THE INSPECTOR GENERAL
SOCIAL SECURITY ADMINISTRATION
OFFICE USE OF THE
By conducting independent and objective audits, evaluations and investigations, we inspire public confidence in the integrity and security of SSA's programs and operations and protect them against fraud, waste and abuse. We provide timely, useful and reliable information and advice to Administration officials, Congress and the public.
The Inspector General Act created independent audit and investigative units, called the Office of Inspector General (OIG). The mission of the OIG, as spelled out in the Act, is to:
Conduct and supervise independent and objective audits and investigations
relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and operations.
Review and make recommendations regarding existing and proposed legislation and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of problems in agency programs and operations.
To ensure objectivity, the IG Act empowers the IG with:
Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.
We strive for continual improvement in SSA's programs, operations and management by proactively seeking new ways to prevent and deter fraud, waste and abuse. We commit to integrity and excellence by supporting an environment that provides a valuable public service while encouraging employee development and retention and fostering diversity and innovation.
Date: July 2, 2007
To: The Commissioner
From: Inspector General
Subject: Field Office Use of the SS-5 Assistant (A-04-07-17026)
Our objective was to determine whether the Social Security Administration's (SSA) field office (FO) staff complied with enumeration policies and procedures when processing Social Security number (SSN) applications through the SS-5 Assistant.
SSA requires that applicants for an original or replacement SSN card complete a Form SS-5, Application for a Social Security Card. The SS-5 Assistant, a Microsoft Access-based application, guides FO personnel in processing SSN applications by providing structured interview questions and requiring certain data to complete the application process. Overall, the SS-5 Assistant is intended to increase control over the SSN application process, improve the quality of data used to assign an SSN and enable management to better control this workload.
Staff from SSA's New York Regional Office Center for Automation developed the SS-5 Assistant program. At the time of our audit, a team consisting of software programmers, computer specialists and computer program analysts supported the SS-5 Assistant application. The SS-5 Assistant remains dynamic. Based on user input, the SS-5 Assistant is frequently enhanced to improve its efficiency and accuracy. Since its initial implementation, the SS-5 Assistant has been modified and upgraded numerous times.
The SS-5 Assistant works with SSA's Modernized Enumeration System (MES) and, in effect, implements many of SSA's enumeration policies and procedures. SSA mandated FO use of the SS-5 Assistant for most SSN applications on March 1, 2005. As of April 2007, SSA reported that its FOs had used the SS-5 Assistant to process about 98 percent of SSN transactions. From January 1, through March 31, 2006, SSA FO staff processed about 3.34 million original or replacement SSN card applications using the SS-5 Assistant. These applications resulted in SSA issuing about 2.96 million replacement cards and assigning some 382,000 original SSNs.
SSA is in the Planning and Analysis phase of developing the Social Security Number Application Process (SSNAP), an automated SSN assignment system that will replace the SS-5 Assistant and MES. The Agency is determining the user requirements for SSNAP and plans to implement this system within the next 2 years. Accordingly, any recommendations we make in this report will address considerations we believe should be given to the new system design.
SCOPE AND METHODOLOGY
We reviewed a random sample of 275 SSN applications processed through the SS-5 Assistant that resulted in the assignment of an original SSN or the issuance of a replacement Social Security card. We selected our sample from the 3.3 million SSN cards (original and replacement) issued between January 1 and March 31, 2006. Of the 275 SSNs selected for review, 252 (91.6 percent) were replacement card transactions, and 23 (8.4 percent) were applications for original SSNs.
Our audit determined whether FO personnel complied with enumeration policies and procedures and SS-5 Assistant requirements when processing the 275 applications. In doing so, we determined whether FO personnel (1) properly entered all the applicant information in SS-5 Assistant; (2) documented required evidence of age, identity, U.S. citizenship or lawful immigration status, as appropriate; (3) documented the verification/authentication of evidentiary documents as required by SSA policy; and (4) obtained supervisory approval of the SSN application, when required.
