SOCIAL SECURITY ADMINISTRATION
OFFICES' COMPLIANCE WITH
POLICIES AND PROCEDURES
NONCITIZEN SOCIAL SECURITY
We improve SSA programs and operations and protect them against fraud, waste, and abuse by conducting independent and objective audits, evaluations, and investigations. We provide timely, useful, and reliable information and advice to Administration officials, the 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.
By conducting independent and objective audits, investigations, and evaluations,
we are agents of positive change striving for continuous improvement in the
Social Security Administration's programs, operations, and management and in
our own office.
Date: August 30, 2004
To: The Commissioner
From: Acting Inspector General
Subject: Field Offices' Compliance with Policies and Procedures When Processing Noncitizen Social Security Number Applications (A-08-04-14005)
Our objective was to evaluate the Social Security Administration's (SSA) compliance with policies and procedures when processing noncitizen Social Security number (SSN) applications at field offices (FO).
Noncitizens can apply for an SSN at one of SSA's 1,300 FOs around the country. When a noncitizen applies for an original SSN, he or she must complete, sign and submit a Form SS-5, Application for a Social Security Card, to SSA and provide acceptable documentary evidence of (1) age, (2) identity, and (3) work authorized lawful alien status and/or a valid nonwork reason. About three out of every four applications for original SSNs at FOs are from noncitizens. In Fiscal Year 2003, SSA assigned about 1.2 million original SSNs to noncitizens who applied at FOs. Appendix B provides a detailed description of how SSA assigns original SSNs to noncitizens.
Because of SSN integrity concerns, SSA reevaluated its policies and procedures for assigning SSNs to noncitizens. Accordingly, FO personnel now verify immigration documents with the Department of Homeland Security (DHS) and/or the Department of State (State) before SSN assignment. In addition, FO personnel record a description of noncitizens' immigration documents and the verification of these documents on the SSN application. This information serves as an audit trail by documenting FO actions taken during SSN application processing.
To accomplish our objective, we reviewed SSA policies and procedures for assigning original SSNs to noncitizens. To evaluate FO compliance with these policies and procedures, we identified a population of 106,675 noncitizens to whom SSA assigned original SSNs in March 2003 based on applications processed at FOs. We then randomly selected and reviewed a sample of 300 SSNs. We also visited 6 FOs in 3 of SSA's 10 regions to meet with management and staff and observe personnel processing SSN applications. Appendix C includes a detailed description of our scope, methodology and sample appraisal.
RESULTS OF REVIEW
Although SSA has instituted numerous policies and procedures designed to prevent
improper SSN assignment, they can only be effective if personnel processing
SSN applications comply with the controls. We estimate that FO personnel did
not fully comply with policies and procedures in about 30 percent of the noncitizen
SSN applications they processed during March 2003. The most common occurrence
of noncompliance was FO personnel's failure to document the verification of
immigration status with DHS. In addition, based on our observations during FO
visits, personnel did not consistently use black lights to verify the authenticity
of immigration documents presented by noncitizens. Although our review did not
identify any noncitizens who inappropriately obtained an SSN, we are concerned
that failure to comply with policies and procedures may increase the Agency's
risk of exposure to improper SSN assignment and misuse, and identity theft.
To help ensure FO compliance, we believe SSA should consider enhancing controls
within the Modernized Enumeration System (MES) that will prevent SSN assignment
when personnel have not adhered to the controls specified in SSA's policies
FIELD OFFICE PERSONNEL DID NOT FULLY COMPLY WITH POLICIES AND PROCEDURES WHEN PROCESSING NONCITIZEN SOCIAL SECURITY NUMBER APPLICATIONS
We estimate FOs did not fully comply with SSA policies and procedures when processing over 31,000 SSN applications for noncitizens in March 2003. This figure represents about 30 percent of the 106,675 original SSNs the Agency assigned to noncitizens who applied at FOs during this period.
Figure 1: Estimated Percentage of FO Compliance with Policies and Procedures When Processing Noncitizen SSN Applications
TYPES OF NONCOMPLIANCE
The most common occurrences of FO personnel's noncompliance with policies and
procedures were failure to record on the SSN application: (1) evidence of verification
of immigration status with DHS; (2) descriptions of at least two documents establishing
the applicant's age, identity, and work-authorized lawful alien status; and
(3) descriptions of the specific DHS documents reviewed. Table 1 shows the specific
occurrences of noncompliance we identified.
