June 18, 2002

The Honorable Gil Gutknecht
House of Representatives
Washington, D.C. 20515

Dear Mr. Gutknecht:

In response to your March 1, 2002 letter, I am pleased to provide you the enclosed report regarding the processing of Social Security number (SSN) applications at the Rochester, Minnesota, field office.

Our objective was to determine whether the Rochester, Minnesota, field office was properly enumerating noncitizens who applied for SSNs. To achieve our objective, we visited the Rochester field office to review its controls for enumerating noncitizens, tested a sample of noncitizen applications, assessed trends in the field office's noncitizen enumeration data, and reviewed prior audit findings related to SSA's enumeration process.

The enclosed report contains information related to our assessment of:

If you have any questions or would like to be briefed on this issue, please call me or have your staff contact Douglas Cunningham, Special Agent at (202) 358-6319.


James G. Huse, Jr.
Inspector General



Noncitizen Enumeration at

the Social Security Administration’s Rochester, Minnesota

Field Office


JUNE 2002


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.


Enactment of the 1935 Social Security Act established the Social Security Administration (SSA) and authorized SSA to set up a recordkeeping system. As a result, SSA established the Social Security number (SSN). An individual requesting a SSN must submit an Application for a Social Security Card (Form SS-5) and evidence of age, identity, and U.S. citizenship or noncitizenship status. Additionally, a noncitizen must provide documentation from the Immigration and Naturalization Service (INS) authorizing him or her to work in the United States. (Appendix B provides more detailed information on SSA’s enumeration process and the required evidence.) After an application is processed, the SSN is assigned centrally from SSA’s Headquarters based on the data input from the field office (FO). SSNs are normally assigned within 24 hours after the application is processed, if there are no issues with the application during processing.

In Fiscal Year 2001, SSA issued over 18.4 million original and replacement SSN cards. Approximately 1.5 million of the original SSN cards were issued to noncitizens. In recent audits and investigations, we have shown that SSA has processed SSN applications based on false documentation. Although SSA has implemented several initiatives to address enumeration weaknesses, we believe SSA remains at risk in the enumeration area. Appendix C contains a list of recent SSA initiatives to improve the integrity of the enumeration process.

On March 1, 2002, Congressman Gutknecht, issued a letter to the Inspector General of SSA. In that letter, Congressman Gutknecht requested that the Office of the Inspector General (OIG) audit the SSA FO in Rochester, Minnesota. Congressman Gutknecht specifically requested an audit of the noncitizen enumeration process at the FO. In response to the Congressman’s request, we conducted an audit to determine whether the Rochester FO was properly enumerating noncitizens who applied for SSNs. To achieve our objective, we visited the Rochester FO to review its controls for enumerating noncitizens, tested a sample of noncitizen applications, assessed trends in the FO's noncitizen enumeration data, and reviewed prior OIG audit findings related to SSA's enumeration process. We sampled 50 SSN applications from a population of 1,071 noncitizen original applications processed by the Rochester FO between January 2001 and March 2002.

Results of Review

In 49 of the 50 noncitizen SSN applications we reviewed, the Rochester FO complied with existing SSA policies and procedures prior to assigning the SSNs. However, in 2 of these 49 cases, the required verification was insufficient to detect invalid immigration documents. SSA, as a whole, needs to improve its procedures for verifying noncitizen evidentiary documents, as we have reported to SSA in the preliminary results of a separate nationwide audit of SSA's procedures in this area.

Verification of Noncitizen Evidentiary Documents

Our review of a sample of noncitizen SSN applications processed at the Rochester FO indicated 4 percent of the applications involved invalid immigration documents. We verified with the INS the evidence submitted for 50 randomly selected noncitizen SSN applications. Of those 50 applications, we identified 2 instances where the INS could not verify the evidentiary documents submitted by the applicants. As a result, these SSNs should not have been assigned. We referred these two cases to our Office of Investigations.

The two cases involved individuals from South Africa and Ghana who were enumerated with invalid immigration documents. A review of the Form SS-5 applications indicated that both individuals presented passports and INS immigration documents claiming they were issued Diversity Visas by the Department of State. Their applications showed no evidence that FO staff attempted to verify the authenticity of the immigration information before SSA issued the SSNs. However, SSA's policies and procedures did not require such verification when the staff believed the underlying documents were valid. We discuss SSA’s procedures in more detail in Appendix B.

The 4-percent error rate in our sample at the Rochester FO is lower than the error rate we found in an ongoing nationwide audit of SSA's noncitizen enumeration process.4 Preliminary results of our nationwide audit of SSA's procedures for verifying documents submitted with SSN applications, indicate that approximately 96,000 (8 percent) of the 1.2 million original SSNs assigned to noncitizens in Calendar Year 2000 may have been based on invalid immigration documents.