We verified document identification numbers recorded in the SS-5 Assistant
evidence fields with the issuing State or Federal agency. Specifically, we verified
U.S. birth certificate information with State Bureaus of Vital Statistics, immigration
documents with the Department of Homeland Security (DHS), passports with the
Department of State, and driver's licenses with the issuing State Department
of Motor Vehicles. Finally, we considered possible enhancements to the enumeration
process that may improve the integrity of the SSN process. Further information
regarding our scope and methodology and sampling methodology and results are
in Appendices B and C, respectively.
RESULTS OF REVIEW
We are very encouraged with the SS-5 Assistant program and FO compliance with its requirements. The system appears to have achieved its mission of increasing control over the SSN application process, improving the quality of data used to assign an SSN and enabling management to better control this workload. However, our review disclosed some areas in which we believe the SS-5 Assistant (or the future SSNAP) could ensure an even higher level of compliance with enumeration policies. Additionally, we identified a policy we believe should be revised to ensure a greater degree of integrity in the SSN assignment process.
In total, we identified 13 (4.7 percent) instances in which SSA FO personnel either did not comply with Agency policies when processing an SSN application through the SS-5 Assistant or made a technical error in entering the application information. Based on these errors, we estimate that 157,786 SSN applications processed through the SS-5 Assistant during the 3-month period of our review contained at least 1 compliance or technical error.
We also noted 26 (9.5 percent) instances in which FO personnel accepted and documented "secondary" evidence when processing replacement card applications. Although there are limited instances in which secondary evidence may be acceptable, we were unable to determine whether these conditions were met with the 26 applications identified. We understand the acceptance of some secondary evidence may be unavoidable; however, we are concerned that 9.5 percent of SSN applicants (almost 1 out of every 10) could not obtain more probative evidence (that is, a driver's license, State identification card or U.S. passport) within the 10 days allowed by SSA policy.
We also noted two instances in which it appears the SSN applicant presented
invalid identity documents to obtain a replacement Social Security card. Finally,
we noted that seven SSN applicants presented U.S. Certificates of Naturalization
as evidence they had obtained U.S. citizenship. Although SSA verifies the authenticity
of other immigration documents through DHS processes, SSA does not require that
FO personnel do so with Certificates of Naturalization. We believe such authentication
would improve the integrity of SSA records and ensure only those with true
U.S. citizenship are afforded the benefits derived from this status.
COMPLIANCE OR TECHNICAL ERRORS IN THE ASSIGNMENT OF ORIGINAL, AND ISSUANCE OF REPLACEMENT, SSN CARDS
As outlined in Table 1, of the 275 randomly selected SSN transactions, 13 (4.7 percent) either did not fully comply with SSA procedures or contained a technical error. Of these 13, FO personnel accepted and documented identity evidence that was insufficient in 4 instances. Additionally, FO personnel approved two SSN applications even though the identity evidence provided contained some discrepancies with the applicants' Numident data. In the remaining seven SSN transactions, FO personnel made data entry errors when processing the application through the SS-5 Assistant.
Table 1: Compliance or Technical Errors Identified in Our Sample
Type of Compliance/Technical Errors Number of Occurrences
Insufficient Evidence to Support Applicant's Identity 4
SSA's Identity Data Differed from the Issuing Agency Data 2
Data Entry Errors 7
Total Number of Compliance Errors Identified 13
Total Sample Size 275
Percentage of Sampled SSN Transactions
with a Compliance Error 4.7
Insufficient Evidence to Support Applicant's Identity
Of the 275 SSN transactions reviewed, FO personnel did not require and/or document acceptable evidence of the numberholder's identity for 4 (1.5 percent) replacement card applications. In two of the four transactions, the FO staff entered insufficient identity evidence in the "other" evidence field in the SS-5 Assistant. In the first case, the evidence documented was a traffic citation, which is not an acceptable identity document. In the second case, the information entered was indiscernible. In a third transaction, FO personnel entered a brief explanation of why they were issuing the replacement card rather than the evidence used to establish the applicant's identity.