Table 1: Specific Occurrences of Noncompliance in Sampled Items
Characteristics Identified Number of occurrences
Verification of immigration status with DHS not recorded 36
Minimum two evidentiary documents not recorded 16
DHS document not recorded 14
SSA employee signed SSN application before DHS verification 13
Student documentation not recorded 11
DHS class of admission not recorded (nonimmigrants) 7
Identification for individual applying on behalf of another not recorded 5
Country of passport not recorded 4
Material discrepancy between DHS and SSN application information 4
Immigration (Alien or Admission) number not recorded 4
SSA employee did not date the SSN application 4
Alien or Admission number was incorrect 2
SSA employee did not sign the SSN application 2
Number of occurrences identified 122
Multiple occurrences identified (more than one occurrence per case) 33
Number of SSNs in sample not in compliance with policies and procedures 89
Percentage of noncompliance cases to sample (89/300) 30%
We believe the following instances of FO personnel's noncompliance with policies and procedures illustrate SSA's risk of exposure to improper SSN assignment and misuse.
· An FO employee did not record on the SSN application verification
of the applicant's immigration status with DHS or the applicant's nonimmigrant
class of admission. We determined from DHS records that the noncitizen was a
student. However, the FO employee did not record evidence of the applicant's
full-time school attendance and authorization to work. Because the employee
did not comply with policies and procedures, SSA did not have documented assurance
that this noncitizen was actually in school and/or authorized to work.
· An FO employee did not record on the SSN application verification of a child's immigration status with DHS or the identification document for the child's father (who applied on behalf of the child). In addition, there were material discrepancies between the SSN application and DHS records regarding the child's first name and date of birth (a 6-year discrepancy). Moreover, the FO employee signed the SSN application before DHS verification. Because the employee did not comply with policies and procedures, SSA did not have documented assurance that it assigned the SSN to the proper individual.
FIELD OFFICE PERSONNEL DID NOT ALWAYS USE BLACK LIGHTS TO ENSURE THE AUTHENTICITY OF IMMIGRATION DOCUMENTS
Through observations at the six FOs visited, we determined that SSA personnel did not always use black lights to verify the authenticity of immigration documents. Our observation of the processing of 60 noncitizen SSN applications showed that FO personnel did not use a black light in 23 (38 percent) instances. SSA procedures require FO personnel to view documents under a black light to help detect fraudulent DHS documents. FO personnel view documents under a black light to ensure conformance to special identification features. Although SSA policy requires FO personnel to verify the immigration and identity status of all noncitizens with DHS, this process does not ensure that the documents themselves are valid. For example, an individual could present a counterfeit document containing the same information as a legitimate one and FO personnel may not detect this deception without a black light examination. We believe it is important for FO personnel to use black lights in conjunction with DHS verification to prevent improper SSN assignment.
OPPORTUNITY TO HELP ENSURE FIELD OFFICE COMPLIANCE WITH POLICIES AND PROCEDURES
When FO personnel do not fully comply with all policies and procedures for processing noncitizen SSN applications, the Agency increases its risk of improper SSN assignment and misuse. While SSA's MES allows FO personnel to record evidence reviewed and accepted, as required by policies and procedures, it does not prevent SSN assignment when personnel do not enter this information into the system. For example, although policies and procedures require FO personnel to record, on the SSN application, a description of the immigration documents presented and reviewed and DHS verification, MES does not prevent SSN assignment if they fail to record this information.
To help ensure FO compliance with policies and procedures, we believe SSA should consider MES enhancements that would prevent SSN assignment when FO personnel do not comply with the Agency's policies and procedures. SSA could incorporate separate and distinct data fields into MES that would capture specific evidence reviewed and accepted. That is, SSA could change the MES evidence field from a free-form entry format to one requiring discrete entries (for example, a noncitizen's immigration number and class of admission, and specific immigration documents reviewed and verified with DHS). We believe MES controls should prevent SSN assignment when FO personnel do not enter such information. Such controls would assist FO personnel through the SSN application process and help prevent improper SSN assignment.
Management and staff at all six FOs we visited agreed that MES enhancements, as discussed above, would assist personnel in complying with policies and procedures. SSA has discussed plans to modify MES to capture more discrete information about the evidence submitted during the SSN application process. We understand that such modifications must be considered as part of the Agency's information technology prioritization process. Nevertheless, we encourage the Agency to begin the systems planning process for MES enhancements.
