Social Security Administration
Improved Agency Coordination Needed for Social Security Card Enhancement Efforts Gao ID: GAO-06-303 March 29, 2006The Social Security Administration (SSA) has issued more than 430 million Social Security numbers (SSN) and cards since the Social Security program began in 1935, of which an estimated 300 million belong to living number holders. SSNs have a key role in verifying individuals' authorization to work in the United States, but SSN cards are also vulnerable to theft and counterfeiting. The Intelligence Reform and Terrorism Prevention Act of 2004 requires that SSA consult with the Department of Homeland Security (DHS), form a task force, establish standards for safeguarding the SSN and card, and provide for implementation by June 2006. Concerns about unauthorized workers and the use of counterfeit documents led the Chairman of the House Judiciary Committee to ask that GAO (1) review SSA's progress to safeguard the SSN and enhance the card as required under the Intelligence Act, (2) identify key issues to be considered before enhancing the card, and (3) outline the range of options available to SSA for enhancing the card.
SSA has implemented several provisions of the Intelligence Act intended to help safeguard the SSN and card, but slow action to form the interagency task force may limit card enhancement efforts. SSA has implemented measures to limit the number of replacement cards, verify birth certificates for applicants under age 1, and improve the Enumeration at Birth process. SSA has taken action to include death indicators and initiated work on fraud indicators for Social Security accounts in its database. SSA set specific tasks and timelines to address card enhancement options and made a preliminary decision to improve the current paper card and issue the improved cards only to new card applicants. Although the card plays a significant role in verifying individuals' authorization to work, SSA did not consult DHS about these initial tasks or the formation of the interagency task force until November 2005 and did not convene the task force until late January 2006. This allows less than 6 months for the task force to consider critical issues that affect card enhancements before establishing new safeguards. The difficulty of counterfeit-proofing the card, the role the card has in determining employment eligibility, and ongoing enhancements to state drivers' licenses and identification cards are critical issues to consider before enhancing the Social Security card. Counterfeit protections were first added in 1983 but older versions of the card remain valid. Millions of older cards never established employment eligibility because SSA did not require that everyone present evidence of age, identity, or citizenship status until 1978. Prior GAO work shows that the employment verification process is jeopardized by document and identity fraud, the wide array of documents that can be used, weak worksite enforcement, and flaws in the voluntary electronic verification system. DHS is currently considering reducing the number of acceptable documents used to verify employment eligibility. Changes to drivers' licenses and identification cards under the Real ID Act will improve verification of identity in the employment process, since states must verify the SSN and legal presence upon application. However, states are not required to check or note employment eligibility. Once these critical issues are considered, a variety of options exist for enhancing the Social Security card, ranging from enhancing the paper card, to adding machine-readable or biometric features such as photographs and fingerprints, to eliminating the card entirely. Additionally, the costs of implementing each option will vary. Each option provides different alternatives for improving the ability to verify employment eligibility. The type of card and distribution method chosen will have a significant effect on costs and the agency's workload. For example, if cards require a fingerprint or photograph, additional infrastructure will be required to obtain these features; reissuing new cards to the estimated 300 million living cardholders or staggering issuance to certain groups, such as those who change jobs, would require a different investment of resources. However, decisions about the card's role will be crucial in determining costs.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-06-303, Social Security Administration: Improved Agency Coordination Needed for Social Security Card Enhancement Efforts
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Report to the Chairman, Committee on the Judiciary, House of
Representatives:
United States Government Accountability Office:
GAO:
March 2006:
Social Security Administration:
Improved Agency Coordination Needed for Social Security Card
Enhancement Efforts:
GAO-06-303:
GAO Highlights:
Highlights of GAO-06-303, a report to the Chairman, Committee on the
Judiciary, House of Representatives:
Why GAO Did This Study:
The Social Security Administration (SSA) has issued more than 430
million Social Security numbers (SSN) and cards since the Social
Security program began in 1935, of which an estimated 300 million
belong to living number holders. SSNs have a key role in verifying
individuals‘ authorization to work in the United States, but SSN cards
are also vulnerable to theft and counterfeiting. The Intelligence
Reform and Terrorism Prevention Act of 2004 requires that SSA consult
with the Department of Homeland Security (DHS), form a task force,
establish standards for safeguarding the SSN and card, and provide for
implementation by June 2006. Concerns about unauthorized workers and
the use of counterfeit documents led the Chairman of the House
Judiciary Committee to ask that GAO (1) review SSA‘s progress to
safeguard the SSN and enhance the card as required under the
Intelligence Act, (2) identify key issues to be considered before
enhancing the card, and (3) outline the range of options available to
SSA for enhancing the card.
What GAO Found:
SSA has implemented several provisions of the Intelligence Act intended
to help safeguard the SSN and card, but slow action to form the
interagency task force may limit card enhancement efforts. SSA has
implemented measures to limit the number of replacement cards, verify
birth certificates for applicants under age 1, and improve the
Enumeration at Birth process. SSA has taken action to include death
indicators and initiated work on fraud indicators for Social Security
accounts in its database. SSA set specific tasks and timelines to
address card enhancement options and made a preliminary decision to
improve the current paper card and issue the improved cards only to new
card applicants. Although the card plays a significant role in
verifying individuals‘ authorization to work, SSA did not consult DHS
about these initial tasks or the formation of the interagency task
force until November 2005 and did not convene the task force until late
January 2006. This allows less than 6 months for the task force to
consider critical issues that affect card enhancements before
establishing new safeguards.
The difficulty of counterfeit-proofing the card, the role the card has
in determining employment eligibility, and ongoing enhancements to
state drivers‘ licenses and identification cards are critical issues to
consider before enhancing the Social Security card. Counterfeit
protections were first added in 1983 but older versions of the card
remain valid. Millions of older cards never established employment
eligibility because SSA did not require that everyone present evidence
of age, identity, or citizenship status until 1978. Prior GAO work
shows that the employment verification process is jeopardized by
document and identity fraud, the wide array of documents that can be
used, weak worksite enforcement, and flaws in the voluntary electronic
verification system. DHS is currently considering reducing the number
of acceptable documents used to verify employment eligibility. Changes
to drivers‘ licenses and identification cards under the Real ID Act
will improve verification of identity in the employment process, since
states must verify the SSN and legal presence upon application.
However, states are not required to check or note employment
eligibility.
Once these critical issues are considered, a variety of options exist
for enhancing the Social Security card, ranging from enhancing the
paper card, to adding machine-readable or biometric features such as
photographs and fingerprints, to eliminating the card entirely.
Additionally, the costs of implementing each option will vary. Each
option provides different alternatives for improving the ability to
verify employment eligibility. The type of card and distribution method
chosen will have a significant effect on costs and the agency‘s
workload. For example, if cards require a fingerprint or photograph,
additional infrastructure will be required to obtain these features;
reissuing new cards to the estimated 300 million living cardholders or
staggering issuance to certain groups, such as those who change jobs,
would require a different investment of resources. However, decisions
about the card‘s role will be crucial in determining costs.
What GAO Recommends:
As the SSA-led task force works to protect the Social Security card,
GAO recommends that DHS and SSA work together to resolve the card‘s
weaknesses in proving employment eligibility. DHS agreed but SSA agreed
in part, stating that aspects of the recommendation are beyond the
Intelligence Act scope.
www.gao.gov/cgi-bin/getrpt?GAO-06-303.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Barbara D. Bovbjerg at
(202) 512-7215 or bovbjergb@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
SSA Has Made Progress on Intelligence Act Provisions, but Slow Action
to Form the Interagency Task Force May Limit Card Enhancement Efforts:
The Difficulty of Counterfeit-proofing the Card, the Role the Card Has
in the Employment Verification Process, and Improvements to Drivers'
Licenses Are Critical Issues to Consider:
A Range of Enhancement Options Exists, and Costs Would Vary:
Conclusions:
Recommendation for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Department of Homeland Security Form I-9:
Appendix III: Comments from the Department of Homeland Security:
Appendix IV: Comments from the Social Security Administration:
Appendix V: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Original SSNs and Replacement Social Security Cards Issued in
Fiscal Year 2005:
Table 2: Social Security Administration Timeline for Implementing
Social Security Card Enhancements:
Table 3: Examples of Fraudulent Social Security Card Activity:
Table 4: Acceptable Documents in the Employment Verification Process:
Table 5: Requirements for State-Issued Drivers' Licenses or ID Cards
under the Real ID Act of 2005:
Table 6: Factors that Affect Costs of Enhanced Card Options:
Table 7: Card Issuance Options:
Figures:
Figure 1: Interagency Task Force Required by the Intelligence Act,
November 2005:
Figure 2: Examples of Possible Social Security Card with Reverse
Showing Magnetic Stripe and Secure Bar Code:
Figure 3: Examples of Biometrics--Fingerprint, Facial Recognition, and
Photograph:
Abbreviations:
DHS: Department of Homeland Security:
OIG: Office of the Inspector General:
SSA: Social Security Administration:
SSN: Social Security number:
United States Government Accountability Office:
Washington, DC 20548:
March 29, 2006:
The Honorable F. James Sensenbrenner, Jr.:
Chairman:
Committee on the Judiciary:
House of Representatives:
Dear Mr. Chairman:
The Social Security Administration (SSA) has issued more than 430
million Social Security numbers (SSN) and cards since the Social
Security program began in 1935. SSA uses the number to track workers'
earnings and eligibility for Social Security benefits, while the card
serves as an individual's record of the number. Over the years, the SSN
is increasingly used as a unique personal identifier by government
agencies and businesses to maintain records and by individuals to file
tax returns, open bank accounts, apply for credit, and conduct consumer
transactions. Since passage of the Immigration Reform and Control Act
of 1986, Social Security cards, drivers' licenses, birth certificates,
and other documents are also used to verify individuals' eligibility to
work in the United States as well as apply for government benefits.
However, these documents can and have been altered, counterfeited, or
stolen to gain access to legitimate documents, create false identities,
obtain employment, or commit financial crimes. The National Commission
on Terrorist Attacks upon the United States (the 9/11 Commission)
reported that all but one of the hijackers had acquired U.S.
identification documents, some by fraud. The 9/11 Commission
recommended that the federal government strengthen the issuance
standards for birth certificates and drivers' licenses, and subsequent
legislation also included Social Security cards.
The Intelligence Reform and Terrorism Prevention Act of 2004 requires
that SSA consult with the Department of Homeland Security (DHS) and
form an interagency task force to establish standards to better protect
the SSN and card from counterfeiting, tampering, alteration, and theft,
and provide for the implementation of security requirements including
standards for safeguarding Social Security cards from counterfeiting
and theft by June 2006. Although SSA is responsible for issuing the
card, DHS monitors employers who are responsible for certifying the
authenticity of documents, such as the card, when presented as proof of
eligibility to work. Congressional concerns about identification
documents and questions about unauthorized workers prompted your
request for us to review SSA's efforts under the Intelligence
Act.[Footnote 1] In response to the request, we (1) reviewed the
progress of SSA's efforts to safeguard the SSN and enhance the card as
required under the act, (2) identified key issues to be considered
before enhancing the card, and (3) outlined the range of options
available to SSA for enhancing the card.