In the fourth exception, SSA FO personnel processed a replacement SSN card application through the SS-5 Assistant for a prisoner who was still incarcerated without documenting proper identity evidence. Although SSA FOs may process replacement card applications for prisoners, certain requirements must be met. Specifically, the
prisoner must be a U.S. citizen,
SSN action cannot result in any changes to the Numident record,
FO must have a written agreement with the prison, and
SSN application must be accompanied with a letter from an authorized prison official that certifies information has been extracted from the prisoner's record that verifies the prisoner's identity.
If no agreement exists, FOs must adhere to the normal evidentiary requirements to process a replacement card. In this instance, the FO had no written agreement with the prison, and the only evidence of identity submitted with the application was the prisoner's identification number. Accordingly, the FO's issuance of this replacement card did not comply with SSA policy.
Information from Identity Documents Did Not Match SSA Records
For 2 (less than 1 percent) of the 275 SSN transactions reviewed, SSA FO personnel documented identity evidence that was inconsistent with identifying information in SSA records-specifically, SSA's Numident file. The two SSN transactions involved replacement card applications. In each of the instances, the SS-5 application data documented a State-issued driver's license or identification card as evidence establishing the individual's identity. We verified the driver's license numbers and identification data with the State of issuance and found that some of the identity information was not consistent with the applicants' existing Numident data. The dates of birth were incorrect for the applicants. We believe such differences should have been resolved before FO personnel approved the replacement card application.
Data Input Errors Occurred When Documenting Evidence Submitted
We identified 7 (2.5 percent) instances in our sample of 275 transactions in which FO personnel likely made data input errors when processing 6 replacement SSN card applications and 1 original SSN application. For example, we detected instances where some numbers or characters that FO staff recorded for State-issued driver's licenses and identification cards did not match the issuing agency's records. We also found similar instances with birth certificate numbers and U.S. passport data. Based on the entirety of the data, we concluded the submitted evidence was valid, but the FO personnel made input errors when recording the information in the SS-5 Assistant.
AREAS WHERE PROCESSING CONTROLS COULD BE IMPROVED
Of the 275 transactions, we believe processing controls could have been improved to better ensure the integrity and accuracy of 26 (9.5 percent). For seven transactions, FO personnel documented a Certificate of Naturalization as evidence of U.S. citizenship; however, the certificates were not verified with DHS. Also, SSA processed 26 applications in which FO personnel documented only secondary evidence to establish the applicants' identity. Although personnel may have complied with SSA policy in both areas, we are concerned that such procedures do not provide the strongest mechanisms to ensure proper SSN assignment, the integrity of the enumeration process and accurate SSA records.
Verification of Citizenship Documents
For 7 (2.5 percent) of 275 sampled SSN applications, SSA FO personnel documented a Certificate of Naturalization as evidence of U.S. citizenship. However, MES evidence fields indicated that FO personnel did not verify the authenticity of these documents through DHS' Systematic Alien Verification for Entitlements (SAVE) program for these seven replacement SSN card applications. According to the applicants' Numident records, on the date of the SSN applications, each applicant either (1) was classified as a noncitizen or (2) had no citizenship status code on the record and a foreign place of birth was indicated.
When FO staff process SSN applications involving a Certificate of Naturalization,
the SS-5 Assistant prompts the staff to select "Certificate of Naturalization"
drop-down menu and enter the document's alien registration number (A-number). SSA policy requires that FO staff visually inspect Certificates of Naturalization for authenticity, but staff is not required to routinely verify the A-number in SAVE when the document appears authentic. The SS-5 Assistant does, however, provide FO personnel with the option to automatically verify the Certificate of Naturalization through SAVE. If the verification is successful, a verification number is propagated to the SS-5 evidence field.
For the seven applicants, we found no evidence that the A-numbers were verified through SAVE. We were able to verify all seven Certificates of Naturalization through SAVE and confirm that the applicants were naturalized U.S. citizens. Although there was no evidence of irregularities in these seven cases, our previous audits and investigations have shown that visual inspection is not always a reliable method of detecting counterfeit documents. Given the technological advances in document reproduction, we are concerned that SSA policy does not require the verification of all Certificates of Naturalization through SAVE.
