Social Security Administration:

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

GAO-04-12: Published: Oct 15, 2003. Publicly Released: Oct 15, 2003.

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In 2002, the Social Security Administration (SSA) issued nearly 6 million new Social Security numbers (SSNs), of which 1.3 million were issued to noncitizens. Despite its narrowly intended purpose, the SSN has in practice become the national identifier. SSNs are key pieces of information in creating false identities, underscoring the importance of issuing SSNs only to those eligible for them and of protecting those already assigned to individuals. The flow of noncitizens into the United States and the accompanying number of SSNs issued to them over the last several years add to the importance of having sound practices to avoid issuing SSNs to those who do not qualify for them. Congress asked GAO to describe and assess SSA's key initiatives to ensure the appropriate issuance of SSNs to noncitizens and identify vulnerabilities to error or fraud SSA has not yet addressed.

SSA Has Increased Noncitizen Verifications and Begun New Initiatives: SSA has taken steps to prevent the inappropriate assignment of SSNs to noncitizens. SSA now requires field staff to verify noncitizens' identity documents with the Department of Homeland Security (DHS), in addition to continuing to require visual inspection of these documents, prior to issuing an SSN. However, many field staff GAO interviewed are relying heavily on DHS's verification while neglecting SSA's standard inspection practices, even though both approaches are necessary. SSA has also undertaken new initiatives to shift the burden of processing noncitizen SSN applications and verifying documents from its field offices. In 2002, SSA started implementation of a process called "Enumeration at Entry" (EAE), which relies on State Department and DHS expertise to authenticate information provided by SSN applicants. SSA is in the early stages of planning to evaluate EAE with the State Department and DHS. Also, SSA recently piloted a specialized center in Brooklyn, New York, which focuses on enumeration and uses the expertise of DHS staff and SSA's Office of the Inspector General investigators. Some Areas Affecting Issuance of SSNs Not Yet Addressed: While SSA has embarked on these new initiatives, it has not tightened controls in two key areas of its enumeration process that could be exploited by individuals--citizens and noncitizens alike--seeking fraudulent SSNs: the assignment of SSNs to children under age 1 and replacement Social Security cards. SSA changed its policy to require independent verification of birth records for U.S.-born children age 1 and over but still only relies on visual inspection of birth documents of children under age 1. This lack of independent verification remains an area vulnerable to fraud. In fact, by posing as parents of newborns, GAO investigators obtained two SSNs using counterfeit documents. SSA's policy for replacing Social Security cards, which allows individuals to obtain up to 52 replacement cards per year, and its documentation requirements for U.S. citizens to obtain such cards also increase the potential for misuse of SSNs. Of the 18 million cards issued by SSA in 2002, 12.4 million, or 69 percent, were replacements. While SSA requires noncitizens applying for replacement cards to provide the same identity and immigration information as if they were applying for a new SSN, its evidence requirements for citizens are much less stringent. The ability to obtain many replacement cards with relatively weak documentation may allow individuals to impersonate others by using counterfeit documents to obtain SSNs for a range of illicit uses, including selling them to noncitizens.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: The Social Security Administration (SSA) has implemented the requirement of the Intelligence Reform and Terrorism Prevention Act of 2004, which states that SSA independently verify any birth records submitted by an individual to establish eligibility for a Social Security account number, other than for purposes of enumeration at birth. SSA now verifies birth records of all individuals seeking an original or replacement Social Security card.

    Recommendation: To strengthen the integrity of SSA's policies and procedures for enumerating noncitizens, the Commissioner of Social Security should 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.

    Agency Affected: Social Security Administration

  2. Status: Closed - Implemented

    Comments: SSA reported that as of March 2005, a report was issued to the Deputy Commissioner for Operation that assessed the feasibility of expanding enumeration centers to other parts of the country. SSA reported that, based on data from the report, the agency opened an additional enumeration center in Las Vegas, Nevada and will open more as resources permit.

