SOCIAL SECURITY ADMINISTRATION

SOCIAL SECURITY NUMBERS
WITH MORE THAN
ONE OWNER

June 2004

A-03-03-23003

AUDIT REPORT

Mission

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.

Authority

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.

Vision

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.

MEMORANDUM

Date: June 23, 2004

To: The Commissioner

From: Acting Inspector General

Subject: Social Security Numbers with More Than One Owner (A-03-03-23003)

OBJECTIVE

Our objective was to determine how often the Social Security Administration's (SSA) records show that more than one individual has been provided with the same Social Security number (SSN).

BACKGROUND

One of the key elements SSA employs in administering the Social Security programs is the SSN. SSA assigns a unique SSN to each individual applying for a Social Security card. This SSN, as well as personal identification information related to the numberholder, is stored on a master file called the Numident. Protecting the integrity of the SSN is essential to the proper posting of reported earnings, the payment of SSA disability and retirement benefits, and the prevention of SSN misuse.

In an August 2002 audit, we reported on two Numident records where more than one person appeared to share the same SSN. At the time, we referred these cases to SSA for resolution. SSA staff explained to us that such errors may occur when identifying information for one person is erroneously posted to the Numident record of another individual. For example, we were told that a replacement card could be issued to an individual in error from another person's Numident record.

SCOPE AND METHODOLOGY

Our audit included procedures to ensure the reliability of the data and gain an understanding of internal controls. We found the data to be reliable for the purposes of our review, except as disclosed in the findings of this report. Our audit work was focused on two sets of cases - 100 randomly selected items and 3 items we reported on in an earlier audit. We provide a full description of our methodology and sampling technique in Appendix B. The SSA entity reviewed was the Office of the Deputy Commissioner for Operations. We conducted our audit from July through November 2003 in accordance with generally accepted government auditing standards.

RESULTS OF REVIEW

Our review of 100 Numident records found 3 instances of 2 individuals sharing the same SSN, with 1 case leading to a $49,100 overpayment of benefits. Furthermore, we reviewed another three similar cases from an earlier audit and identified another $223,200 in payment errors caused by two individuals sharing one SSN. All but one of the six errors we reviewed occurred prior to 1983, when SSA modernized its enumeration systems. SSA's current enumeration procedures should minimize future occurrences of individuals sharing the same SSN. However, past enumeration problems may still lead to payment errors in the future.

INDIVIDUALS SHARING THE SAME SOCIAL SECURITY NUMBER

In our review of 100 randomly selected records, we found 3 records where 2 individuals were sharing the same SSN. Our population consisted of Numident records having more than one date of birth (DOB) and place of birth. In all three cases, it appears that the second individual was added to the Numident at least 26 years after the SSN was originally issued. Based on these results, we estimate that the Numident files may contain approximately 820 records where 2 individuals are sharing the same SSN (see Appendix D for our sampling methodology and results). Furthermore, in one case two individuals were sharing the same earnings information in their benefit calculations, which led to an overpayment of $49,100.

The three records with two individuals indicate that an error occurred when the field office (FO) attempted to process a replacement card. Two of these individuals already had their own SSN and appeared to be requesting replacement cards. In the third case, the individual was requesting an original SSN, but it appears that SSA issued a replacement card on another individual's record. Each of these replacement card errors occurred decades after the original SSN was issued. For instance, in one case the original Social Security card was issued to the owner in 1936 and the second name was added to the Numident in 1992 when a replacement card was issued. In one instance (see case #1 in Table 1), while both individuals on the record were retired, the second person's retirement benefits were calculated using both his earnings as well as the earnings of the SSN owner, leading to an increase in the second person's benefit payment. In all, the same 30 years of earnings were used to calculate the Old Age, Survivors and Disability Insurance (OASDI) benefits for two individuals. As of October 2003, the overpayment was approximately $49,100 and continues to increase. This case and the others noted above were referred to SSA for resolution. SSA staff corrected the Numident records of all individuals in the three cases and the earnings record of the affected individual, and is still resolving the overpayment issue.

Table 1: Results of Sample Cases

Case Date SSA Issued Original Social Security Card
Date of Erroneous
Numident Posting Individual #1 Individual #2
Date of Birth Overpayment/
(Underpayment) Date of Birth Overpayment/
(Underpayment)
Case 1 05/16/1938 10/21/1982 03/04/1905 0 7/26/1919 $49,100 (1)
Case 2 12/06/1936 10/08/1992 04/20/1912 0 5/07/1939 0
Case 3 03/05/1951 06/22/1977 05/05/1921 0 5/15/1926 0
Note: (1) Approximate amounts through October 2003.

Reason for Other Discrepancies in Sample Items

The remaining 97 cases showed discrepancies in the places of birth as well as DOBs, though we believe only 1 person was shown on each Numident record. The discrepancies in the place of birth related to different or misspelled cities and States. For example, in one case a Numident showed the city of birth as "NYC" and "New York City" on the same record. In another case, two different cities appeared on the Numident - Fellowsville, West Virginia and Preston, West Virginia. These two towns are 12 miles apart. While we could not explain this discrepancy, the rest of the information on the Numident indicates only one person on this record.