In conducting our review, we met with officials from the Social
Security Administration and the Department of Homeland Security. We
also met with officials from the Government Printing Office who
administer the contract for printing Social Security cards. We
documented key issues SSA should consider as it proceeds with changing
the Social Security card by interviewing officials from SSA, DHS, the
American Association of Motor Vehicle Administrators, and state motor
vehicle administrators in Illinois, West Virginia, and Wyoming. We
selected these three states because they used various security features
in their drivers' licensing or identification processes such as
fingerprinting, advanced optical printing and inks, or holograms and
other features, which already met stated or anticipated federal
legislative requirements for improving drivers' licenses and
identification cards. We reviewed identification initiatives using
biometrics at the United States Visitor and Immigrant Status Indicator
Technology program and the Transportation Security Administration's
Registered Traveler program.[Footnote 2] Finally, we met with employer
association groups identified by the U.S. Chamber of Commerce. To
examine the range of options available to SSA for enhancing the card,
we researched and analyzed technical literature; identified card
technologies; interviewed biometrics technology experts, vendors, and
industry associations; and consulted the National Institute of
Standards and Technology. We also met with Banknote Corporation of
America, the contractor that prints Social Security cards, to discuss
advances in security printing techniques. We performed our work between
April 2005 and January 2006 in accordance with generally accepted
government auditing standards. Appendix I discusses our scope and
methodology in greater detail.
Results in Brief:
The Social Security Administration has implemented several Intelligence
Act provisions intended to help safeguard the SSN and the card, and
made a preliminary decision to add improved security features to the
card before convening the interagency task force that was required to
develop safeguards for the card. SSA has implemented measures to limit
the number of replacement cards, verify birth certificates for
applicants under age 1, and improve the application process of the
Enumeration at Birth Program.[Footnote 3] SSA has also taken action to
include death indicators and initiated action to include fraud
indicators in its database. Additionally, SSA set eight specific tasks
and timelines to develop safeguards for enhancing the card before
reaching the statutory implementation date of June 17, 2006. Three
tasks were expected to be completed before convening the interagency
task force and thereby involving DHS--researching the range of
available security features, coming to an internal agreement on new
security features for the paper card, and developing a publicity
campaign for the new card. SSA officials told us that a preliminary
decision had been made to develop an improved version of the current
paper card and issue the improved cards only to new card applicants.
Although the card plays a significant role in verifying individuals'
authorization to work, SSA did not consult with DHS as it worked for
nearly a year on these three tasks. Further, SSA did not convene the
task force until late January 2006, allowing the task force less than 6
months to consider critical issues that affect card enhancement options
before new safeguards are to be established in June 2006. SSA is
required to provide for the implementation of security requirements by
the same date. These officials told us that the agency is unlikely to
take action beyond enhancing features of the paper card without
specific legislative direction to do so.
The difficulty of counterfeit-proofing the card, the role the card has
in determining employment eligibility, and ongoing enhancements to
state drivers' licenses and identification cards are critical issues to
consider before enhancing the Social Security card. Counterfeit
protections were first put on the card in 1983, but older versions of
the card remain in circulation, and all cards, including those issued
before counterfeit protections were put in place, are still valid. Use
of these older versions of the card would adversely affect the intended
benefits of a newly enhanced card. Additionally, when SSA began issuing
Social Security cards in 1936, individuals applying for a card were not
required to provide information useful for determining employment
eligibility, such as evidence of age, identity, or citizenship status-
-not until 1978 were all persons required to provide this information.
Since older cards never established employment eligibility, employers
cannot be certain if individuals with older Social Security cards are
eligible to work. However, the Social Security card is a key document
for verifying an individual's authorization to work. Prior GAO work
shows that the employment verification process is jeopardized by
document and identity fraud, the wide array of documents that
applicants can present, weak worksite enforcement, and flaws in the
voluntary electronic verification system.[Footnote 4] To improve the
employment verification process, DHS is currently considering reducing
the number of acceptable documents permitted to verify employment
eligibility. Further, recent legislation will require states to verify
the Social Security numbers and legal presence of individuals applying
for state drivers' licenses and identification cards---linking the
estimated 250 million licenses and identification cards to the Social
Security number and immigration documents. These improved licenses and
identification cards could improve the employment verification process.
However, they are not meant to prove employment eligibility, since
states are not required to determine and note worker status when
verifying the Social Security number with SSA and immigration documents
with DHS.
Once these critical issues are considered, a variety of options exist
for enhancing the card, ranging from enhancing the paper card to adding
machine-readable or biometric features such as photographs and
fingerprints, to eliminating the card entirely. Additionally, the costs
of implementing each option will vary. First, the paper card could be
made more counterfeit-resistant with features such as the use of paper
with a fiber content that reacts to certain chemicals or security
threads similar to those used in U.S. paper currency. Second, the card
could be plastic and include some machine-readable features such as a
magnetic strip or secure bar code; employers would use automated
equipment to determine an individual's employment eligibility status.
Third, the card could include some form of biometrics that links the
card to the cardholder, such as a fingerprint or a photograph. Finally,
SSA could eliminate the card and instead issue a letter with an
individual's Social Security number; in the absence of the card,
employers could use a system such as Basic Pilot, or some similar
system, to verify employment eligibility through SSA and DHS using the
Social Security number or Alien number provided by the worker in
combination with an identification document such as a driver's license.
Each option provides different alternatives for improving the ability
to verify employment eligibility. Choosing the type of card and the
method for issuing new cards will have a significant effect on costs
and the agency's workload. For example, if cards are machine-readable
or require a fingerprint or photograph, additional infrastructure will
be needed to obtain and read these features. Reissuing new cards to all
300 million current cardholders could improve the cards' counterfeit
resistance and strengthen the card as a worker authorization document,
but would be costly. Staggering issuance of an enhanced card to certain
groups, such as those who change jobs, would require a lower initial
investment of resources. Decisions about the card's role for SSA as
well as in employment eligibility authorization will be crucial to
determining the most cost-effective strategy for enhancing the card.
As the SSA-led task force develops ways to protect the Social Security
card, we are making a recommendation to the Secretary of Homeland
Security and the Commissioner of Social Security to work together to
resolve the weaknesses of the Social Security card in proving
employment eligibility.
In response to our draft report, DHS agreed that much could be done on
an interagency basis to improve the integrity of Social Security cards
and numbers as required under the Intelligence Act. DHS stated that
determining what to do to make the card more secure or eliminating the
card altogether appears to be appropriate, and DHS will continue to
work with SSA through the interagency task force. SSA said that it
agreed in part with our recommendation; although SSA stated that some
aspects of the recommendation were outside the scope of what Congress
provided in the Intelligence Act, SSA said it would continue to work
with DHS on issues related to employment eligibility and verification.
SSA also expressed concern that current law requires that the Social
Security card be made of banknote paper, and thus limits the task
force's consideration of improvements. SSA also suggests that
requirements under the Real ID Act could be modified so that drivers'
licenses could be made to reflect work authorization. DHS and SSA's
comments are reproduced in appendixes III and IV.
Background:
The Social Security Act of 1935 authorized a record-keeping system to
help manage the Social Security program and resulted in the creation of
the SSN. SSNs are now issued to most U.S. citizens at birth. They are
also available to noncitizens lawfully admitted to the United States
with permission to work. Lawfully admitted noncitizens may also qualify
for an SSN for nonwork purposes when a federal, state, or local law
requires that they have an SSN to obtain a particular public benefit or
service. SSA is responsible for paying retirement, survivors', and
disability benefits to eligible insured persons based on their lifetime
earnings in covered employment. SSA maintains a historical record of
each worker's annual earnings, which are identified by the worker's
name and SSN.
Social Security Cards and Noncitizen Employment Eligibility:
Since the Social Security program began, SSA has issued over 430
million Social Security numbers and cards, of which an estimated 300
million represent living number holders.[Footnote 5] As shown in table
1, in fiscal year 2005, SSA issued a total of 17.5 million SSN cards to
U.S. citizens and to noncitizens, of which about 12.1 million were
replacement cards. SSA issues replacement cards when individuals' cards
are lost, stolen, or require corrections to the original card. In
fiscal year 2005, SSA issued about 4.3 million original SSNs to U.S.
citizens, of which 3.9 million SSNs were issued to newborns through the
voluntary Enumeration at Birth Program. Under this program, parents can
request SSNs and cards for newborns at hospitals and other facilities
at birth. The Enumeration at Birth Program eases SSA's work demands in
its approximately 1,300 field offices because parents using the
Enumeration at Birth Program generally do not need to visit SSA field
offices.
Table 1: Original SSNs and Replacement Social Security Cards Issued in
Fiscal Year 2005:
Numbers in millions.
Original SSNs and cards issued;
U.S. citizens: 4.28;
Noncitizens: 1.12;
Overall Total: 5.40.
Replacement Social Security cards;
U.S. citizens: 11.27;
Noncitizens: 0.81;
Overall Total: 12.08.
Total;
U.S. citizens: 15.55[A];
Noncitizens: 1.94[A];
Overall Total: 17.48[A].
Source: SSA.
[A] Totals by category may not equal overall total because of rounding.
[End of table]
The card has also become a document used in controlling unauthorized
work. In 1986, Congress enacted the Immigration Reform and Control Act
to help reduce the attraction of employment to illegal aliens coming to
this country.[Footnote 6] The act made it illegal for individuals and
entities to knowingly hire, continue to employ, or recruit unauthorized
workers. The act required employers to review documents that
established newly hired workers' identity and eligibility to work in
the United States and to sign statements certifying that the documents
they review, such as a Social Security card, appear genuine and refer
to the prospective worker. DHS has responsibility for implementing and
enforcing the act and has authorized a combination of 27 documents that
employees can choose from and provide to prove identity and eligibility
to work. See appendix II for DHS's Form I-9, which contains a list of
the documents used to verify employment eligibility.
Efforts to Enhance the Card and Drivers' Licenses:
As uses for the SSN have grown, misuses of the number and
counterfeiting of the card have increased. Since the SSN's creation,
SSA has used the same basic wallet-sized card but included additional
information on the card to meet the evolving role of the SSN. At
present, there are 50 valid versions of the card--many of which have
little or no counterfeit protection. On several occasions, Congress
considered directing SSA to issue cards that were more resistant to
tampering and counterfeiting. In 1983, the Social Security Act was
amended to require that the card be made of banknote paper and to the
maximum extent practicable be a card that cannot be counterfeited.