Adherence to SSA's Procedures for Reviewing Evidentiary Documents

In our review of a sample of noncitizen applications, we determined that, while most of the evidentiary documentation provided was appropriately reviewed and verified, the Rochester FO did not always adhere to SSA's policies and procedures. We found one instance out of 50 where FO staff did not properly verify immigration documents related to an application from an individual seeking asylum.

SSA's policies and procedures require that FO staff verify noncitizen evidentiary documentation (1) through visual inspection, including the use of a black light where appropriate, and/or (2) with the INS through online or manual verification. However, verification of evidentiary documentation with the INS is mandated in certain cases.

Of our 50 sampled noncitizen applications, SSA’s policies and procedures required INS verification of documentation for only 4 of the noncitizen applications—3 asylum applicants enumerated after April 2001 and 1 refugee enumerated after January 2002.

The refugee application was processed according to SSA's policies and procedures, but one of the three applications from individuals seeking asylum was not. We found no indications that SSA staff properly verified documents related to one application for an individual seeking asylum. This application related to a Somalian who entered the country in July 2001 and was issued a SSN by the Rochester FO in October 2001. While FO staff marked "asylum" on the application and performed some of the required verification steps before issuing the SSN card—such as verifying the document online with INS—further verification was required. According to SSA’s procedures, FO staff should have also contacted the Executive Office of Immigration Review to determine the status of the individual's application for asylum and then verified the document with the INS. In our later verification with INS, we found the individual's documentation was valid. Nonetheless, FO staff should have performed and documented this required step to ensure the validity of the underlying immigration documents before issuing the SSN.

Noncitizen SSN Issuance Trends at the Rochester FO

Our review of data related to all noncitizen SSNs issued by the Rochester FO indicates the office's issuance rate for noncitizen SSNs was above average for SSA’s Chicago Region. However, Rochester serves a diverse population—including a number of noncitizens relocated by the Department of State—which could account for the above average number of noncitizen SSNs issued.

We compared the Rochester FO noncitizen SSN issuance rate to the rate for all 224 FOs in the Chicago Region for a 15-month period. As a percent of its overall workload, the Rochester FO's noncitizen SSNs represented about 47 percent more of the office's workload than the average FO in the region (see Table 1). The number of noncitizen SSN cards issued was 1,725 compared to the regional average of 1,392 noncitizen SSN cards. However, this variance may be related to the diversity of the population the Rochester FO serves.

Table 1: Rochester FO and Chicago Region Issuance of Noncitizen SSNs

Social Security Cards Issued

All Cards (Citizen and Noncitizen)

Noncitizen Cards

Noncitizen Percent of All Cards

Rochester FO




Chicago Regional Average




Percent Above Regional Average


Our analysis indicated that the Rochester FO serves a demographically diverse community that could lead to a higher rate of noncitizen enumeration than other FOs within the Chicago Region. See Appendix D for the entry status and country of origin related to the 50 noncitizens in our sample. Rochester is Minnesota’s fifth largest city. According to a recent Department of Housing and Urban Development community profile, "Rochester has become a haven for Arabic and Asian immigrants as well as refugees from Somalia, the Sudan and Bosnia…." Another report from the Department of State noted that in FY 2000, 74 percent of newly arrived refugees resettled in 15 States, with Minnesota representing about 4 percent of this resettled group. In addition, SSA FO staff noted that a number of local institutions—such as the Mayo Clinic and an IBM plant—also attract workers from other countries.

Minnesota's State Demographic Center has also noted that Minnesota has a strong economy and "…many low-paying jobs in food processing, meat and poultry packing, agriculture and hospital industry." Some of these same industries are located in the Rochester area. However, the report notes that many young Minnesotans are not attracted to such jobs. As a result, recent immigrants—and even illegal aliens—can find work in these industries. This same report noted that the INS estimates 25,000 illegal aliens reside in Minnesota, while a separate Hispanic advocacy group estimates that Minnesota contains between 18,000 and 28,000 undocumented Hispanic workers.


In 49 of the 50 noncitizen SSN applications we reviewed, the Rochester FO complied with existing SSA policies and procedures prior to assigning the SSNs. However, in 2 of these 49 cases, the required verification was insufficient to detect invalid immigration documents. SSA, as a whole, needs to improve its procedures for verifying noncitizen evidentiary documents, as we have reported to SSA in the preliminary results of a separate nationwide audit of SSA's procedures in this area.