Most of the DOB discrepancies were minor, but we found 34 instances where the difference was 2 or more years. In one instance, the individual's Numident showed multiple DOBs, the earliest being October 2, 1905 and the latest being
October 22, 1921. It is not clear why this discrepancy occurred. The last replacement card issued on this particular Numident was in 1986.

FOLLOW-UP OF PREVIOUS AUDIT

During our previous audit, we found three cases where the SSN was shared by two different individuals, leading to $223,200 in incorrect payments. Of the three cases cited in our prior audit, we found that one case resulted in the owner's children being overpaid about $49,800 and the second individual and his family being underpaid approximately $110,000 in OASDI benefits and overpaid $63,400 in Supplemental Security Income (SSI) benefits.

In one instance (see case 3P in Table 2), three individuals were impacted by an erroneous Numident posting. While issuing a replacement card in 1982, SSA added a second person to an existing Numident record. Both individuals continued to work under this SSN and all earnings from that point forward were posted to the earnings record for this SSN. When the owner of the SSN died in 1987, his two children collected benefits under this record until they reached the age of 18. However, these benefits were based on both the SSN owner's earnings as well as the second person's earnings. As a result, the children were overpaid approximately $49,800 in OASDI benefits.

Moreover, when the second person on the record became disabled and attempted to collect OASDI benefits under his correct SSN, his claim was denied because he lacked sufficient earnings. As noted previously, approximately 10 years of his earnings had been posted to the first person's earnings record. While the second individual was denied OASDI benefits, he did qualify for SSI benefits. We estimate that SSA should have paid this second individual, and his family, approximately $110,000 in OASDI benefits between December 1992 and November 2003. However, this individual received approximately $63,400 in SSI payments; therefore, the overall SSA underpayment would be about $46,600. This individual is still receiving SSI payments. On July 29, 2003, we referred both of these cases to SSA and they were still being resolved as of March 2004.

Table 2: Results of Previous Audit

Case
Date of Erroneous
Numident Posting Individual #1 Individual #2
Date of Birth Overpayment/
(Underpayment) Date of Birth Overpayment/
(Underpayment)
Case 1P 07/15/1971 3/11/1952 0 3/02/1952 0
Case 2P 07/07/1982 2/19/1937 0 1/28/1952 0
Case 3P 06/30/1982 5/04/1958 $49,800 (1) 1/01/1961 ($46,600) (1,2)
Note: (1) Approximate amounts through November 2003.
(2) This figure represents the difference between an underpayment of $110,000 in OASDI benefits and an overpayment of $63,400 in SSI payments.

ENUMERATION INTERNAL CONTROLS

SSA has improved its enumeration controls in recent years, and most of the instances of two individuals sharing one SSN happened prior to these improvements. For example, SSA created an automated enumeration process which generated alerts when inconsistent information is entered for a replacement card. As a result, the problems found in this audit, as well as our earlier audit, are less likely to occur today.

Changes in Enumeration Process

SSA's enumeration procedures have changed significantly since the first card was issued in 1936. Originally, FOs issued SSN cards and then sent the corresponding applications to SSA Headquarters in Baltimore, Maryland, where SSN records were established. Since 1984, processing completed SSN applications has become almost fully automated with the Social Security cards being issued centrally from Baltimore, Maryland.

SSA requires all applicants for original SSNs to submit an application and provide acceptable documentary evidence of age, identity, and citizenship or lawful alien status. Furthermore, since the events of September 11, 2001, SSA has added additional controls to the enumeration process. See Appendix C for a more detailed explanation of the current enumeration process.

When processing SSN applications, FO personnel are required to review the evidence that each applicant presents and then enter the information into SSA's Modernized Enumeration System (MES). The MES provides FO personnel with alerts when the information being input for a replacement card does not match the personal data from the last Numident entry. For example, if FO personnel entered a DOB that does not match the last DOB entered into MES for this SSN, the system will alert them to the difference so that they can verify the information. Had these alerts always been in place, the alerts should have notified SSA personnel to some, if not all, of the Numident errors we identified in the six cases noted earlier.

Period and Nature of Enumeration Errors

A review of the six cases cited in our report indicates that a second person was added to the Numident record between 1971 and 1992 (see Table 3). Furthermore, five of these six additions occurred prior to 1984, when the automated enumeration process was not in place. Only one instance occurred after 1984, where an individual received a replacement card under his mother's SSN and SSA's system clearly indicated that the replacement card was being issued on the mother's account. Nonetheless, the FO processed the application and added the son to the Mother's Numident. Even considering this error, it appears that the instances of two individuals sharing one SSN were less likely to occur after system improvements.

Table 3: Date of Second Individual Added to Numident and Reason for Error

Case Date Original
Card Issued Date Second
Individual Added Possible Reason
For Numident Error
1 05/16/1938 10/21/1982 Similar SSN
2 12/06/1936 10/08/1992 Similar name
3 03/05/1951 06/22/1977 Similar name
1P 05/20/1968 07/15/1971 Similar SSN
2P 04/19/1951 07/07/1982 NA(1)
3P 11/08/1971 06/30/1982 Similar SSN
Note: (1) We were unable to locate another number within SSA's systems for this individual. A new SSN was assigned to the second individual after we referred the case to SSA.