Later that year, SSA introduced a card with security features including
tinted patterns that show when information is erased, small
multicolored discs randomly placed on the paper, and special raised
ink. Some members of Congress subsequently expressed disappointment
that these security features did not make the card significantly more
difficult to counterfeit and that employers could not easily determine
the card's authenticity for employment authorization purposes. In 1996,
Congress asked SSA to study and report on different methods for
improving the Social Security card and develop a prototype of a
counterfeit-resistant Social Security card. In the report, SSA provided
several options for enhancing the card, along with estimated costs, but
did not recommend options for implementation. In 1998, we reviewed
SSA's estimates and agreed that a mass issuance of a more secure card
would cost billions of dollars but concluded that alternative
approaches to issuing new cards may provide a more cost-effective
approach to verifying individuals' authorization to work.
Since the terrorist attacks of September 11, 2001, Congress has focused
attention on verifying identity and protecting American forms of
identification. In December 2004, Congress enacted the Intelligence
Act, which required improvements to birth certificates, drivers'
licenses, and Social Security cards. Under the act, minimum standards
for birth certificates are to be established, such as certifications by
state or local governments that they issued the document, the use of
safety paper or an alternative, the use of a seal representing the
issuing government entity and other features designed to prevent fraud.
For the Social Security card, the act required improvements to the
process for issuing the card and required that the Social Security
Commissioner consult with the Secretary of Homeland Security to form a
task force for the purpose of safeguarding Social Security cards and
numbers. Within an 18-month time frame following the December 2004
enactment of the act, the task force is to establish:
* standards for safeguarding Social Security cards from counterfeiting,
tampering, alteration, and theft;
* requirements for verifying documents submitted for the issuance of
replacement cards; and:
* actions to increase enforcement against the fraudulent use or
issuance of Social Security numbers and cards.
The SSA Commissioner is to provide for the implementation of such
security requirements by June 2006.
In 2005, Congress enacted the Real ID Act, which, among other things
amended the security requirements of the Intelligence Act for state
drivers' licenses.[Footnote 7] Under the Real ID Act, the Secretary of
Homeland Security must determine whether states meet certain minimum
security requirements for drivers' licenses and personal identification
cards. The law provides that, in order to be federally recognized, the
state-issued card must have certain physical security features designed
to prevent tampering, counterfeiting, or duplication, including a
digital picture and machine-readable technology. The Real ID Act also
requires individuals to provide evidence of their legal status to
obtain a driver's license and provide proof of their Social Security
numbers so that states can verify the information with SSA.
Additionally, the law requires that states verify individuals'
immigration status with DHS. Ultimately, Real ID prohibits federal
agencies from accepting state-issued drivers' licenses or
identification cards as identity documents unless they are determined
to meet certain minimum security requirements.
SSA Has Made Progress on Intelligence Act Provisions, but Slow Action
to Form the Interagency Task Force May Limit Card Enhancement Efforts:
SSA has made progress implementing the Intelligence Act requirements
enacted in December 2004. The agency implemented provisions for
obtaining replacement cards, verifying birth certificates of applicants
under age 1, and improving the application process of the Enumeration
at Birth Program. In addition, SSA has taken actions to include death
indicators and initiated action to include fraud indicators on Social
Security records. In the effort to safeguard the Social Security card
and number, SSA did not contact DHS until November 2005 to form an
interagency task force, and the task force did not meet until late
January 2006. This allows the task force less than 6 months to consider
critical issues that affect card enhancement options before the
establishment of security standards in June 2006. In addition, SSA is
required to provide for the implementation of standards for
safeguarding the card and number from counterfeiting, tampering,
alteration, and theft by the same date. Before convening the task
force, SSA made a preliminary decision to improve the current paper
card.
Replacement Cards Limited:
The Intelligence Act requires that, generally, SSA limit the number of
replacement cards it issues to individuals to 3 annually and 10 over a
lifetime, and the act increased requirements for verifying the
authenticity of documents presented before issuing replacement cards.
SSA's policy prior to the Intelligence Act allowed individuals to
obtain as many as 52 replacement cards annually, generally, requiring
only proof of identity for U.S. citizens to receive the cards. GAO
previously reported on the potential for fraud with SSA's replacement
card policy. Our investigators were able to obtain 8 replacement cards
in less than 6 weeks before SSA placed a fraud alert on the SSN
accounts.[Footnote 8] In response to the act, SSA reported that the
agency had:
* modified its computer system to enable monitoring the number of cards
issued to individuals;
* published interim final regulations on replacement cards in the
Federal Register on December 16, 2005;
* issued operating instructions for SSA employees to use in processing
claims and conducting the daily business of the agency; and:
* provided training to staff on SSA's new policy on replacement cards.
Minimum Standards for Verifying Documents Established:
The Intelligence Act requires that SSA establish minimum standards for
verifying documents or records that individuals present when applying
for original and replacement Social Security cards other than through
the Enumeration at Birth process. SSA reported that it had:
* published operating instructions that describe the minimum standards
for verifying all documents submitted for enumeration;
* created a new fact sheet for applicants explaining the Intelligence
Act provisions and revised public information, such as brochures and
pamphlets; and:
* provided training to SSA personnel on the minimum standards for
verifying all documents.
Birth Certificates for Card Applicants under Age 1 Independently
Verified:
The act required that SSA independently verify birth certificates that
individuals submit to establish eligibility for a Social Security
number. Prior to the act, SSA required verification of birth
certificates for individuals over age 1, but required only a visual
inspection of birth certificates for children under age 1 who were
assigned SSNs outside the Enumeration at Birth process. Both GAO and
SSA's Office of the Inspector General (OIG) identified the potential
for fraud with the verification of birth certificates because SSA
personnel could not detect counterfeit birth certificates by visual
inspection, and because no verification of documents with the issuers
was required for replacement Social Security cards. GAO investigators
posing as parents of children under age 1 used counterfeit birth
certificates to get two SSNs for fictitious children. In one instance,
the investigators supplied the counterfeit documents in person; in the
other, they mailed the counterfeit documents. In both cases SSA staff
verified the counterfeit documents as valid and SSA issued the SSNs and
cards. SSA reported that upon enactment of the Intelligence Act, the
agency changed its policy for verifying birth certificates for
individuals under age 1. Specifically, SSA:
* issued Program Operations Manual System requirements for
independently verifying birth certificates, and:
* provided training to SSA personnel on specific requirements for
verifying birth certificates.
Progress Made on Enumeration at Birth Process:
The Intelligence Act requires that SSA undertake to improve the
application process for assigning Social Security numbers to newborns.
The act requires that SSA improve the:
* assignment of Social Security numbers to unnamed children,
* issuance of SSNs to prevent assigning more than one Social Security
account to the same child, and:
* system to prevent other opportunities for fraudulently obtaining a
Social Security account number.
Prior GAO work showed that SSA did not have sufficient internal
controls in place to minimize fraudulent activities that could affect
the Enumeration at Birth data that SSA uses to issue SSNs and cards.
Additionally, the SSA OIG reported various vulnerabilities in the
Enumeration at Birth Program and suggested that SSA provide more
systematic oversight and management. As of our review, SSA reported
that the agency has made systems changes to improve the Enumeration at
Birth Program. For example, a more detailed check of the child's name
will be made to prevent assigning SSNs to "Baby Boy" or "Baby Girl," or
to issue two different SSNs to the same child by honoring the parents'
request at the hospital but then honoring a second request a short time
later through a field office with a claim of nonreceipt of the SSN
through the hospital or an urgent need for the SSN. SSA submitted a
report to Congress detailing these improvements in December 2005.
The act also required that SSA conduct a study to determine the options
for ensuring the integrity of the Enumeration at Birth Program.
Specifically, the report must include an examination of available
methods to reconcile hospital birth records with birth registrations
submitted to state agencies that submit data to SSA as part of the
Enumeration at Birth process.
SSA reported that it asked the Inspector General to conduct the
required study, and the Inspector General plans to deliver the study to
Congress by June 2006.
Work on Death Indicators Taken and Fraud Indicators Initiated:
The Intelligence Act requires that SSA add death and fraud indicators
to the systems for verifying Social Security numbers so employers and
state agencies issuing drivers' licenses and identification cards can
receive accurate information when verifying the SSN. Death and fraud
indicators are "flags," or "alerts," that SSA would place on SSN
accounts to warn inquirers that certain SSN accounts belong to a
deceased person or were used for fraudulent purposes. SSA is required
to add death indicators by June 17, 2006, and fraud indicators by
December 17, 2007. SSA reported that the agency currently maintains
death information in its records and has added state death information
to its verifications as of March 6, 2006. SSA reported that it has
begun to discuss what steps are needed but has not yet drafted guidance
for handling fraud indicators.
SSA Has Moved Slowly to Convene the Interagency Task Force for
Safeguarding the Card:
The Intelligence Act requires that SSA consult with DHS and form an
interagency task force to safeguard Social Security cards and numbers.
Under the act, the task force has 18 months to establish standards for
preventing counterfeiting, tampering, alteration, and theft. During the
first 12 months since enactment, SSA has conducted research on
enhancement options, come to a preliminary internal agreement on the
features a newly enhanced card might have, and discussed what type of
publicity campaign is needed to promote an enhanced paper Social
Security card. However, SSA did not consult with DHS about the
formulation of an interagency task force until November 2005, and the
task force did not meet until late January 2006, allowing the task
force less than 6 months before security standards are to be
established in June 2006. SSA is required to provide for implementation
of the new safeguards by the same date. Prior to consulting with DHS on
forming the interagency task force, SSA made a preliminary decision to
enhance security features for the paper card. According to SSA, the
agency wanted to have an approach to present to the task force once it
convened. Table 2 shows the timeline SSA has set for implementing tasks
related to card enhancement.
Table 2: Social Security Administration Timeline for Implementing
Social Security Card Enhancements:
Intelligence Reform and Terrorism Prevention Act passed: 12/17/04:
Task name: SSA internal agreement on new security features for SSN
cards;
Start: 8/18/05;
Finish: 12/16/05.
Task name: Develop publicity campaign[B];
Start: 8/18/05;
Finish: 12/16/05.
Task name: Interagency task force agreement on new security features;
Start: 12/19/05;
Finish: 3/17/06.
Task name: Prepare new contract for SSN card;
Start: 3/20/06;
Finish: 6/16/06.
Task name: Provide SSA systems support for changes;
Start: 3/20/06;
Finish: 6/16/06.
Task name: Finalize SSA publicity campaign;
Start: 3/20/06;
Finish: 6/16/06.
Task name: Report to Congress;
Start: 6/17/06;
Finish: 6/17/06.
Source: SSA.
[A] Research and benchmarking were not completed as of February 3, 2006
to allow for coordination with the Document Security Alliance regarding
card enhancement options.