A Certificate of Naturalization may establish an SSN applicant as a U.S. citizen in SSA's records, which could bestow certain privileges on the individual. For example, the Employment Eligibility Verification System (EEVS), formerly known as the Basic Pilot, is a DHS program supported by SSA, which provides employers a tool for determining whether newly hired employees reported the correct name, SSN, and date of birth and are authorized to work in the United States. If noncitizens are incorrectly classified as U.S. citizens in SSA records (and allege U.S. citizenship to an employer), EEVS would not require that DHS determine their immigration and work status before confirming employment eligibility. A mandatory employment eligibility system has been proposed in both House and Senate bills for all newly hired U.S. employees. If such legislation is enacted, the accuracy and integrity of SSA's records regarding the numberholders' citizenship status would be essential to ensuring correct employment eligibility feedback to employers. As such, we believe an additional control requiring the verification of Certificates of Naturalization will reduce the potential for the improper assignment of SSNs. Also, since the SS-5 Assistant can automatically verify Certificates of Naturalization through SAVE, we believe this additional control would have minimal effect on FO workloads.
Reliance on Secondary Evidence
From our sample of 275 transactions, we identified 26 occurrences (9.5 percent)
in which SSA FO personnel processed replacement SSN card applications using
only secondary evidence. Typical examples of secondary evidence used included
insurance cards, employee identification cards, Certificates of Naturalization,
and student identification cards. In comparison, acceptable primary evidence
is a valid U.S. State-issued driver's license, a U.S. State-issued identification
card, or a U.S. Passport.
When processing SSN applications, FO personnel are required to obtain documentation with the highest probative value to establish identity-which includes available primary evidence. According to SSA policy, "available" means the document exists and the applicant can access or obtain it within 10 business days. Further, lost or expired documents are also considered "available" if the SSA staff processing the application know that the documents(s) can be renewed or replaced within 10 business days.
We understand that certain circumstances allow SSN applications to be completed with secondary evidence. However, we are concerned that almost 1 of every 10 SSN transactions was processed using secondary identity evidence. Because SSA FO staff deferred to secondary evidence when processing the transactions, we can only conclude that none of the 26 applicants were able to produce a valid State driver's license, identification card or passport. We are wary of the frequency of this situation.
IDENTITY EVIDENCE WAS SUSPECT
Of the 275 sampled SSN transactions, the identity documents presented for 2 (less than 1 percent) replacement SSN card applications were suspect. In these two cases, FO personnel recorded a driver's license number as the type of identity evidence submitted. The driver's license numbers did not verify with the issuing State's department of motor vehicles data. Additionally, officials for the issuing States researched their databases by the SSN applicants' names and could not identify a valid license for either individual.
CONCLUSION AND RECOMMENDATIONS
We are pleased with the SS-5 Assistant program and FO compliance with its requirements. Also, we recognize the New York Regional Office Center for Automation's efforts to continually improve the SS-5 Assistant. Our review determined that the SS-5 Assistant is functioning as intended. Although we identified some minor compliance and technical errors, we do not believe these instances are significant or indicative of larger systemic problems. Given the success of the SS-5 Assistant, we believe it-or the future SSNAP-could be enhanced to ensure an even higher level of SSN integrity and further reduce the Agency's risk of improper SSN assignment.
Accordingly we recommend SSA:
1. Consider coordinating with DHS to implement a requirement that FO staff verify the authenticity of all Certificates of Naturalization through SAVE when processing SSN transactions.
2. Issue a reminder to FOs about the importance of properly establishing and documenting an applicant's identity when processing an SSN transaction.
3. Issue a reminder to FOs that staff consider all viable options to obtain primary identity evidence before deciding to process SSN transactions based on secondary identity data.
AGENCY COMMENTS AND OIG RESPONSE
SSA agreed with our recommendations. The Agency's comments are included in Appendix D.
Patrick P. O'Carroll, Jr.
