social Security Numbers
              “Generally, there are two ways that one can receive a [… ] social security number. Through
              the mail or in-person at the local social security office. I would suggest that you try to
              do everything through the mail…In my opinion,…you should never go to the SS
              office in person. [Emphasis added] Obviously, if there is a problem with your documents
              and you need to walk away from the process, with a mail drop, you simply close it and
              walk away. There is no more connection to you, but to be fair, I have never heard of a
              problem at the SSN office.”

              Source: Withheld.



              SSA officials told us the agency is considering limiting the number of
              replacement cards to 2 per year and 10 cards over an individual’s lifetime,
              with certain exceptions for name changes, administrative errors, and
              hardship. However, SSA officials cautioned that while support exists for
              this change within the agency, some advocacy groups, such as those
              representing the homeless and mentally ill, oppose such a limit. At the
              completion of our audit work, it was unclear whether SSA would address
              the weaknesses in its document requirements for providing replacement
              cards to citizens. Until SSA changes its policy in this area, there will be an
              increased chance that both citizens and noncitizens seeking to
              fraudulently obtain SSNs may target this vulnerable area.


              SSA has made substantial progress toward strengthening its processes for
Conclusions   issuing SSNs to noncitizens through initiatives that involve improvements
              to old procedures as well as broad new approaches. Indeed, the agency
              has taken a step it has never before attempted by requiring that the
              immigration and work status of every noncitizen applicant be verified
              through an independent third-party source before an SSN is issued.
              However, without further systems improvements and staff compliance
              with all prescribed verification procedures, this initiative may not
              sufficiently prevent the issuance of SSNs to individuals seeking to
              fraudulently obtain them.

              Beyond changes to its verification procedures, SSA’s ability to corroborate
              the immigration status and identity information of noncitizen applicants
              may be further enhanced by newly implemented initiatives such as EAE
              and the BSSCC. SSA’s collaboration with the Departments of State and
              Homeland Security through the EAE initiative brings additional resources
              to bear on noncitizen applications. However, because this program
              represents a considerable change to the enumeration process, it merits a
              thorough evaluation to overcome operational problems and to identify




              Page 23                                       GAO-04-12 Issuing Social Security Numbers
                       changes that may be needed before it is expanded to other noncitizen
                       groups.

                       Similarly, specialized enumeration centers that combine the expertise of
                       SSA and DHS examiners have the potential to better deter SSN fraud and
                       identity theft, as well as improve the timeliness and accuracy of the
                       service SSA provides. Because EAE will not be fully realized for many
                       years, the enumeration center concept may also represent a viable near-
                       term strategy for concentrating expertise in key geographic regions to
                       process SSNs for applicants already in the country. However, a
                       comprehensive evaluation of the effectiveness of the BSSCC, as well as an
                       assessment of the long-term viability of additional centers in the face of
                       future EAE expansion are needed to help SSA think more strategically
                       about how it can be best positioned to ensure the integrity of its
                       enumeration process.

                       Finally, SSA’s substantial efforts may be undercut by other vulnerabilities
                       that remain unaddressed. As SSA closes off many avenues of unauthorized
                       access to SSNs, perpetrators of fraud will likely shift their strategies to
                       less protected areas. In particular, SSA’s policies for enumerating children
                       under age 1 and providing replacement cards may well invite such activity,
                       unless they, too, are modified.


                       To strengthen the integrity of SSA’s policies and procedures for
Recommendations        enumerating noncitizens, we recommend that the Commissioner of Social
                       Security take the following actions:

                  •	   Perform systematic reviews of field office compliance with verification
                       requirements for enumerating noncitizens and identify corrective actions
                       needed to ensure maximum effectiveness of this process.

                  •	   Enhance the Modernized Enumeration System to prevent staff from
                       issuing SSNs without following required verification procedures.

                  •	   Develop and implement a structured evaluation plan to assess the initial
                       operation of the EAE initiative and identify SSA, State Department, and
                       DHS business process changes needed to expand EAE to additional
                       groups of noncitizens. For the initial phase of EAE, this evaluation should
                       determine the accuracy of SSN issuance decisions and causes of
                       operational weaknesses. To assist SSA in moving forward on EAE
                       expansion, the assessment should identify categories of noncitizens to
                       which EAE can and should be expanded as well as additional data



                       Page 24                               GAO-04-12 Issuing Social Security Numbers
                         collection and changes to automated systems that will be needed by all
                         three participating agencies.

                    •	   Evaluate the BSSCC to assess the feasibility of expansion to other
                         locations and interaction with SSA’s other initiatives to improve the
                         integrity of SSN issuance to noncitizens. This should include an
                         assessment of the (1) need and role of possible future centers in relation
                         to the agency’s plans to expand EAE; (2) accuracy of SSN issuance
                         decisions, its value as a fraud detection and prevention tool, and its impact
                         on surrounding field office workloads; and (3) the costs and benefits of
                         how such centers would function without DHS staff on-site.

                    •	   Revise its requirement for verification of the birth records of U.S. citizens
                         who apply for an SSN to require third-party verification of the birth
                         records of children under age 1.

                    •	   Reassess SSA’s policies for issuing replacement Social Security cards and
                         develop options for deterring abuse in this area.