[B] The publicity campaign has been discussed but is not yet complete.
SSA noted that these timelines are internal guidelines with room built
in to allow for slippage, but the agency fully expects to meet the
legislated completion date of June 17, 2006.
[End of table]
SSA officials told us that they expect the interagency task force to
include representation from DHS and several other agencies. According
to SSA, the task force's first meeting in January 2006 addressed the
Intelligence Act requirement to establish standards for verifying
documents submitted to obtain replacement cards. SSA reported that the
task force will address other requirements of the Intelligence Act,
such as enhancements to the Social Security card in future meetings.
While the task force has broad latitude to address issues relative to
the Social Security card, information SSA and DHS provided at the time
of our review does not indicate that the task force will address the
role of the card in verifying employment eligibility. According to SSA,
final agreements on the new features to add to the card will be made
based partly on results from work being performed by the Document
Security Alliance, a group of experts on document security with
representatives from industry and government agencies. Figure 1 shows
the task force membership and structure as proposed by SSA.
Figure 1: Interagency Task Force Required by the Intelligence Act,
November 2005:
[See PDF for image]
[End of figure]
The Difficulty of Counterfeit-proofing the Card, the Role the Card Has
in the Employment Verification Process, and Improvements to Drivers'
Licenses Are Critical Issues to Consider:
The Social Security card is a critical federal government document that
is used in daily American life, and understanding what is needed to
protect the card is essential to enhancement efforts. Critical issues
to consider include the difficulty of developing and maintaining a
counterfeit-proof card, the role the card has in the employment
verification process, and new requirements of state drivers' licenses
and identification cards that provide links to the card and immigration
documents and could help improve the employment verification process.
A Counterfeit-proof Social Security Card Is Difficult to Develop and
Maintain:
In the past 30 years the Social Security number and card have become
critical to daily functions in the United States, such as filing tax
returns, opening bank accounts, applying for credit, conducting
consumer transactions, and obtaining employment. As uses for the number
and card have grown, demand for counterfeit cards has risen. In
testimony before Congress, SSA's Assistant Deputy Commissioner for
Disability and Income Security Programs (Program Policy) stated that
when the Social Security program began, no special efforts were needed
to prevent the Social Security card from being counterfeited, but as
the card's use expanded and technology improved, counterfeiting became
a concern. According to the Assistant Deputy Commissioner, SSA has
incorporated a number of security features to make the card counterfeit-
resistant since 1983, but the expertise of counterfeiters and the wide
availability of state-of-the-art technology make it increasingly
difficult to develop and maintain a document that cannot be
counterfeited.[Footnote 9] Table 3 describes four examples of
fraudulent Social Security card activity.
Table 3: Examples of Fraudulent Social Security Card Activity:
Document fraud: Law enforcement officials investigating an alleged case
of document fraud in the state of Maryland in December 2005 expressed
concern that technology has improved so much that it is difficult to
identify counterfeit documents. These officials arrested an individual
for allegedly selling a fake Social Security card and an immigration
document (resident alien card) for about $250 to a law enforcement
official posing as an undocumented immigrant. According to the law
enforcement report, two passport-sized photographs were provided so
that a resident alien card could be made, along with a Social Security
card, both of which were ready in 3 days.
Document fraud: In testimony before the House Committee on Ways and
Means in November 2005, the Deputy Inspector General for SSA stated
that investigators had apprehended an individual who used counterfeit
immigration documents to obtain over 600 valid Social Security numbers
to sell to undocumented immigrants at a price of $1,000 to $2,000. In
addition, this person had multiple Social Security cards and
photocopies of cards. Counterfeit Social Security cards and activities
have also involved U.S. citizens.
Identity and mail fraud: The SSA Inspector General reported in August
2005 that a university professor was indicted on 33 counts of mail
fraud for posing as a parent and using students' personal information
to obtain Social Security cards, credit cards, and birth
certificates.[A].
Identity and document fraud: The Deputy Inspector General testified
that in August 2005, one individual was sentenced to 18 months'
incarceration for submitting more than 200 applications for Social
Security numbers for fictitious children using fraudulent birth
certificates and other falsified documents. The individual used two
identities, one of which belonged to a person who had been dead for a
year.
[A] Office of the Inspector General, Social Security Administration,
Universities' Use of Social Security Numbers as Student Identifiers in
Region VI, A-06-05-15100 (August 2005).
[End of table]
Although the card is now used as documentation for government and
nongovernment functions, the card was never intended as a personal
identification document and does not establish the person presenting
the card as the person whose name and SSN appear on the card. According
to SSA, while the card has some counterfeit-resistant features, it does
not contain information that would allow the card to be used as proof
of identity. In its 1997 Report to Congress on Options for Enhancing
the Social Security Card, SSA reported that:
"The only way the Social Security card can, with certainty, assure that
the bearer of the card is the assigned number holder is if the number
holder's identifying information, picture, fingerprint, or biometric
identifier is on the card itself. Then, someone needing assurance the
card bearer is the assigned number holder could perform a visual
comparison with the number holder's picture or identifying information,
or an electronic comparison to a biometric identifier stored on the
Social Security card."
SSA reported that linking the number holder to the card would entail
collecting and maintaining biometric data, a step the agency reported
would be costly for the agency and complicated for the public. Although
the technology has advanced since the 1997 SSA report, the agency
maintains that the same principles of cost and complexity apply. The
ability to tie the card to the cardholder could assist SSA in reducing
the number of instances in which wages are not credited to the correct
Social Security account and assist DHS in its efforts to confirm the
immigration status of nonimmigrants.
The Card Is a Weak Link in the Employment Verification Process:
The Social Security card is commonly presented as a document to prove
authorization to work. As part of the employment verification process,
job applicants can choose from a list of 27 documents that employers
then use to verify identity and employment eligibility. Employers are
required to certify on DHS's Form I-9 that they have examined the
documents presented, and that the documents appear genuine and relate
to the person presenting them. As shown in table 4, documents from
three categories may be used to establish identity and employment
eligibility. See appendix II for Form I-9.
Table 4: Acceptable Documents in the Employment Verification Process:
List A: Documents that establish both identity and employment
eligibility: (only one document from this category needed):
(1) U.S. passport;
(2) Unexpired foreign passport;
(3) Permanent Resident card or Alien Registration Receipt card with
photograph;
(4) Unexpired Temporary Resident card;
(5) Unexpired Employment Authorization card;
(6) Unexpired reentry permit;
(7) Unexpired refugee travel document;
(8) Unexpired employment authorization document issued by DHS with a
picture;
List B: Documents that establish identity: (a document from this
category must be used with one from List C):
(1) Driver's license or ID card issued by a state or U.S. possession;
(2) ID card issued by federal, state, or local governments;
(3) School ID card with a photograph;
(4) Voter's registration card;
(5) U.S. military card or draft record;
(6) Military dependent's ID card;
(7) U.S. Coast Guard Merchant Mariner's card;
(8) Native American tribal document;
(9) Driver's license issued by a Canadian government authority;
(10) School record or report card;
(11) Clinic, doctor or hospital record;
(12) Day-care or nursery school record.
List C: Documents that establish employment eligibility: (a document
from this category must be used with one from List B):
(1) U.S. Social Security card issued by SSA;
(2) Certification of birth abroad issued by the State Department;
(3) Original or certified copy of a birth certificate issued by a
state, county, etc. bearing an official seal;
(4)Native American tribal document;
(5) U.S. citizen ID card;
(6) ID card for use of resident citizen in the United States;
(7) Unexpired employment authorization document issued by DHS.
Source: Department of Homeland Security.
[End of table]
While the employment verification process relies on a variety of
documents to establish identity, the role of the Social Security card
in proving authority to work has limitations. Millions of existing
cardholders have not proven their employment eligibility status to SSA,
because SSA did not begin requiring identification documents from all
persons until 1978. According to SSA, at the inception of the Social
Security program, all SSNs were assigned and cards issued based solely
on information provided by the applicant. In 1971, SSA began requiring
evidence of identity from individuals age 55 and over who were applying
for an original number and Social Security card. From the first
issuance of the Social Security number and card until evidence of
identity was first required, SSA issued over 194 million SSNs and
cards. SSA first required that noncitizens show evidence of age,
identity, and status in 1974, by which time SSA had issued another 26
million original SSNs and cards. In his testimony, the SSA Deputy
Commissioner stated that in 1974, the agency began to annotate its
records to show the issuance of SSNs to noncitizens for nonwork
purposes because the agency was concerned that individuals might use
SSNs assigned for purposes other than work to obtain unauthorized
employment. Beginning in 1978, SSA required all SSN applicants to
provide evidence of age, identity, and United States citizenship or
noncitizen status, by which time SSA had issued about 253 million
original SSNs and cards. In 1982 SSA began printing the legend, "NOT
VALID For Employment," on the cards of noncitizens not authorized to
work.
To reduce the instances of fraudulent activity associated with
documents used in the employment verification process, both SSA and
Homeland Security offer employers voluntary electronic verification of
information on the Social Security card and immigration documents.
However, in August 2005, GAO reported several weaknesses in the current
employment verification process.[Footnote 10] The wide array of
documents permitted leaves the employment verification process
vulnerable to fraud. Various studies show that document fraud (use of
counterfeit documents) and identity fraud (fraudulent use of valid
documents or information belonging to others) have made it difficult
for employers to accurately verify individuals' eligibility to work. In
its 1997 report to Congress, the U.S. Commission on Immigration Reform
noted that the widespread availability of false documents made it easy
for unauthorized workers to obtain jobs in the United States. Prior GAO
work shows that the problems with document and identity fraud undermine
the employment verification process. For example, in 1999 we reported
that large numbers of unauthorized workers either fraudulently used
valid documents that belong to others or presented counterfeit
documents as evidence of employment eligibility.[Footnote 11] In 2004,
we reported that unauthorized workers were able to use false documents
to illegally gain entry to secure areas of critical infrastructure
sites, such as airports, nuclear power plants, and military bases. To
improve the employment verification process, DHS reported it is
considering reducing the number of acceptable documents permitted to
verify employment eligibility.
DHS has made worksite enforcement a relatively low priority, given the
other immigration enforcement programs that compete for DHS resources.