CONCLUSION AND RECOMMENDATIONS
Despite SSA's safeguards to prevent improper SSN assignment to noncitizens, the Agency remains at risk to such activity when FO personnel do not fully comply with policies and procedures. We recognize SSA's efforts can never fully eliminate the potential that noncitizens may inappropriately acquire and misuse SSNs. Nonetheless, we believe SSA has a stewardship responsibility to ensure that FO personnel comply with all policies and procedures. We believe SSA would benefit by taking additional steps to strengthen SSN integrity and reduce its risk of exposure to improper SSN assignment and misuse, and identity theft.
Accordingly, we recommend SSA:
1. Reemphasize to FO personnel the importance of following all policies and procedures, including the use of black lights to detect counterfeit documents, when processing SSN applications from noncitizens.
2. Conduct periodic studies to assess FO compliance with policies and procedures for processing noncitizen SSN applications and take corrective action as needed.
3. Consider MES enhancements that would prevent SSN assignment to noncitzens when FO personnel do not comply with policies and procedures.
AGENCY COMMENTS AND OIG RESPONSE
SSA agreed with our recommendations. The Agency also provided technical comments that we considered and incorporated, where appropriate. The full text of SSA's comments is included in Appendix D. We commend SSA for its efforts to strengthen the integrity of the SSN. We especially acknowledge the New York Region's recently developed MES Workload Management Information application and SS-5 Assistant. We believe both of these applications will serve as valuable tools to ensure compliance with SSA enumeration policies and procedures.
Patrick P. O'Carroll, Jr.
APPENDIX A - Acronyms
APPENDIX B - How the Social Security Administration Assigns Original Social Security Numbers to Noncitizens APPENDIX C - Scope, Methodology, and Sample Appraisal
APPENDIX D - Agency Comments
APPENDIX E - OIG Contacts and Staff Acknowledgments
ASVI Alien Status Verification Index
DHS Department of Homeland Security
State Department of State
EAE Enumeration at Entry
FO Field Office
GAO Government Accountability Office
MES Modernized Enumeration System
OIG Office of the Inspector General
POMS Program Operations Manual System
SSA Social Security Administration
SSN Social Security number
How the Social Security Administration Assigns Original Social Security Numbers to Noncitizens
When a noncitizen applies for an original Social Security number (SSN), he
or she must complete, sign and submit Form SS-5, Application for a Social Security
Card, to the Social Security Administration (SSA) and provide acceptable documentary
evidence of (1) age, (2) identity, and (3) work authorized lawful alien status
and/or a valid nonwork reason.
Field office (FO) personnel verify documents through (1) visual inspection, including the use of a black light where appropriate and (2) verification with the Department of Homeland Security (DHS), either on-line or manually. If documents do not appear valid, then FOs send Form G-845, Document Verification Request, along with photocopies of the applicant-provided documents, to DHS. If documents appear valid, FO personnel query DHS' Alien Status Verification Index (ASVI) database to verify the immigration and work status of noncitizens. If ASVI information is not available, FO personnel send Form G-845 to DHS. In addition, FO personnel record noncitizens' immigration documents and the verification of these documents (either the ASVI verification number or annotation of "G-845 verified") on the SSN application.
FO personnel enter SSN information into SSA's Modernized Enumeration System (MES). SSN applications awaiting verification of DHS immigration status are coded with an "S" for suspect. After determining the validity of supporting evidentiary documents, FO personnel sign and date the SSN application and clear the application in MES. Once certified and cleared, MES performs numerous automated edits to validate certain applicant information. If the application passes these edits, SSA systems assign an SSN, issue an SSN card, and establish a record in SSA's information systems.
Description of Evidentiary Documents
Along with an SSN application, noncitizens must present two documents that establish age, identity, and work authorized lawful alien status or a valid nonwork reason for an SSN. If the DHS document is used to establish noncitizen status and age, the noncitizen must provide another document, such as a passport or driver's license, to establish identity. An individual signing the SSN application on behalf of another (for example, a parent for his/her child) must establish his/her own identity.
DHS issues numerous documents that indicate the status and class of noncitizens. Following is a description of the general evidence requirements (not all-inclusive) submitted with original SSN applications.
Lawfully Admitted for Permanent Residence are lawful immigrants who are residing permanently in the United States with the authorization of DHS. Acceptable evidence of this status includes the I-551, Alien Registration Receipt Card, commonly known as the "Green Card," and I 688, Temporary Resident Card.