Rochester, like many U.S. cities, faces an influx of noncitizens who will need to be enumerated to participate in the U.S. economy. Whether SSA is dealing with a citizen or a noncitizen, the enumeration process needs to be grounded in valid evidentiary documentation. In the case of noncitizen enumeration, the best way to ensure proper enumeration is to verify all documents noncitizens provide before issuing SSNs, regardless of the time delay required for the individual to obtain a SSN. While SSA should strive for timely customer service, this must be balanced with the integrity of the enumeration process and Homeland Security concerns.

Since we are completing a separate nationwide review of SSA’s procedures for verifying evidentiary documents—and we expect to make recommendations to address the Agency as a whole in that report—we are not making recommendations in this report.


Appendix A – Acronyms

Appendix B – Enumeration Process

Appendix C – Enumeration Task Force

Appendix D – Characteristics of 50 Noncitizens

Appendix E – Scope and Methodology

Appendix F – Prior Office of the Inspector General Reports

Appendix G – OIG Contacts and Staff Acknowledgements

Appendix A



Alien Status Verification Index


Department of State


Executive Office for Immigration Review


Field Office


Immigration and Naturalization Service


Modernized Enumeration System


Office of the Inspector General


Program Operations Manual System


Refugee Data Center


Systematic Alien Verification for Entitlement

Form SS-5

Application for a Social Security Card


Social Security Administration


Social Security Number

Appendix B

Enumeration Process

In Fiscal Year 2001, the Social Security Administration (SSA) issued over 18.4 million original and replacement Social Security number (SSN) cards. Approximately 1.5 million of the original SSNs were issued to noncitizens. When SSA assigns a SSN or issues a Social Security card, it is critical that SSA independently verifies the authenticity of the birth records, immigration records, and other identification documents the applicant presented.

How SSA Assigns Original SSNs

When an individual applies for an original SSN, he or she must first complete, sign and submit an Application for a Social Security Card (Form SS-5) to a SSA field office (FO). SSA requires the applicant to provide acceptable documentary evidence of (1) age, (2) identity, and (3) U.S. citizenship or lawful alien status. Upon submission, the FO employee enters applicant information and a description of the evidence presented into the Modernized Enumeration System (MES).

If, after reviewing the application and supporting evidentiary documentation, the FO employee believes the documents and information are valid, he or she certifies the application for overnight validation. Once entered and certified in MES, the SSN application undergoes numerous automated edits. For example, SSA’s programs compare the applicant's name and date of birth with existing SSN records to ensure the Agency has not previously assigned a SSN to the individual. If the application passes all of these edits, MES issues a SSN card.

Evidentiary Documents Submitted

Evidence of Age: To verify an applicant's age, SSA requests a birth certificate issued by a State or local Bureau of Vital Statistics, which was established before the applicant reached 5 years of age. Common examples of documents used to establish a noncitizen's age are a foreign birth certificate, passport, or Immigration and Naturalization Service (INS) record.

Evidence of Identity: An identity document submitted as evidence must be recently issued and provide information so FO personnel can compare its contents with Form SS-5 data and/or with the applicant's physical appearance. Acceptable identity documents are driver's licenses, passports, school identification cards, marriage or divorce certificates, or military records. For foreign-born applicants, SSA accepts as evidence of identity an INS document—submitted as evidence of age—only if the applicant has no other document of probative value for identity and is a refugee, parolee, or asylum applicant.

Evidence of Work Authorized or Lawful Alien Status: Applicants who allege a foreign place of birth and/or who are not U.S. citizens must submit evidence supporting either lawful alien status and/or the INS-granted work authorization. INS issues numerous documents that indicate the status and class of aliens. For example, the Form I-551, Permanent Resident Card, establishes the alien as lawfully admitted for permanent residence.

An example of INS documents issued to support the lawful alien status for a student are the Form I-94, Arrival/Departure Record and the Form I-20, Certificate for Eligibility for Nonimmigrant Student Status, which show the "F-1" (student) class of admission. Also, INS issues numerous documents acceptable as evidence of employment authorization. Some examples of documents that establish work authorization for nonimmigrants are the Form I-94 that has the alien's classification displayed; the "employment authorization" that is shown on a Form I-94 for a refugee; the annotation on the Form I-20 for certain F-1 students; or the INS Employment Authorization Document.


SSA has a number of electronic and paper interfaces with INS to verify evidentiary documents provided during the application process. The use of a particular INS process relates to whether an individual is a refugee, permanent resident alien, parolee, seeking asylum, or another type of visa holder. SSA's policies and procedures require that FO staff verify noncitizen evidentiary documentation (1) through visual inspection, including use of a black light where appropriate, and/or (2) with the INS through online or manual verification. Verification of evidentiary documentation with the INS is mandated in certain cases.