Since the terrorist attacks of September 11, 2001, DHS has focused its
investigative resources on national security, and worksite enforcement
has focused on identifying and removing unauthorized workers from
critical infrastructure sites such as airports and nuclear power
plants. However, fraudulent use of SSNs among immigrants remains a
problem. In September 2005, the SSA Inspector General reported that
some nonimmigrants may remain in the United States and continue working
without DHS authorization,[Footnote 12] while others leave the country,
and in their absence, someone else may use these individuals' SSNs to
obtain employment. Using a universe of about 800,000 nonimmigrants that
SSA enumerated in fiscal year 2000, the Inspector General estimated
that about 32,000 nonimmigrants continued working after their
immigration status expired or someone else may have used their SSNs to
work after they left the country. [Footnote 13]
DHS has a voluntary "Basic Pilot" program where employers can choose to
verify employment eligibility electronically, but few employers
participate, and technological flaws hinder the program's
effectiveness. Most of the nation's approximately 5.6 million employer
firms rely on visual examination of documents individuals present,
while about 5,500 employer firms signed up to participate in Basic
Pilot as of March 2006.[Footnote 14] Basic Pilot enables employers to
verify Social Security numbers with SSA and work authorization and
immigration status with DHS. Basic Pilot shows promise for detecting
document fraud, but if an unauthorized worker presents valid
documentation that belongs to another person who is authorized to work,
Basic Pilot may verify the individual as work-authorized. If the use of
Basic Pilot expands, some unresolved problems, such as delays in data
entry and timely verification, will need to be resolved.
Real ID Act May Improve Links to the Card and Employment Eligibility
Determinations, but Limitations Exist:
Improvements to state drivers' licenses and identification cards, as a
result of the Real ID Act, may help the government's ability to
identify individuals and establish better links to the Social Security
card and employment eligibility determinations. The Real ID Act will
require that the estimated 250 million state drivers' licenses and
identification cards have a biometric such as a digital photo; physical
security features, such as a special hologram, to prevent tampering,
counterfeiting, or duplication; and a common machine-readable
technology. Before issuing drivers' licenses and identification cards,
states will be required to verify the Social Security numbers and legal
presence of applicants. While licenses and identification cards are
meant to prove identification, under the new law states are not
required to establish employment eligibility and will not be checking
worker status as they verify the Social Security number with SSA and
immigration documents with DHS. Beginning 3 years after the date of
enactment, a federal agency may not accept a state's driver's license
or identification card for any official purpose, unless the state meets
certain requirements. Table 5 shows the key requirements of the Real ID
Act.
Table 5: Requirements for State-Issued Drivers' Licenses or ID Cards
under the Real ID Act of 2005:
Minimum issuance standards:
Applicant must present evidence and have verified:
* Photo identification or nonphoto identification with full legal name
and date of birth on the document;
* Date of birth;
* Proof of valid SSN or verification that the person is not eligible
for one;
Address of principal residence.
Minimum document information standards:
The driver's license must contain:
* Full legal name;
* Date of birth;
* Gender;
* Driver's license or identification number;
* Digital photo of the person;
* Address of principal residence;
* Security features meant to prevent counterfeiting, tampering, or
duplication;
* Common machine-readable technology with defined data elements.
Evidence of lawful status:
A state shall require that a person provide valid documentary evidence
that the person;
* Is a citizen or national of the United States;
* Is an alien lawfully admitted for permanent or temporary residence in
the United States;
* Has conditional permanent resident status in the United States;
* Has an approved application for asylum in the United States or has
entered into the United States in refugee status;
* Has a pending application for asylum in the United States;
* Has a pending or approved application for temporary protected status
in the United States;
* Has approved deferred action status;
* Has a pending application for adjustment of status to that of an
alien lawfully admitted for permanent residence in the United States;
* Has a valid, unexpired nonimmigrant visa or nonimmigrant visa status
for entry into the United States.
Temporary drivers' licenses and identification cards; Temporary
drivers' licenses and identification cards will only be accepted by
federal agencies if they;
* Are valid only during the time in which the individual is authorized
to reside in the United States or, if there is no definite end to the
period of authorized stay, a period of 1 year;
* Clearly display that the license has been temporarily issued and
plainly display the expiration date;
* With respect to a temporary driver's license or temporary
identification card, may only be renewed upon presentation of valid
documentary evidence that the status has been extended by the
Department of Homeland Security.
Source: Real ID Act.
[End of table]
A Range of Enhancement Options Exists, and Costs Would Vary:
A range of options exists for enhancing the Social Security card, and
these options provide different levels of counterfeit protection and
capacity to verify employment eligibility. Options range from adding
counterfeit-resistant features to the paper card, adding machine-
readable features such as a magnetic stripe or bar code, and adding
biometric features such as photographs and fingerprints, to eliminating
the card entirely. Currently, the cost of providing a card to a
cardholder is approximately $25, and the cost of some of these options
will be higher.[Footnote 15] The total cost of enhancing the card will
be significantly affected by how many people are issued new cards and
the time frame for distribution. Options for distribution include
providing enhanced cards only to new cardholders, reissuing cards to
all of the 300 million estimated cardholders, or staggering issuance by
providing cards to new cardholders and to individuals who change jobs.
The options that we describe below are not intended to be an all-
inclusive listing of options available to enhance the security of the
card, but provide a framework of approaches for doing so.
Options for Enhancing Cards:
Adding secure features to the paper card:
There are a wide range of features that could be added to the current
paper card to make it more counterfeit-resistant. According to
Government Printing Office officials and other industry experts, these
features could include such improvements as printing a hidden image
that appears when the card is tilted to the light, changing the paper
content of the card to include fiber that reacts to certain chemicals,
and incorporating various security features currently used on currency,
such as a security thread in the paper. Government Printing Office
officials and industry experts report that these are relatively
inexpensive changes that would help protect the card by rendering
obsolete many of the counterfeit techniques currently used. Adopting
these types of changes to the current card would be the least
disruptive to SSA operations and to cardholders.
Adding machine--readable features:
Adding machine--readable features such as a magnetic stripe or secure
bar code feature could offer some measure of security of the card,
though some experts question the value of this option. Machine--
readable technology varies in the amount and type of information that
can be included on the card. For example, a card with a magnetic stripe
similar to those on credit and debit cards may contain the information
currently displayed on the Social Security card plus the individual's
work status. A secure bar code can also store identifying information
such as a photograph or fingerprint. Much like the process to verify
credit cards, machine-readable technology combines the security of
counterfeit-resistant features on the card with features that can be
read and verified by an external device. Employers and SSA would rely
on machines to read the cards, thus adding another step to assess the
cards' validity and protect the cards from counterfeiting. See figure 2
for a possible SSN card showing a magnetic stripe and a secure bar
code.
Figure 2: Examples of Possible Social Security Card with Reverse
Showing Magnetic Stripe and Secure Bar Code:
[See PDF for image]
[End of figure]
The main change to the card would be the introduction of machine-
readable technology. The primary advantage of machine--readable
technology is that it combines the security of counterfeit-resistant
features with those that can be read by an external device. The use of
machine-readable features could be useful as part of DHS's employment
eligibility authorization process. Current DHS guidelines state that an
employer has to review documents provided by new employees to prove
their eligibility to work and make a reasonable determination as to the
validity of documents presented. Use of machine-readable features would
take the burden off employers to make a determination that the card
that is presented is valid. Due to the large number of documents that
can be presented, including the many versions of the Social Security
card, employers are often ill equipped to determine if documents are
valid. A secure card with machine-readable features could also be used
by SSA or other programs in determining the validity of the card and
eligibility for benefits.
Card technology experts have noted that certain machine-readable
technology offers little protection against counterfeiting. For
example, magnetic stripe technology is relatively easy to counterfeit
with inexpensive equipment that is widely available. Other industry
experts stated that even though the data included in a secure bar code
may be encrypted, or coded so that the data cannot be read by
unauthorized persons, the data may still be copied in its encrypted
form and included on a counterfeit card.
Adding biometric features:
A highly secure card could incorporate biometric security features to
effectively establish an individual's identity and backup systems to
authenticate an individual's eligibility for benefits or work status.
Biometric features cover a wide range of technologies that can be used
to verify a person's identity by measuring or analyzing his or her
characteristics. Some widely used and well-known biometric features
include fingerprints, which uses distinct ridges of the fingertips to
establish an individual's identity, and digital pictures, which are
commonly used in drivers' licenses. These digital pictures support
facial recognition, which electronically compares facial features in
the digital pictures with those of the individual. Biometric cards
would be made of plastic or other durable material and could
incorporate smart card technologies.[Footnote 16] See figure 3 for
examples of biometrics that might be used on a Social Security card's
front or reverse sides depending on the card's design.
Figure 3: Examples of Biometrics--Fingerprint, Facial Recognition, and
Photograph:
[See PDF for image]
[End of figure]
Biometrics-enhanced cards could be supported by a central SSA database
to store the biometric information to verify the identity of an
individual. Storing identifying information on a central system would
provide additional protection if some of the physical security features
used on the card are able to be counterfeited. For example, many motor
vehicle administrations maintain central databases to compare stored
photos with those of individual renewing a driver's license. The
ability to make similar verifications to a centralized database could
also establish if individuals are eligible to work in the United
States. The biometric feature could also be stored only on the card,
but some industry experts indicate that data stored only on the card
are far more vulnerable to fraud than data in a centrally located
database of identifying information.[Footnote 17] However, experts also
caution that a centralized database has its own set of security
concerns, which will require a risk assessment to determine the most
cost-effective solution for storing biometric data. For example,
techniques would need to be developed to ensure that biometric
information provided to the centralized database actually represents
the individual, and a method would need to be implemented to handle the
inevitable situations where the information in the central database did
not agree with information provided. Prior GAO work on biometrics
outlines the strengths and concerns raised with the use of biometric
technology.[Footnote 18]
An additional consideration in using biometrics on the Social Security
card is determining when a biometric can first be captured from a
cardholder, as in the case of fingerprints or a picture or the need to
update the biometric in the case of a photograph. This may require SSA
to issue a temporary card through the Enumeration at Birth process and
then issue a card with a biometric at some other time, such as when the
individual reaches adulthood or enters the workforce. Depending on the
biometric selected, such as a digital picture, SSA would also need to
reissue the card at intervals to update these data.
A biometric Social Security card could raise general privacy concerns
about the card becoming a national identification card. A new Social
Security card with a biometric identifier issued to all number holders
could create a central database capable of identifying 300 million
individuals. A system that stores biometrics related to individuals'
identity may raise concerns about how the government would use and
protect the data. The Privacy Act of 1974 limits federal agencies'
collection, use, and disclosure of personal information, such as
fingerprints and photographs. While the act includes exemptions for law
enforcement and national security purposes, representatives of civil
liberties groups and privacy experts have expressed concerns regarding
the adequacy of protections for security, data sharing, identity theft,
and other identified uses of biometric data and the potential
intrusiveness of such an approach. Additional concerns focus on the
ease of using biometrics and their effect on the ability of the agency
to complete its mission.
Eliminating the card:
Finally, another approach would be to eliminate Social Security cards
entirely and use other, more secure documents to prove employment
eligibility. Under a no Social Security card option, each person who is
assigned an SSN would receive a letter, not a card, with an SSN on it.