Nonimmigrants are temporary lawful residents to whom DHS grants limited stay in the United States for a specific purpose, such as foreign Government officials, visitors, and students. DHS issues an I-94 Arrival/Departure Record to all documented noncitizens. DHS also issues employment authorization documents to certain nonimmigrants as evidence of their authorization to work in the United States. SSA has additional SSN documentation requirements for certain classes of nonimmigrants. For example, to be eligible for an SSN, an F 1 post secondary student must provide, in addition to evidence of age and identity, an I-20 ID (Student) Copy, Certificate of Eligibility for Nonimmigrant (F-1) Student Status, from an accredited school, a current I-94, and evidence of authorization to work on-campus and full-time school attendance.
Asylees, refugees, and parolees come to the United States because of persecution
or emergency conditions. Form I-94, with the proper annotations, is acceptable
evidence of aslyee, refugee or parolee status. In cases when such individuals
have no documentation other than his/her DHS document, SSA will accept such
documentation (an exception to the two document requirement).
Scope, Methodology, and Sample Appraisal
We obtained a data extract from the Social Security Administration's (SSA) Modernized Enumeration System (MES) Transaction History File for March 2003. From this extract, we identified a population of 106,675 noncitizens to whom SSA assigned original Social Security numbers (SSN) for SSN applications processed by field offices (FO). From this population, we randomly selected and reviewed a sample of 300 SSNs. For each of the sampled SSNs, we
· requested from SSA a microfiche copy of Form SS-5, Application for a Social Security Card, including all information recorded at the bottom of the form;
· determined whether SSA personnel followed applicable policies and procedures when processing the SSN application; and
· independently verified the applicant's noncitizen immigration status
Department of Homeland Security (DHS). We verified the Alien registration number or Admission number via DHS' Alien Status Verification Index (ASVI) database. Additionally, we manually verified with DHS those records where ASVI displayed exceptions or FO personnel failed to record an evidence description on the SSN application. We did not conduct an independent assessment of the quality of DHS' records.
As part of this audit, we also visited six SSA FOs. To ensure geographic diversity, we selected FOs in 3 of SSA's 10 regions. Within each region, we first selected an FO that issued a large number of original cards to noncitizens during our audit period. We then selected another FO in the same location to supplement our work. At each FO, we met with management and staff to obtain their views on the Agency's policies, procedures, and practices for processing noncitizen SSN applications. We observed personnel processing 60 original noncitizen SSN applications.
The SSA entity reviewed was the Office of the Deputy Commissioner for Operations.
We relied primarily on MES to complete our review, and determined that the MES
data used in the report is sufficiently reliable given the audit objective and
use of the data.
We conducted our work from May 2003 through February 2004 in accordance with generally accepted government auditing standards.
Table 1 shows our sample size, results, and appraisal.
Table 1: Results and Projection
SAMPLE ATTRIBUTE APPRAISAL
Total population of original SSNs assigned to noncitizens from SSN applications processed at FOs 106,675
Sample size 300
Number of instances in sample where FO personnel did not comply with policy
and procedures 89
Estimate of instances in population where FO personnel did not comply with policy and procedures 31,647
Projection lower limit 27,023
Projection upper limit 36,593
Projection made at the 90-percent confidence level.
Date: July 30, 2004
To: Patrick P. O'Carroll, Jr.
Acting Inspector General
From: Larry W. Dye
Chief of Staff
Subject: Office of the Inspector General (OIG) Draft Report "Field Offices' (FO) Compliance with Policies and Procedures When Processing Noncitizen Social Security Number (SSN) Applications" (A-08-04-14005)--INFORMATION
We appreciate OIG's efforts in conducting this review. Our comments on the draft report content and recommendations are attached.
Please let me know if you have any questions. Staff inquiries may be directed
Candace Skurnik, Director, Audit Management and Liaison Staff, at extension 54636.
COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL (OIG) DRAFT REPORT "FIELD OFFICES' (FO) COMPLIANCE WITH POLICIES AND PROCEDURES WHEN PROCESSING NONCITIZEN SOCIAL SECURITY NUMBER (SSN) APPLICATIONS" (A-08-04-14005)
Thank you for the opportunity to comment on the draft report. We are pleased the report acknowledges our efforts to improve the accuracy of SSN applications and that the review found no instances where noncitizens inappropriately obtained an SSN. Furthermore, we realize this is a vulnerable area for the Agency and are continuing our efforts to develop methods to ensure SSNs are assigned only to those individuals that are eligible to receive them. Our comments to the specific recommendations and some technical comments are provided below.