APPENDIX A - Acronyms
APPENDIX B - Scope and Methodology
APPENDIX C - Sampling Methodology and Results
APPENDIX D - Agency Comments
APPENDIX E - OIG Contacts and Staff Acknowledgments
ASVI Alien Status Verification Index
DHS Department of Homeland Security
EEVS Employment Eligibility Verification System
FO Field Office
MES Modernized Enumeration System
OIG Office of the Inspector General
POMS Program Operations Manual System
SAVE Systematic Alien Verification for Entitlements
SSA Social Security Administration
SSN Social Security Number
SSNAP Social Security Number Application Process
Scope and Methodology
We reviewed a random sample of 275 Social Security number (SSN) applications processed through the SS-5 Assistant that resulted in the assignment of an original SSN or the issuance of a replacement Social Security card. We selected our sample from a universe of 3,337,772 Social Security cards issued from January 1 through March 31, 2006. Based on information we obtained from the Modernized Enumeration System (MES), we determined whether the Social Security Administration (SSA) documented the required applicant information prescribed by SSA's enumeration policy. Because we tested more than one control attribute for each SSN transaction, some of the sampled SSN transactions may have more than one reportable issue and are included as audit findings in more than one section of the report.
To accomplish our objectives we:
Reviewed applicable laws, regulations, policies and procedures.
Interviewed SSA personnel in New York Regional Office Center for Automation responsible for developing and servicing the SS-5 Assistant application.
Interviewed field office personnel to gain an understanding of the SSN transaction
Examined SSA's Numident for the sampled SSN transactions to determine whether the citizenship and evidence codes properly reflected the applicant's status in accordance with the evidence descriptions documented in MES.
Obtained and reviewed MES data.
For SSN transactions in which the identity evidence descriptions provided alien registration numbers, we queried the Department of Homeland Security's Systematic Alien Verification for Entitlement program to verify the noncitizen's purported citizenship status.
For SSN transactions in which the identity evidence descriptions provided U.S. passports, we verified the passport information with the Department of State.
Obtained birth certificates from various State Bureaus' of Vital Statistics and queried data from States' Department of Motor Vehicles.
We conducted field work from August 2006 through April 2007 at SSA's Regional Office in Atlanta, Georgia. During our review, we relied on data extracted from SSA's MES and the Numident. We determined the data were sufficiently reliable to satisfy our audit objectives. Our tests of internal controls were limited to gaining an understanding of the laws, regulations and polices that govern the assignment and issuance of original and replacement SSNs cards and performing the tests identified above. The SSA entity audited was the Office of the Deputy Commissioner for Operations. We conducted our audit in accordance with generally accepted government auditing standards.
Sampling Methodology and Results
We reviewed a random sample of 275 Social Security number (SSN) applications processed through the SS-5 Assistant that resulted in the assignment of an original SSN or the issuance of a replacement Social Security card. We selected our sample from a universe of 3,337,772 SSN cards issued from January 1 through March 31, 2006. Our audit tested more than one control attribute for each SSN transaction.
We made all projections at the 90-percent confidence level.
Results - Original SSNs and Replacement SSN Cards with at Least One Compliance Error
Original SSNs and Replacement SSN Cards
With At Least One Compliance Error
Attribute Appraisal Projections
Population and Sample Data SSN Transactions
Total Population 3,337,772
Sample Size 275
SSN Transactions Processed with a Compliance Error 13
Projection to Population Projections
Lower Limit 94,078
Point Estimate 157,786
Upper Limit 247,355
Date: June 20, 2007
To: Patrick P. O'Carroll, Jr.
From: Larry W. Dye
Subject: Office of the Inspector General (OIG) Draft Report, "Field Office Use of the SS-5 Assistant" (A-04-07-17026)--INFORMATION
We appreciate OIG's efforts in conducting this review. Our comments on the draft report's content and recommendations are attached.
Please let me know if we can be of further assistance. Staff inquiries may be directed to Ms. Candace Skurnik, Director, Audit Management and Liaison Staff, at 410 965-4636.
COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL (OIG) DRAFT REPORT, "FIELD OFFICE USE OF THE SS-5 ASSISTANT" (A-04-07-17026)
Thank you for the opportunity to review and comment on the draft report. We are pleased that OIG concluded that the SS-5 Assistant is effective in ensuring the accuracy of the Social Security number (SSN) assignment process. We are also pleased that OIG did not find any fraud in this audit related to the Social Security Administration's (SSA) acceptance of Certificates of Naturalization as proof of citizenship. We appreciate OIG's willingness to incorporate the comments made at the exit conference into the formal draft. Below are our responses to the specific recommendations and some technical comments.
The Social Security Administration (SSA) should consider coordinating with the Department of Homeland Security (DHS) to implement a requirement that Field Office (FO) staff verify the authenticity of all Certificates of Naturalization through Systematic Alien Verification of Entitlement (SAVE) system when processing SSN transactions.
We will consider this; however, there are a number of technical and budgetary issues that need to be evaluated to determine if implementation of this recommendation is feasible and desirable. Our review of the current Memorandum of Understanding (MOU) with DHS does not require that they verify Certificates of Naturalization. Prior to pursuing this, we would need a commitment from DHS to ensure that it could handle the additional SSA verification workload. One important operational issue to be addressed is to determine whether the alien registration number, known as the "A number," appears on all Certificates of Naturalization. If it does, the verifications could be performed electronically; if it does not, a manual verification process would be necessary which would create an additional operational workload for SSA. We will complete our analysis of the feasibility of this recommendation by September 30, 2007.
SSA should issue a reminder to FOs about the importance of properly establishing and documenting an applicant's identity when processing an SSN transaction.
We agree. We will issue a reminder on this subject by the end of June 2007.
SSA should issue a reminder to FOs that staff consider all viable options to
obtain primary identity evidence before deciding to process SSN transactions
based on secondary identity data.
We agree. The SS-5 Assistant now requires that primary evidence be shown as unavailable before allowing FO employees to select a lower level document. This new process ensures that employees consider all viable options to obtain primary evidence of identity before processing SSN transactions based on lower level documents. We will issue a reminder to FO employees on this subject by the end of June 2007.
OIG Contacts and Staff Acknowledgments
Kimberly Byrd, Director, Southern Audit Division, (205) 801-1650
Frank Nagy, Audit Manager, (404) 562-5552
In addition to those named above:
Phillip Krieger, Auditor
For additional copies of this report, please visit our web site at www.socialsecurity.gov/oig or contact the Office of the Inspector General's Public Affairs Specialist at (410) 965-3218. Refer to Common Identification Number A-04-07-17026.
Overview of the Office of the Inspector General
The Office of the Inspector General (OIG) is comprised of our Office of Investigations (OI), Office of Audit (OA), Office of the Chief Counsel to the Inspector General (OCCIG), and Office of Resource Management (ORM). To ensure compliance with policies and procedures, internal controls, and professional standards, we also have a comprehensive Professional Responsibility and Quality Assurance program.
Office of Audit
OA conducts and/or supervises financial and performance audits of the Social Security Administration's (SSA) programs and operations and makes recommendations to ensure program objectives are achieved effectively and efficiently. Financial audits assess whether SSA's financial statements fairly present SSA's financial position, results of operations, and cash flow. Performance audits review the economy, efficiency, and effectiveness of SSA's programs and operations. OA also conducts short-term management and program evaluations and projects on issues of concern to SSA, Congress, and the general public.
Office of Investigations
OI conducts and coordinates investigative activity related to fraud, waste, abuse, and mismanagement in SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, third parties, or SSA employees performing their official duties. This office serves as OIG liaison to the Department of Justice on all matters relating to the investigations of SSA programs and personnel. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.
Office of the Chief Counsel to the Inspector General
OCCIG provides independent legal advice and counsel to the IG on various matters, including statutes, regulations, legislation, and policy directives. OCCIG also advises the IG on investigative procedures and techniques, as well as on legal implications and conclusions to be drawn from audit and investigative material. Finally, OCCIG administers the Civil Monetary Penalty program.
Office of Resource Management
ORM supports OIG by providing information resource management and systems security. ORM also coordinates OIG's budget, procurement, telecommunications, facilities, and human resources. In addition, ORM is the focal point for OIG's strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act of 1993.