Like the current card, the letter would record the number assigned and
provide individuals with a written record of their number. Eliminating
the Social Security card would mean that the card itself would not be
used as documentation for obtaining government benefits, and the burden
of finding a means to secure the card would be removed. Changing from a
card to a letter would not require that SSA deviate from its current
issuance process,[Footnote 19] which would save SSA the time,
inconvenience, and many of the costs associated with issuing an
enhanced card. Documentation of an individual's identity could be tied
to other documents such as a driver's license and require some link
between the SSN and drivers' licenses, which are currently undergoing
improvements, or other identity documents.
Factors Affecting the Cost of Card Options:
The current cost of issuing an original or replacement Social Security
card is approximately $25. This includes approximately 4 cents for the
banknote paper card, and as table 6 shows, to enumerate an applicant,
SSA needs to interview applicants, verify documents such as birth
certificates with the agencies that issued them, and determine work
eligibility status. Including additional features on the card would
increase the cost of the card. For example, in 1997, SSA reported that
the cost of the current Social Security card document was 5 cents; a
plastic card with security features was 12 cents; a plastic card with a
picture was 14 cents; and a plastic card with a magnetic stripe was 22
cents. According to SSA, these costs have likely decreased somewhat
since its 1997 estimate. But this estimate also showed that processing
costs accounted for the bulk of issuance costs for most options it
considered. SSA's processing costs would increase if additional
features were included on the card. In 2004, SSA estimated that the
cost of obtaining a number holder's picture and biometric identifier
would add 5 minutes, or $3.50, to the cost of issuing a card. Adding
machine-readable or biometric features to the card would also require
additional equipment in SSA's approximately 1,300 field offices, and
employers and other users would also need equipment if they were
expected to read features on the card. Further, biometric features
would likely require cardholders to have their biometric information
updated at periodic intervals--greatly affecting the number of cards
cardholders would receive in their lifetime and long-term card issuance
costs.
Table 6: Factors that Affect Costs of Enhanced Card Options:
Card options: Unchanged paper card;
Determine employment eligibility[A]: Yes;
New equipment at SSA field offices: No;
New equipment at job sites: No;
Periodic updates needed from cardholder at SSA field offices: No.
Card options: Machine-Readable; (paper or plastic);
Determine employment eligibility[A]: Yes;
New equipment at SSA field offices: Yes;
New equipment at job sites: Yes;
Periodic updates needed from cardholder at SSA field offices: No.
Card options: Biometric;
Determine employment eligibility[A]: Yes;
New equipment at SSA field offices: Yes;
New equipment at job sites: Yes;
Periodic updates needed from cardholder at SSA field offices: Yes.
Card options: No card--letter to notify assigned SSN;
Determine employment eligibility[A]: Yes;
New equipment at SSA field offices: No;
New equipment at job sites: No;
Periodic updates needed from cardholder at SSA field offices: No.
Source: GAO.
[A] This includes interviewing applicants and verifying documents:
[End of table]
Issuance Options Affect Cost:
Specific costs for each card option are not yet available. However,
issuing 300 million enhanced cards at the current cost of approximately
$25 each is costly, but maintaining the current method of issuing cards
and permitting older versions of cards to remain valid would do little
to stem counterfeiting or help employers determine whether applicants
are eligible to work. Permitting older versions is cost-effective for
SSA, since new cards have to be issued only to new applicants and
people needing replacement cards. About 17 million new and replacement
cards are issued annually. Table 7 shows three card issuance options,
including the number of cardholders requiring new cards.
Table 7: Card Issuance Options:
Issuance options: Current issuance process;
Cards issued in the initial 12 months: 18 million[A];
Document used to prove employment eligibility: Old cards valid: Yes;
Document used to prove employment eligibility: Only new cards valid:
No.
Issuance options: Mass issuance;
Cards issued in the initial 12 months: 300 million;
Document used to prove employment eligibility: Old cards valid: No;
Document used to prove employment eligibility: Only new cards valid:
Yes.
Issuance options: Staggered issuance;
Cards issued in the initial 12 months: 45 million[B];
Document used to prove employment eligibility: Old cards valid: No;
Document used to prove employment eligibility: Only new cards valid:
Yes.
Source: GAO analysis of SSA data.
[A] Total rounded to next million.
[B] This figure represents the approximately 34 million people who SSA
estimates change jobs annually, 5.4 million original Social Security
cards issued annually, and SSA's estimate of 6 million individuals who
would request replacement cards under this option.
[End of table]
Mass issuance:
While mass reissuance of Social Security cards to all 300 million
Social Security number holders would ensure a more effective tool for
establishing employment eligibility, mass issuance could cost billions
of dollars. Number holders would need to be notified through costly
mass mailings that they would need to come to an SSA field office with
appropriate documentation to obtain their new card, and field offices
would need to be staffed and equipped to verify the identity of the
number holders and issue the cards. To help ease the strain on SSA
field offices and resources, costs for a mass issuance could be phased
in over several years.
Staggered issuance:
Staggering issuance of an enhanced Social Security card to new hires or
individuals who change jobs could help increase the likelihood that the
card is a valid document in the worker verification process and help
reduce the cost of a mass issuance. Under this issuance option, only an
enhanced card would be permitted for determining employment
eligibility. As a result, the 34 million workers who change jobs each
year would need to obtain an enhanced card. In addition, SSA issues
approximately 5 million cards to new cardholders annually. Further, SSA
has estimated that this option would include about half, or 6 million,
of the replacement cards issued annually. Therefore, staggering
issuance to job changers and new cardholders would result in a total of
about 45 million enhanced cards issued during the first year of an
enhanced card issuance.
Conclusions:
Congress has long recognized that the Social Security card is
vulnerable to misuse and has considered various approaches to
minimizing this vulnerability and securing the card against
counterfeiting. However, with 50 valid versions, many of which lack any
counterfeit protections, the card is difficult to counterfeit-proof
completely, making it an element in identity theft and benefit program
fraud, as well as an ineffective tool in verifying employment
authorization. We recognize that the Intelligence Reform and Terrorism
Prevention Act does not, specifically, require SSA to establish
safeguards for the card for the purposes of employment eligibility, but
the act intends for SSA to establish standards for safeguarding the
card from fraudulent use. In doing so, SSA is thus far considering card
protection solely within the context of the Social Security program;
the agency is not currently planning to address card protection as part
of the broader question of the card's role in employment verification
or the potential impact of other identification advances such as the
new state driver's license requirements on the use of the card.
While DHS is represented on the SSA-led task force to address card
protection, the task force has been convened late in SSA's card
enhancement process, only a few months before SSA must provide for
implementing new card safeguards. This approach allows little time to
involve DHS in addressing the scope of critical issues affecting the
role of the card. Yet DHS's ongoing reevaluation of which documentation
represents acceptable proof of employment authorization is clearly
relevant to the card's role and the types of security elements that
might be warranted. It is important that the card's role in the
employment eligibility documentation process not be overlooked in SSA's
work on enhancements. Although consideration of this issue may not be
specified in law, broader thinking about the card's use and security
could mitigate the need to revisit card enhancement issues in the
future.
Recommendation for Executive Action:
As the SSA-led task force develops ways to protect the Social Security
card, it is important that the card meets the needs of DHS in the
employment verification process; therefore, we recommend that:
* the Secretary of Homeland Security and the Commissioner of Social
Security work together to resolve the weaknesses of the Social Security
card in proving employment eligibility. Specifically, they should
consider the millions of cards that do not prove employment
eligibility, the inability to tie the card to the cardholder, flaws in
the voluntary employment verification system, improvements to
identification cards by the Real ID Act, and the current ease of
counterfeiting the card.
Agency Comments:
The Department of Homeland Security and the Social Security
Administration provided comments on a draft of this report.
In its response, DHS agreed that much could be done on an interagency
basis to improve the integrity of Social Security cards and numbers, as
required by the Intelligence Reform and Terrorism Prevention Act of
2004. In addition, DHS agreed with SSA's decision to link the role of
the card with verifying employment eligibility later in the task
force's deliberative process. DHS stated that determining what to do to
make the card more secure, or eliminating the card altogether, appears
to be the appropriate task at this stage and DHS will continue to work
with SSA through the interagency task force. DHS's comments are
reprinted in appendix III. We also received technical comments, which
we incorporated where appropriate.
In SSA's response to our recommendation, SSA agreed in part, although
it stated that some aspects of the recommendation are outside the scope
of what Congress provided in the Intelligence Act. But otherwise SSA is
continuing to work with DHS on issues related to employment eligibility
and verification through the Basic Pilot program. While we assessed
SSA's implementation of the Intelligence Act provisions, we also
studied the role of the Social Security card and number in the context
of employment verification. We recognize that the Intelligence Act does
not specifically state that the task force is to establish safeguards
for the card for the purposes of employment eligibility. However, the
act was broadly written and provides sufficient authority to address
such issues, given the act's requirement to consult with DHS to form an
interagency task force. Our work showed major flaws with the Social
Security card's role in the employment verification process, which
raises concern when SSA did not involve DHS early enough in the process
to fully consider its input to card enhancement decisions. That is why
we recommended that SSA and DHS work together more closely to resolve
the weaknesses of the Social Security card in proving employment
eligibility.
SSA states that the Intelligence Act requires SSA to have a plan for
implementation by June 2006 and that the agency is on target to develop
a plan for implementation by June 2006. While developing a plan for
implementation is certainly consistent with the Intelligence Act's
mandate, we do not view the Commissioner's responsibilities under the
law to be limited solely to developing a plan. Specifically, the
Intelligence Act requires that "Not later than 18 months after the date
of enactment of this Act, the task force shall establish, and the
Commissioner shall provide for the implementation of, security
requirements, including--standards for safeguarding social security
cards from counterfeiting, tampering, alteration, and theft."
SSA further notes that our report has various references to SSA moving
slowly and is not convening the task force until a time so late in the
process that successful implementation would be nearly impossible. We
believe our report accurately characterizes SSA's actions to date. The
Intelligence Act requires that SSA consult with DHS and form an
interagency task force to establish standards to better protect the SSN
and card. Instead of having the task force direct efforts to establish
safeguards for the SSN and card, SSA studied card enhancement options
for nearly 1 year and made a preliminary decision without task force
input. By the time SSA convened the task force, the group had less than
6 months to study and establish standards for safeguarding the card.
SSA stated that current law requires that the card be made of banknote
paper, and as a result, the task force was technically limited to
improvements to the paper card. We believe that SSA and the task force,
as stewards of the Social Security card, have a responsibility to
ensure that the most appropriate enhancements to the card are
considered. Although the law requires that the card be made of banknote
paper, the Intelligence Act does not prohibit SSA or the task force
from recommending legislative changes to better prevent tampering,
alteration, and counterfeiting.