Below are definitions of the primary verification interfaces.

Systematic Alien Verification for Entitlements (SAVE): The SAVE program provides a method of document verification within an automated environment. The Alien Status Verification Index (ASVI) data base, part of SAVE, contains certain biographic information and current status on over 25 million aliens. Each FO must verify INS documents submitted via the ASVI system. With this data base, FO staff can enter an alien's registration number and determine whether the information alleged by the applicant is valid. If ASVI cannot verify the document, a manual verification is required via the additional processes described below.

Executive Office for Immigration Review (EOIR): The EOIR is an INS case status telephone line available to SSA’s FO personnel to determine whether an applicant has been granted asylum or there is an appeal pending on the particular case. As of April 2001, INS considers aliens granted asylum to have permanent employment authorization and requests that SSA treat them as permanent resident aliens for enumeration purposes.

Direct INS Verification: A Document Verification Request (Form G-845) is part of the manual verification process required by SAVE. This method is used to validate alien documentation after primary verification, when appropriate, or in those situations when verification through SAVE is not applicable. This procedure, conducted by INS, consists of checking other indices available only to INS and returning a response to SSA within 20 days of receipt.

Refugee Data Center: SSA has entered into an agreement with the Department of State (DoS) to verify a refugee's status with the DoS’ Refugee Data Center (RDC) when SSA cannot verify refugee status by a SAVE query. Refugees often apply for SSNs within days of arriving in the United States and before data is available online in an INS data base. Since RDC data accurately reflects refugee information—including the information that INS admitted the person as a refugee—SSA now requires verification of refugee status by DoS when verification is not available via SAVE. The RDC data base also includes some biographical information as well as other data about refugees that may help to confirm an applicant's identity. SSA and DoS have established a procedure for FO staff to fax verification requests directly to the RDC. RDC staff will respond to SSA’s requests within 1 business day by faxing printouts of the information contained in RDC records. The RDC staff will also respond to telephone requests in emergency situations.

Appendix C

Enumeration Task Force

Recognizing the Social Security numbers' (SSN) importance in noncitizens' assimilation in U.S. society, the Social Security Administration (SSA) established an Enumeration Task Force to examine and establish policy that would strengthen the Agency's procedures. On November 1, 2001, SSA's then-Acting Commissioner issued a memorandum to SSA executive staff announcing seven reforms the Enumeration Task Force recommended and the Agency would implement to address enumeration-related vulnerabilities. In that memorandum, the then Acting Commissioner committed that SSA would institute these reforms by February 2002. Additionally, the Enumeration Task Force added another planned initiative to the list after the November 2001 memorandum, bringing the total short-term projects to eight. SSA has implemented several of these initiatives, while others have been delayed. These initiatives are as follows.

  1. Provide refresher training on enumeration policy and procedures, with emphasis on enumerating noncitizens, for all involved staff.
  2. Convene a joint task force between SSA, the Immigration and Naturalization Service (INS), the Department of State (DoS), and the Office of Refugee Resettlement to resolve issues involving enumeration of noncitizens, including working out procedures for verifying INS documents before SSNs are issued.
  3. Eliminate a driver's license as a reason for issuing a nonwork SSN.
  4. Provide an alternative to giving out a Numident printout for SSN verification.
  5. Lower the age tolerance from age 18 to age 12 for mandatory interview procedures; verify birth records before enumeration for all applicants age 1 and older for original SSNs; and require evidence of identity for all children, regardless of age.
  6. Determine the feasibility of photocopying (or scanning) all documentary evidence submitted with SSN applications.
  7. Change the Modernized Enumeration System to provide an electronic audit trail, regardless of the mode used to process SSN applications.
  8. Implement the SSN Verification System.

Additionally, SSA's Enumeration Task Force recommended that the Agency seek independent verification of all noncitizen documents before assigning SSNs. We believe this action will have a positive impact on preventing the assignment of SSNs based on fraudulent documents. SSA’s current implementation plan is to verify all evidentiary documents in field offices with a low volume of noncitizen applications beginning on July 1, 2002; and in all its field offices nationwide by September 1, 2002. As a result, SSA will continue to issue SSNs to noncitizens without obtaining independent verification of evidentiary documents from the issuing agency for a few more months.

Appendix D

Characteristics of the 50 Noncitizens

Figure D-1 provides the Immigration and Naturalization Service entry status for the 50 noncitizens in our sample. In addition, Table D-1 provides the country of origin for these same noncitizens.