    Recommendation: To strengthen the integrity of SSA's policies and procedures for enumerating noncitizens, the Commissioner of Social Security should evaluate the Brooklyn Social Security Card Center 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.

    Agency Affected: Social Security Administration

  3. Status: Closed - Implemented

    Comments: SSA conducted a study to assess the accuracy of the Enumeration at Entry (EAE) process and identified several changes that were needed. The SSA Inspector General also issued a report on the EAE process. The first of these reports noted higher error rates in the EAE program compared to the regular enumeration process and both studies made recommendations for improving the EAE process. For example, both studies found that the EAE process is more prone to multiple SSN issuances than the regular enumeration process. Recommendations were made to SSA, Homeland Security and the Department of State. SSA and State officials agreed to explore expansion of EAE to three additional nonimmigrant groups.

    Recommendation: To strengthen the integrity of SSA's policies and procedures for enumerating noncitizens, the Commissioner of Social Security should 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 collection and changes to automated systems that will be needed by all three participating agencies.

    Agency Affected: Social Security Administration

  4. Status: Closed - Implemented

    Comments: In response to our report, SSA agreed to modify the Modernized Enumeration System (MES), and would consider such modifications as part of its Long Term Enumeration Fraud initiative. In the nearer term, it would make programming changes to MES in 2005, which would interrupt the card production process whenever the system detected problems: at that point, a card would not be produced until an investigation was concluded. On March 1, 2005, SSA mandated Field Office use of the SS-5 Assistant for most SSN applications. The SS-5 Assistant works with SSA's Modernized Enumeration System (MES) and, in effect, implements SSA's policies and verification procedures for enumerating noncitizens. The SS-5 Assistant helps the interviewer in properly documenting the interview and evidence in accordance with policy through more structured screens and questions. As part of the application process, the SS-5 Assistant will also automatically query the Systematic Alien Verification for Entitlements (SAVE) system used to verify immigration documents and status. As of April 2007, 98 percent of SSN transactions were processed using the SS-5 Assistant. SSA is also currently developing the Social Security Number Application Process (SSNAP), an automated SSN assignment system that will replace and incorporate the same functionality as the SS-5 Assistant and MES. Phase one of SSNAP is expected to be implemented some time at the end of fiscal year 2009.

    Recommendation: To strengthen the integrity of SSA's policies and procedures for enumerating noncitizens, the Commissioner of Social Security should enhance the Modernized Enumeration System to prevent staff from issuing SSNs without following required verification procedures.

    Agency Affected: Social Security Administration

  5. Status: Closed - Implemented

    Comments: The Social Security Administration (SSA) took several actions to perform systematic reviews of field office compliance with verification requirements. SSA (1) issued an Emergency Message to all field staff that explained the new verification policy; (2) conducted broadcast interactive video training on enumeration policies; (3) expanded a program the SSA New York region developed for processing SSN applications nationwide, which improved service delivery and helped field offices control workloads; and (4) improved the automated management information system so that employee compliance could be monitored and potential weaknesses could be identified. The agency also made field office compliance with verification requirements a part of an on-going quality review of enumeration activities, as well as the agency's Comprehensive Integrity Review Process to make improvements when problems are identified.

    Recommendation: To strengthen the integrity of SSA's policies and procedures for enumerating noncitizens, the Commissioner of Social Security should 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.

    Agency Affected: Social Security Administration

  6. Status: Closed - Implemented

    Comments: The The Social Security Administration (SSA) has implemented the requirement of the Intelligence Reform and Terrorism Prevention Act of 2004, which limits the number of replacement Social Security cards issued to an individual to 3 per year and 10 for the life of the individual.

    Recommendation: To strengthen the integrity of SSA's policies and procedures for enumerating noncitizens, the Commissioner of Social Security should reassess SSA's policies for issuing replacement Social Security cards and develop options for deterring abuse in this area.

    Agency Affected: Social Security Administration

 

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