                         We obtained written comments on a draft of this report from the
Agency Comments 
        Commissioner of SSA. SSA's comments are reproduced in appendix II.
                         SSA agreed with our recommendations to strengthen its policies and
                         procedures for issuing SSNs to noncitizens and citizens alike and to
                         enhance coordination and deployment of new initiatives in this area. SSA
                         also provided information on planned and current actions that it believes
                         address our recommendations. In particular, SSA discussed its efforts to
                         assess field office staff compliance with its verification requirements as
                         part of its ongoing enumeration quality reviews, to assess the accuracy of
                         the EAE process, and to develop options to improve the integrity of its
                         policies for issuing replacement Social Security cards. SSA also provided
                         technical comments on our draft report, which we incorporated where
                         appropriate.




                         Page 25                                 GAO-04-12 Issuing Social Security Numbers
We are sending copies of this report to the Commissioner of SSA, the
Secretary of Homeland Security, the Secretary of State, and other
interested parties. Copies will also be made available to others upon
request. In addition, the report will be available at no charge on GAO's
Web site at http://www.gao.gov. If you have any questions concerning this
report, please call me on (202) 512-7215. Key contributors to this report
are listed in appendix III.

Sincerely yours,




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




Page 26                               GAO-04-12 Issuing Social Security Numbers
Appendix I: Scope and Methodology 



              The Chairman, Subcommittee on Social Security, House Committee on
              Ways and Means asked us to describe and assess the Social Security
              Administration’s (SSA) initiatives to ensure the appropriate issuance of
              Social Security Numbers (SSNs) to noncitizens and to identify
              vulnerabilities to error or fraud SSA has not yet addressed. To address the
              Chairman’s questions, we examined SSA’s enumeration policies and
              procedures and obtained information on key initiatives planned and
              undertaken to strengthen SSA’s processes to ensure the integrity of the
              enumeration process. We also reviewed SSA’s current noncitizen
              enumeration processes to identify areas where existing and recent
              changes to its Program Operations Manual System (POMS) were not being
              followed or the POMS guidance was not sufficient to ensure the integrity
              of the enumeration process. We collected and analyzed implementing
              documentation and available performance data on the timeliness,
              accuracy, and workload impacts for key noncitizen enumeration
              initiatives, including Enumeration at Entry (EAE), Collateral Verification,
              and Enumeration Centers. We analyzed the results of prior reviews and
              studies performed by SSA’s Office of the Inspector General (OIG) and
              Office of Quality Assurance. In addition, we reviewed studies and data
              provided by the Department of Homeland Security (DHS) and Department
              of State on their specific agency processes that support SSA’s noncitizen
              enumeration initiatives. We also analyzed our prior reports, related
              documents, and audits performed by the Inspectors General at the
              Departments of State and Justice. We conducted our review at SSA
              headquarters in Baltimore, Maryland, and in 4 of its 10 regional offices—
              Atlanta, Georgia; Chicago, Illinois; New York, New York; and San
              Francisco, California (and at 17 field offices in those regions). We
              selected the regional and field offices based on the following criteria
              (1) enumeration workload—the locations represented about 70 percent of
              noncitizen enumerations in 2001; (2) geographic distribution—the regions
              are dispersed across the nation, representing border and inland locations;
              and (3) best practices—locations trying innovative approaches to
              enumeration, such as the Brooklyn, New York, Social Security Card Center
              (BSSCC). We also collected and analyzed data and documents on SSA’s
              enumeration initiatives and workloads.

              We documented officials’ perspectives on SSA’s enumeration initiatives
              and identified areas where vulnerabilities and gaps exist in SSA’s
              implementation of these policies from our in-depth interviews with more
              than 100 management and line staff. From our analysis of documents and
              data obtained during fieldwork, we were able to identify significant
              problems and issues associated with implementing these initiatives.
              Furthermore, we identified best practices developed at the regional or


              Page 27                               GAO-04-12 Issuing Social Security Numbers
Appendix I: Scope and Methodology




local levels that have the potential to improve the integrity of SSN issuance
to noncitizens nationally. Also, our investigators tested SSA’s enumeration
practices by posing as parents of newborns and used counterfeit
documents to obtain SSNs from an SSA field office and though the mail.
We performed our work from September 2002 through July 2003 in
accordance with generally accepted government auditing standards.




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Appendix II: Comments from the Social
Security Administration




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Appendix II: Comments from the Social Security Administration




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Appendix II: Comments from the Social Security Administration




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Appendix II: Comments from the Social Security Administration




Page 34                                      GAO-04-12 Issuing Social Security Numbers
Appendix III: GAO Contacts and Staff
Acknowledgments

                  Barbara Bovbjerg, (202) 512-7215 

GAO Contacts      Daniel Bertoni, (202) 512-5988 

                  Anthony J. Wysocki, (202) 512-6016 



                  In addition to those named above, the following team members made key
Staff             contributions to this report throughout all aspects of its development:
Acknowledgments   Patricia M. Bundy, William E. Hutchinson, Eileen Peguero, and Jill D. Yost.
                  In addition, Susan C. Bernstein, Andrew O’Connell, and Roger J. Thomas
                  made contributions to this report.




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                  Page 35                                GAO-04-12 Issuing Social Security Numbers
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