Table D-1: Place of Origin for our Sample of 50 Applicants



Number of Applicants










South Africa






























United Kingdom



North America



El Salvador





South America




Grand Total


Appendix E

Scope and Methodology

To meet our objective, we:

To develop a population of applications for testing, we obtained a data extract from SSA's Modernized Enumeration System (MES) Transaction History File. Our extract included 1,071 noncitizens who applied for original SSNs between January 2001 and March 2002 at SSA’s Rochester FO. From this extract, we sampled 50 SSN applications to determine whether (1) the Immigration and Naturalization Service (INS) could verify the underlying evidentiary documents presented to SSA, and (2) the Rochester FO staff had reviewed the applications in accordance with SSA's policies and procedures.

We also compared the Rochester FO’s enumeration statistics to the Chicago Region's statistics to determine whether enumeration workload trends were consistent with the rest of the region. For this analysis, we reviewed both original and replacement SSN application data for citizens and noncitizens.

Our audit did not include a test of information systems to verify the completeness and accuracy of the MES file. Our work was conducted at the SSA FO in Rochester, Minnesota and in Philadelphia, Pennsylvania. We conducted our field work between April and May 2002. The SSA entity responsible for the maintenance of the MES is the Office of Central Operations within the Office of the Deputy Commissioner of Operations. Our review was conducted in accordance with generally accepted government auditing standards.

Appendix F

Prior Office of the Inspector General Reports

Social Security Administration, Office of the Inspector General Reports Related to Social Security Number Integrity

Name and Common Identification Number

Date Report Issued

Using Social Security Numbers to Commit Fraud (A-08-99-42002)

May 1999

Procedures for Verifying Evidentiary Documents Submitted with Original Social Security Number Applications (A-08-98-41009)

September 2000

Audit of the Enumeration at Birth Program

September 2001

Replacement Social Security Number Cards: Opportunities to Reduce the Risk of Improper Attainment and Misuse (A-08-00-10061)

September 2001

Congressional Response Report: SSN Misuse - A Challenge for the Social Security Administration (A-08-02-22030)

October 2001

Congressional Response Report: Terrorist Misuse of Social Security Numbers

October 2001

Social Security Number Integrity: An Important Link in Homeland Security (A-08-02-22077)

May 2002

Appendix G

OIG Contacts and Staff Acknowledgements

OIG Contacts

Rona Rustigian, Director, Northern Audit Division (617) 565-1819
Walter Bayer, Deputy Director, (215) 597-4080


In addition to those named above:

Francis Trzaska, Auditor
Donna Parris, Auditor
Carol Ann Frost, Computer Specialist

For additional copies of this report, please visit our web site at http://www.socialsecurity.gov/oig or contact the Office of the Inspector General’s Public Affairs Specialist at (410) 966-1375. Refer to Common Identification Number A-03-02-22078.

Overview of the Office of the Inspector General

Office of Audit

The Office of Audit (OA) conducts comprehensive financial and performance audits of the Social Security Administration’s (SSA) programs and makes recommendations to ensure that program objectives are achieved effectively and efficiently. Financial audits, required by the Chief Financial Officers Act of 1990, assess whether SSA’s financial statements fairly present the Agency’s financial position, results of operations, and cash flow. Performance audits review the economy, efficiency, and effectiveness of SSA’s programs. OA also conducts short-term management and program evaluations focused on issues of concern to SSA, Congress, and the general public. Evaluations often focus on identifying and recommending ways to prevent and minimize program fraud and inefficiency.

Office of Executive Operations

OEO supports the OIG by providing information resource management; systems security; and the coordination of budget, procurement, telecommunications, facilities and equipment, and human resources. In addition, this office is the focal point for the OIG’s strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act. OEO is also responsible for performing internal reviews to ensure that OIG offices nationwide hold themselves to the same rigorous standards that we expect from SSA, as well as conducting investigations of OIG employees, when necessary. Finally, OEO administers OIG’s public affairs, media, and interagency activities, coordinates responses to Congressional requests for information, and also communicates OIG’s planned and current activities and their results to the Commissioner and Congress.

Office of Investigations

The Office of Investigations (OI) conducts and coordinates investigative activity related to fraud, waste, abuse, and mismanagement of SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, physicians, interpreters, representative payees, third parties, and by SSA employees in the performance of their duties. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.

Counsel to the Inspector General

The Counsel to the Inspector General provides legal advice and counsel to the Inspector General on various matters, including: 1) statutes, regulations, legislation, and policy directives governing the administration of SSA’s programs; 2) investigative procedures and techniques; and 3) legal implications and conclusions to be drawn from audit and investigative material produced by the OIG. The Counsel’s office also administers the civil monetary penalty program.