Report Summary
Social Security Administration Office of the Inspector General

March 2010

The Social Security Administration's Compliance with Social Security Number Replacement Card Issuance Provisions of the Intelligence Reform and Terrorism Prevention Act of 2004


To determine whether the Social Security Administration (SSA) complied with provisions of the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) (Public Law 108-458), which set limits on the number of Social Security Number (SSN) replacement cards that can be issued.


On December 17, 2004, the President signed IRTPA into law. Section 7213(a) of IRTPA mandates that SSA restrict the issuance of multiple replacement SSN cards to any individual to 3 per year and 10 for lifetime. Replacement cards provided for certain reasons, such as a legal name change or legend change on a previously issued card, are not counted toward the annual or lifetime limits. SSA also created certain exceptions for the release of an SSN replacement card to an individual who has already reached his or her annual or lifetime limit.

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Our Findings

Twenty-nine (58 percent) of the 50 individuals in our random sample received 4 or 5 SSN replacement cards in 1 year even though they did not have a valid exclusion or exception for the additional cards. They received additional replacement cards beyond their annual limit because (1) SSA's systems detected a change in the type of evidence submitted to obtain an SSN card as an allowable legend change exclusion or (2) SSA issued replacement cards beyond the time limit permitted under the non-receipt exception. Projecting this finding to the population, we estimate that SSA erroneously issued SSN replacement cards to 947 individuals after they reached their annual limit. We also identified 17 individuals who received either 6 or more cards in a year or 4 or more cards during each of 2 calendar years. We determined that 12 (70 percent) of these 17 individuals received 1 or more replacement SSN cards in error.

Our Recommendations

We recommend that SSA:

1.  Ensure its systems allow legend change exclusions to IRTPA annual and lifetime limits only when a restrictive legend on the face of an SSN card has been changed or removed; and    

2.  Ensure its systems only allow non-receipt exceptions to IRTPA annual and lifetime limits for non-receipt claims that occur within 45 days of the previous request for an SSN replacement card.  In the rare instances where a valid justification for allowing a non-receipt claim beyond 45 days of the previous request exists, ensure that the justification is documented within SSA’s systems.  (For example, SSA could use a two-personal identification number process requiring management personnel to approve such transactions.)

SSA agreed with the recommendations.