SSA should reemphasize to FO personnel the importance of following all policies and procedures, including the use of black lights to detect counterfeit documents, when processing SSN applications from noncitizens.
We agree and have taken some actions to strengthen the integrity of the processes that we use to assign SSNs. In April 2004, we conducted an Interactive Video Training session focusing on the identification of fraudulent documents, including the use of black lights to verify the various check points on the Department of Homeland Security's (DHS) and other documents. We have made these procedures available online so they can be accessed easily by interviewing employees. We are currently revising Program Operations Manual System (POMS) instructions to clearly stress these procedures and policies in reviewing immigration documents. In addition, on July 12, 2004, we released a reminder to FO personnel emphasizing the need to utilize all tools available to the field for detecting fraudulent documents.
SSA should conduct periodic studies to assess FO compliance with policies and procedures for processing noncitizen SSN applications and take corrective action as needed.
We agree and have already taken steps to implement the recommended studies. Specifically, as of October 2002, all SSA regional offices had plans in place to monitor FO compliance with the collateral verification requirements, such as reviewing samples of completed SS-5 applications. We have also included an assessment of FO staff compliance with verification requirements as part of our ongoing enumeration quality reviews. The published findings from these reviews are currently limited to addressing those enumeration failures classified as "critical errors" (a misassigned SSN that is either assignment of an SSN that belongs to someone else or a multiple SSN that is not cross-referred on the existing records) or "major errors" (errors that can result in an additional or incorrect action in subsequent enumeration transactions or claims actions because information on the applicant's record is incorrect or incomplete). Based on the results of this review, we will provide an analysis and assessment of documentation failures in future reports. Finally, we continue to monitor compliance through our Comprehensive Integrity Review Process program and develop process improvements to address any identified weaknesses or errors.
In addition to these ongoing reviews, the recently developed New York Region's Modernized Enumeration System (MES) Workload Management Information application provides information on SS-5 applications from foreign-born individuals who were assigned SSNs in one day, but whose immigration documents were subject to verification; US-born individuals over the age of one who were assigned SSNs in one day, but whose birth records were subject to verification; and individuals who reside outside the State or service area of the processing field office. The MES application serves as a valuable resource for managers to identify: 1) employees who may not be following current collateral verification procedures; 2) local weaknesses in the enumeration process; and 3) any SS-5 workloads that appear to be unusual for particular offices.
SSA should consider MES enhancements that would prevent SSN assignment to noncitzens when FO personnel do not comply with policies and procedures.
We agree. We are considering certain changes as suggested to the MES as part of our Long Term MES Enhancements Initiative. We will consider revising the evidence collection fields in MES to collect evidentiary data in specific fields, however, any identified modifications will have to be considered as part of our Information Technology prioritization process.
In the interim, the New York Region has developed a front-end software program to improve FO compliance with the policies and procedures for processing SS-5 applications. The SS-5 Assistant application assists FOs to comply with the collateral verification procedures by providing greater control over, and improving the accuracy of, SSN applications filed by noncitizens. We expect to release Version 2.0 of the SS-5 Assistant in early fiscal year 2005. The new features of this version will: 1) serve as the front-end input system that will collect all necessary data in mandatory fields and propagate it to the current MES screens; 2) collect data in an intelligent manner as a data-driven system that will understand the policy requirements and facilitate capturing the mandated information from the user, include drop-down selections, and ensure the character lengths for certain fields are appropriate; and 3) automatically query the Systematic Alien Verification for Entitlements system of DHS for the user at the time the application is being entered (as the interface will require that verification is received) before permitting processing of the SS-5 application.
We anticipate that the implementation of Release 2 of the SS-5 Assistant application
will eliminate the noncompliance situations identified in the report.
OIG Contacts and Staff Acknowledgments
Kimberly A. Byrd, Director, (205) 801-1605
Jeff Pounds, Audit Manager, (205) 801-1606
In addition to those named above:
Charles Lober, Senior Auditor
Ellen Justice, Auditor
Susan Phillips, Auditor
Brennan Kraje, Statistician
Annette DeRito, Writer-Editor
For additional copies of this report, please visit our web site at www.ssa.gov/oig
or contact the Office of the Inspector General's Public Affairs Specialist at
(410) 966-1375. Refer to Common Identification Number A-08-04-14005.
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 Executive Operations (OEO). 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 Executive Operations
OEO supports OIG by providing information resource management and systems security. OEO also coordinates OIG's budget, procurement, telecommunications, facilities, and human resources. In addition, OEO 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.