SSA characterized the report as having an overarching theme that
suggests the use of an enhanced card would address weaknesses in
employment eligibility and enforcement, which SSA cites as beyond the
scope of its mission and more in line with DHS's primary missions. SSA
states that attempting to make the card meet a purpose for which it was
not crafted would deflect valuable resources from the Social Security
program. According to SSA, the report should make the point that a new,
more secure card tailored to proving employment eligibility would do
little good if not accompanied by other significant changes in the
workplace enforcement arena. SSA stated that to expend considerable
resources to develop a card to confirm employment eligibility that is
used by a few employers would seem an injudicious use of government
resources. We agree that these are critical issues to consider.
SSA also noted that because the Real ID Act requires states to use a
DHS verification system for noncitizens, it would be an easy next step
to reflect work authorization on drivers' licenses if Congress wanted
to do so. We believe that SSA's suggestion for modifications to the
Real ID Act requirements for drivers' licenses and identification cards
is important to the broader discussion on safeguards and represents yet
another example of a critical issue that DHS and SSA should consider in
the deliberation on card enhancements. SSA states that our claim that
SSA is not planning to address card protection as part of employment
verification or the potential impact of changes required by the Real ID
Act to drivers' licenses is not true. SSA stated that it is working
with DHS and the American Association of Motor Vehicle Administrators
on matters of joint interest. We are encouraged by SSA's comments that
the agency is working with DHS and the American Association of Motor
Vehicle Administrators. However, we have asked SSA and DHS to provide
information on the task force initiative but they have not provided the
information we requested.
SSA indicated that it found our report title misleading, stating that
the majority of the report focuses on one purpose of enhancement--
employment eligibility verification. We disagree; our report title
accurately reflects the need for SSA to coordinate with DHS in its card
enhancement efforts and our recommendation that the agencies do so.
Besides employment eligibility, our report describes SSA's efforts to
implement the Intelligence Act and outlines options for enhancing the
Social Security card.
Finally, because our report is concerned with counterfeiting, SSA
stated that it would be prudent to protect its content by limiting
distribution. We disagree. While our report describes examples
involving counterfeit cards, the information in our report is readily
available publicly in prior reports published by SSA and, most
recently, in a November 2005 testimony by an SSA official before the
House Committee on Ways and Means, Subcommittee on Social Security.
However, we have made changes to some language in the report to address
SSA's concerns. SSA's comments are reprinted in appendix IV. SSA also
provided technical comments, which we incorporated where appropriate.
We are sending copies of this report to the Secretary of Homeland
Security and the Commissioner of the Social Security Administration and
other interested parties. Copies will also be made available to others
upon request. In addition, the report will be available at no charge on
GAO's Web site at http://www.gao.gov:
Please contact me at (202) 512-7215 or bovbjergb@gao.gov if you or your
staff have any questions about this report. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff that made major contributions
to this report are listed in appendix V.
Sincerely yours,
Signed by:
Barbara D. Bovbjerg:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Scope and Methodology:
The Chairman of the of the House Committee on the Judiciary asked us to
review the Social Security Administration's (SSA) efforts to implement
provisions of the Intelligence Reform and Terrorism Prevention Act of
2004 for safeguarding the Social Security number (SSN) and enhancing
the Social Security card. The Chairman also asked that we identify key
issues to be considered before enhancing the Social Security card and
that we outline the range of options available to SSA for enhancing
Social Security cards.
To address the Chairman's request, we met with officials from SSA
headquarters in Baltimore, Maryland, to review the agency's progress in
implementing provisions of the Intelligence Act. We reviewed key
initiatives planned and undertaken to strengthen SSA's enumeration
processes and SSA's plans for enhancing the Social Security card. We
also reviewed SSA's schedule for implementing the card enhancement
provision of the act and documented SSA's progress in meeting other
provisions contained in the legislation. In order to gain an
understanding of the policies, procedures, and issues related to the
current employment verification process, we met with officials from the
Department of Homeland Security (DHS) in Washington, D.C. We discussed
the current Form I-9 procedures and the role of employers in reviewing
employment eligibility documents, as well as DHS's Basic Pilot system
used to determine the employment eligibility of certain prospective
employees.
To identify key issues to be considered before enhancing the Social
Security card, we consulted the GAO body of work on the integrity of
the SSN, our work on immigration enforcement and problems reported in
the employment verification process, and work the SSA Office of the
Inspector General and selected law enforcement agencies had performed
in these areas. We contacted law enforcement officials involved in an
alleged document fraud case in Montgomery County, Maryland. We examined
concerns raised regarding the integrity of the SSN and card with
respect to counterfeiting, and reported document and identity fraud
with the requirements of the employment verification process. We also
reviewed SSA documents including agency testimonies before Congress and
the 1997 SSA report entitled Social Security Administration: Report To
Congress On Options for Enhancing the Social Security Card to document
flaws in the card and its ability to serve as proof of employment
eligibility. We studied the new federal legislative requirements for
states' drivers' licenses and identification cards included in the Real
ID Act. We contacted DHS, the American Association of Motor Vehicle
Administrators in Arlington, Virginia, and state motor vehicle
administrations in Chicago, Illinois; Charleston, West Virginia; and
Cheyenne, Wyoming, to discuss security features used in drivers'
licenses and the implication of changes to drivers' licenses as a
result of the Real ID Act. We selected these three states because they
used various security features in their driver's licensing or
identification processes such as fingerprinting, advanced optical
printing and inks, or holograms and other features, which already meet
stated or anticipated requirements of the Real ID Act.
To identify the range of options available to SSA for enhancing the
card, we researched and analyzed technical literature and identified
various technology experts and industry associations. We held
discussions with technology experts in the metropolitan Washington,
D.C., area at the National Institute of Standards and Technology,
International Biometrics Industry Association, AC Technology, Mitretek
Systems, and the Smart Card Alliance to discuss the range of card
options and available security features, their feasibility for use on
the Social Security card, and privacy and other concerns. Through these
discussions we developed a framework of options available to enhance
the security of the card.
Because the current legislation governing the Social Security card
requires that the card be made of banknote paper, we also obtained
information on card improvements suitable to a paper format. We met
with officials from the Government Printing Office, in Washington,
D.C., who administer the contract for printing Social Security cards
and Banknote Corporation of America in Browns Summit, North Carolina,
the contractor that prints Social Security cards, to discuss advances
in security printing techniques.
We reviewed identification initiatives using biometrics at the United
States Visitor and Immigrant Status Indicator Technology program and
the Transportation Security Administration Registered Traveler program
in DHS in Washington, D.C. Finally, we met with employer association
groups identified by the U.S. Chamber of Commerce in Washington, D.C.,
to discuss the impact of potential changes to the Social Security card
on the business community.
We performed our work between April 2005 and January 2006 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: Department of Homeland Security Form I-9:
[See PDF for image]
Note: While DHS has removed the Certificate of United States
Citizenship and Certification of Naturalization as acceptable List A
documents that establish both identity and employment eligibility, it
has not updated the Form I-9.
[End of section]
Appendix III: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
March 14, 2006:
Ms. Barbara D. Bovbjerg:
Director:
Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Bovbjerg:
We appreciate the opportunity to comment on the Government
Accountability Office's (GAO) draft report, Social Security
Administration: Improved Agency Coordination Needed for Social Security
Card Enhancement Efforts GAO-06-303. The report provides in-depth
information on the history and background of the Social Security card
to include past and present efforts in making the card more secure.
The report frequently links the Department of Homeland Security's
employer verification requirements as a rationale for enhancing the
Social Security card; however, the GAO reported the Social Security
Administration is thus far considering card protection solely within
the context of the Social Security program. The GAO further concluded
the Social Security Administration is not currently planning to address
card protection as part of the broader question of the card's role in
employment verification. The GAO recommended the Secretary of Homeland
Security and the Commissioner of Social Security work together to
resolve the weaknesses of the Social Security card in proving worker
eligibility. Specifically, the GAO recommended both organizations
consider the millions of cards that do not prove worker eligibility,
the inability to tie the card to the cardholder, flaws in the voluntary
worker verification system, improvements to identification cards by the
Real ID Act, and the current ease of counterfeiting the card.
We concur that much can be done on an interagency basis to improve the
integrity of Social Security cards and numbers, as is required by the
Intelligence Reform and Terrorism Prevention Act of 2004. We further
agree with the Social Security Administration's decision to link the
role of the Social Security card with verifying worker eligibility
later in their deliberative process. Determining what to do to make the
card more secure, or eliminating the card altogether, appears to be the
appropriate task at this stage. We will continue to work with the
Social Security Administration through the interagency task force.
We thank you again for the opportunity to provide comments on this
draft report and look forward to working with you on future homeland
security issues.
Sincerely,
Signed by:
Steven J. Pecinovsky:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix IV: Comments from the Social Security Administration:
SOCIAL SECURITY:
The Commissioner:
March 16, 2006:
Ms. Barbara D. Bovbjerg:
Director, Education, Workforce, and Income Security Issues:
Room 5968:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Ms. Bovbjerg:
Thank you for the opportunity to review and comment on the draft report
"Social Security Administration Improved Agency Coordination Needed for
Social Security Card Enhancement Efforts" (GAO-06-303). Our comments on
the draft report content and recommendations are enclosed.
If you have any questions, please contact Candace Skumik, Director,
Audit Management and Liaison Staff at (410) 965-4636.
Sincerely,
Signed by:
Jo Anne B. Barnhart:
Enclosure:
COMMENTS ON THE GOVERNMENT ACCOUNTABILITY OFFICE (GAO) DRAFT REPORT
"SOCIAL SECURITY ADMINISTRATION (SSA): IMPROVED AGENCY COORDINATION
NEEDED FOR SOCIAL SECURITY CARD ENHANCEMENT EFFORTS" (AUDIT NUMBER GAO-
06-303):
Thank you for the opportunity to review and comment on the draft
report. We are committed to ensuring that the Agency complies with all
legislative requirements with respect to the Social Security number
(SSN) card, as such we believe there are a number of points in the
report that need to be clarified or discussed in more detail to put an
accurate perspective on this issue.
Our comments below are structured in four segments: 1) general
observations and suggestions regarding the context of the report; 2)
our response to the recommendation; 3) specific technical comments to
further enhance the accuracy of the report; and 4) an other matters
section which addresses the Real ID Act and its relationship to the
Social Security (SS) card. Finally, because of the report's content
concerning SS card counterfeiting, we believe that it would be prudent
to protect the contents of the report and therefore request limited
distribution.
General Comments:
Report Title:
We believe the report's title is misleading. As stated, one would
expect the report's body to focus primarily on enhancements to the SS
card, but the majority of the report focuses on one purpose of the
enhancements --employment eligibility verification.
Background:
In the letter to the Chairman, GAO states that the 9/11 Commission's
Report stated that all but one of the hijackers had acquired United
States (U.S.) identification documents, some by fraud, and further
states that the Commission's Report recommended that the Federal
Government strengthen issuance standards for SS cards, driver's
licenses and birth certificates. While the report did recommend that
the Federal Government set standards for the issuance of sources of
identification (page 390 of the Commission's Report), we found no
recommendation in the report that the Federal Government strengthen the
issuance of SS cards. We would emphasize that the SS card was never
intended to be a form of identification. As correctly noted in the GAO
draft report, the purpose of the SSN has been, and continues to be, a
mechanism to track an individual worker's earnings and eligibility for
Social Security benefits. The card serves merely as a record of the
number assigned to an individual worker.
Requirements of the Intelligence Reform and Terrorism Prevention Act
P.L. 108-458, (IRTPA):
IRTPA (Intelligence Act) required the Commissioner of Social Security,
in consultation with the Secretary of Homeland Security, to form an
interagency taskforce. The taskforce is specifically charged with
establishing security requirements, including: 1) standards for
safeguarding SS cards from counterfeiting, tampering, alteration, and
theft; 2) requirements for verifying documents submitted for the
issuance of replacement cards; and 3) actions to increase enforcement
against the fraudulent use or issuance of SSNs and cards.
Current law requires that the card be made of banknote paper (see, 42,
U.S.C. 405(c)), and, as a result, the taskforce was technically limited
to consideration of improvements to a card made of banknote paper. The
taskforce has considered a wide range of security features that would
strengthen the card, and while we acknowledge that pending legislation
may require changes to the card, such as magnetic strips or bar coded
cards or many of the other proposals suggested by GAO, the task force
is clearly limited in scope by the legislative authority granted it by
Congress. The preliminary Agency decisions to continue with a card
based on bank note paper and to only issue the card prospectively are
reflective of what is within the Commissioner's authority to implement.
In addition, we do not agree with GAO's interpretation of the date by
which SSA must implement improvements to the card as required in the
Intelligence Act. Throughout the report, there are references to SSA
moving slowly and not convening the task force until a time so late in
the process that successful implementation would be nearly impossible
("not convening the task force until late January 2006, allowing the
task force less than 6 months to consider critical issues that affect
card enhancement options before SSA is required to implement new
safeguards in June 2006'). This same language regarding implementing
new safeguards by June 2006 is found throughout the report, including
pages 9 and 12. The report needs to be clear that the legislation does
not require SSA to "implement new safeguards in June 2006." Rather, it
requires the Agency to develop a plan to implement the security
requirements established by the task force.
Furthermore, we believe the report's overarching theme that suggests
the use of an enhanced card will address weaknesses in employment
eligibility and enforcement is beyond the scope of our mission. GAO's
assessment on page 18 is accurate when it states that the role of the
SS card in proving authorization to work has limitations. Under
existing protocols, SSA is entirely dependent upon the number holder to
report changes in work authorization status on a timely basis, and once
reported, SSA confirms the change of status with the Department of
Homeland Security (DHS) before issuing a replacement SS card. If
current, accurate work authorization information is to be contained on
an SS card, then the number holder must request a status change from
DHS, and DHS must share that status change data with SSA on a timely
basis. SSA would then need to reissue a replacement SS card to the
number holder, and at the same time make void the prior card.
Establishing such a process would involve many challenges, such as
timely updating of the information and determining how to contact the
number holder to provide an updated card, not to mention the costs.
These process implications go well beyond the mandated purpose of the
SS card. Finally, any change to the SS card to resolve weaknesses in
the area of employment eligibility would be of very limited value if
not accompanied by legislative requirements imposed on employers
requiring the use of whatever employment eligibility features were
designed into a new card.
In summary, the determination and tracking of current employment
eligibility remains one of DHS' primary missions. Attempting to make
the SS card meet a purpose for which it was not crafted would deflect
valuable resources from the Social Security programs on which the
public relies. We acknowledge that current pending legislation could
require changes to the card, and we are committed to working with
Congress; however, SSA is limited in its ability to establish
safeguards to the current card as required by the law. Given that the
Intelligence Act required SSA to have a plan for implementation by June
2006, we believe the overriding conclusion of the report should reflect
that SSA is on target to develop a plan for implementation by June
2006, and that ample opportunity for Agency cooperation has been
established.
Options for Enhancing Cards:
We believe the report should make the point that a new, more secure
card tailored to proving employment eligibility would do little good if
not accompanied by other significant changes in the workplace
enforcement arena. For example, there is considerable discussion in the
report about making a "machine readable" card, or a card with biometric
data which, when compared to the information in a central database
housing the biometric data of all cardholders, could be used to verify
current work authorization for employers and others. The efficacy of
such a card in workplace enforcement would depend on employers'
willingness to buy and use the equipment needed to read the card and do
the verifications. However, the experience of both SSA and DHS with
employer verification services (e.g., the Basic Pilot and SSA's SSN
Verification Service) is that only a small percentage of employers are
interested in using such services on a voluntary basis. To expend
considerable resources to develop and offer a machine readable card to
confirm employment eligibility that would probably not be used by most
employers would seem to be an injudicious use of government resources.
Recommendation:
The Secretary of Homeland Security and the Commissioner of Social
Security should work together to resolve the weaknesses of the Social
Security card in proving worker eligibility. Specifically, they should
consider the millions of cards that do not prove worker eligibility,
the inability to tie the card to the cardholder, flaws in the voluntary
worker verification system, improvements to identification cards by the
Real ID Act, and the current ease of counterfeiting the card.
SSA Response:
We agree in part. Some aspects of the recommendation are outside the
scope of what Congress provided in the Intelligence Act. As required by
IRPTA, the Commissioner of Social Security, in consultation with the
Secretary of Homeland Security, has formed an interagency taskforce
specifically charged with establishing security requirements,
including: 1) standards for safeguarding SS cards from counterfeiting,
tampering, alteration, and theft; 2) requirements for verifying
documents submitted for the issuance of replacement cards; and 3)
actions to increase enforcement against the fraudulent use or issuance
of SSN's and cards. In addition, SSA is continuing to work with the
Department of Homeland Security on issues related to employment
eligibility and the Basic Pilot verification program.
Other Matters:
Real ID Act Implications:
On page 20, the point is made that the Real ID Act does not require
States to check employment eligibility in issuing driver's licenses,
implying that the new driver's license required under the Real ID Act
would have limited value in workplace enforcement. However, the Real ID
Act does require States to use the DHS Systematic Alien Verification of
Entitlement queries for any non-citizen, and that query shows work
authorization. It would be an easy next step to reflect this on
driver's licenses if Congress wanted to do so. In addition, the Real ID
Act requirement that time limited driver's licenses be issued to non-
citizens who are in the U.S. on time limited visas would also seem to
be a good fit with the time limits on many work authorization
categories. We think the point should be made that the driver's license
could be made to reflect work authorization with relative ease, given
these other requirements of the Real ID Act.
Page 31 states that SSA "is not currently planning to address card
protection as part of the broader question .. or the potential impact
of other identification advances such as the new state driver's license
requirements.." This is not true; SSA has taken into account the action
of Congress in passing the Real ID Act to make the State issued
driver's license and ID card excellent identity documents that will be
available to all U.S. citizens and non-citizens. SSA is working with
the Association of American Motor Vehicle Administrators and DHS on
matters of joint interest regarding the Real ID Act and SSN's/cards.
Our expectation is that these documents will serve the nation's needs
to prove identity.
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Barbara D. Bovbjerg (202) 512-7215 or bovbjergb@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Blake Ainsworth, Assistant
Director; Daniel Bertoni, Assistant Director; Jacqueline Harpp; Jeff
Bernstein; Jeremie Greer; Roger Thomas; and Tovah Rom made key
contributions to this report.
[End of section]
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FOOTNOTES
[1] As used in this report, the Intelligence Act refers to the
Intelligence Reform and Terrorism Prevention Act of 2004, Pub. L. No.
108-458 (2004).
[2] Biometrics is a technology that uses automated methods of
recognizing a person based on analyzing physiological or behavioral
characteristics such as fingerprints or facial features among others.
[3] Since 1989, SSA has used the voluntary Enumeration at Birth Program
to allow parents the option of requesting SSNs for their newly born
children at the birth facilities rather than having to visit an SSA
field office.
[4] GAO, Immigration Enforcement: Weaknesses Hinder Employment
Verification and Worksite Enforcement Efforts, GAO-05-813 (Washington,
D.C.: Aug. 31, 2005), and GAO, Social Security: Better Coordination
among Federal Agencies Could Reduce Unidentified Earnings Report, GAO-
05-154 (Washington, D.C.: Feb. 4, 2005).
[5] SSNs are assigned for the life of the number holder and remain
valid indefinitely even after a number holder's death for the purposes
of administering survivor benefits.
[6] Pub. L. No. 99-603, (1986), 8 U.S.C.§ 1324a et seq.
[7] Pub. L. No. 109-13, Emergency Supplemental Appropriations Act for
Defense, the Global War on Terror, and Tsunami Relief, 2005, Title II,
(2005).
[8] GAO, Social Security Administration: Actions Needed to Strengthen
Processes for Issuing Social Security Numbers to Children, GAO-05-115
(Washington, D.C.: Jan. 31, 2005).
[9] Testimony of the 109th Congress, Social Security Testimony before
Congress, November 1, 2005, Statement of Frederick G. Streckewald,
Assistant Deputy Commissioner, Office of Disability and Income Security
Programs (Program Policy), before the House Committee on Ways and
Means, Subcommittee on Social Security.
[10] GAO-05-813.
[11] GAO, Illegal Aliens: Significant Obstacles to Reducing
Unauthorized Alien Employment Exist, GAO/GGD-99-33 (Washington, D.C.:
Apr. 2, 1999).
[12] A nonimmigrant is a foreign-born individual who is granted
temporary admission to the United States for a specific purpose, such
as students and temporary workers.
[13] Office of Inspector General, Social Security Administration,
Impact of Nonimmigrants Who Continue Working after Their Immigration
Status Expires, A-08-05-15073 (September 2005).
[14] This indicates the number of businesses that have signed
memorandums of understanding with DHS and is not indicative of the
number of active participants.
[15] Based on fiscal year 2004 data.
[16] Smart cards are plastic devices about the size of a credit card
that use integrated circuit chips to store and process data.
[17] American Association of Motor Vehicle Administrators officials
have pointed out that the combination of a number of security features
raises the overall level of security of a card or document.
[18] GAO, Information Security: Challenges in Using Biometrics, GAO-03-
1137T (Washington, D.C.: Sept. 9, 2003).
[19] SSA currently has numerous means of establishing an individual's
identity. These include verifying the individual's identity by asking
open-ended questions and confirming this information with information
previously provided in SSA's records. If there are questions about the
individual's identity, SSA staff may request identification documents,
check telephone directories, or contact persons or organizations who
may know the individual. They are not constrained by any single
document or question.
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