Our review of the six cases also indicates that the error appeared to relate to confusion over a similar name or SSN. We found that three of the six errors (50 percent) related to a replacement card issued to a second individual whose own SSN was different by only one digit. Again, the new controls under the automated enumeration process should now detect differences in the DOB and other information, thereby preventing this from happening.

CONCLUSION AND RECOMMENDATIONS

Our review of 100 Numident records, as well as our previous work in this area, found 6 instances of 2 individuals sharing the same SSN, some of which led to improper payments. Based on these results, we estimate that the Numident master file may contain approximately 820 records where 2 individuals are sharing the same SSN. The majority of the enumeration input errors we reviewed during this audit occurred prior to improvements made to SSA's MES. SSA's current enumeration procedures should minimize future occurrences of individuals sharing the same SSN. However, past enumeration problems may still lead to payment errors in the future.

We recommend that SSA take appropriate action on the cases with improper payments discussed in this report.

AGENCY COMMENTS

SSA agreed with our recommendation, noting that the Agency has taken action on the cases identified and is working to resolve all earnings posting payment issues.

Patrick P. O'Carroll, Jr.

Appendices

APPENDIX A - Acronyms
APPENDIX B - Scope and Methodology
APPENDIX C - Enumeration Process
APPENDIX D - Sampling Methodology and Results
APPENDIX E - Agency Comments
APPENDIX F - OIG Contacts and Staff Acknowledgments

Appendix A
Acronyms
ASVI Alien Status Verification Index
DHS Department of Homeland Security
DOB Date of Birth
EOIR Executive Office for Immigration Review
FO Field Office
LOSSIV Los Angeles Immigration Status Verification Unit
MES Modernized Enumeration System
OASDI Old-Age, Survivors and Disability Insurance
POMS Program Operations Manual System
SAVE Systematic Alien Verification for Entitlements
SDW Special Disability Workload
SSA Social Security Administration
SSI Supplemental Security Income
SSN Social Security Number

Forms G-845 Document Verification Request
SS-5 Application for Social Security Card
I-20 Certificate of Eligibility for Nonimmigrant Student Status

Appendix B
Scope and Methodology

To meet our objective, we:

Reviewed pertinent laws, regulations, policies and procedures, as well as prior audits and reviews, related to the Social Security Administration's (SSA) Modernized Enumeration System (MES).

Reviewed the information related to numberholders from one segment of the Numident files and extracted those records containing more than one date of birth and place of birth. We found 1,358 records that met this criterion.

We randomly selected 100 records and reviewed the associated Numident to determine whether it appeared that more than one distinct individual was on the record. If it appeared that more than one person was involved, we attempted to determine (1) which individual was the true numberholder, (2) whether the additional person(s) had their own Social Security number (SSN), (3) whether earnings were cross-posted between Master Earnings File records, and (4) whether SSA benefits had been paid on any cross-posted earnings. We then estimated our results based on the 20 segments of the Numident files.

Reviewed three problem cases from an August 2002 report, Effectiveness of the Social Security Administration's Earnings after Death Process (A 03-01-11035), where more than one individual was sharing the same SSN. In each case, we attempted to determine (1) which individual was the true numberholder, (2) whether the additional person(s) had their own SSN, (3) whether earnings were cross-posted between Master Earnings File records, and (4) whether SSA benefits had been paid on any cross-posted earnings.

We visited a local SSA field office to view the enumeration process and obtained their views on previous practices and current concerns.

We referred the problem cases in this audit to SSA staff to resolve both (1) Numident posting errors and (2) potential benefit payment errors.

Appendix C
Enumeration Process

In Fiscal Year 2003, the Social Security Administration (SSA) issued over 17.5 million original and replacement Social Security number (SSN) cards to citizens and noncitizens. When SSA assigns an SSN or issues a Social Security card, it independently verifies the authenticity of the United States birth records for applicants age one and over, immigration records, and other identification documents the applicant presented to ensure the integrity of the process.

How SSA Assigns Original SSNs

When an individual applies for an original SSN, he or she must first complete, sign and submit a Form SS 5, Application for a Social Security Card, 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 and independently verifying the documents with the issuing Agency, 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 automated edits. For example, SSA's programs compare the applicant's name and DOB 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 a United States citizen's age, SSA requests a birth certificate issued by State or local vital statistics agencies. The United States birth certificate needs to be 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 Department of Homeland Security (DHS) documents.

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 drivers' licenses, passports, school identification cards, marriage or divorce certificates, or military records. For foreign-born applicants, SSA accepts as evidence of identity a DHS 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 DHS-granted work authorization. DHS 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, which is evidence of work authorization.

Verification of Evidentiary Documentation with DHS

SSA has a number of electronic and paper interfaces with DHS to verify evidentiary documents provided during the application process. The use of a particular DHS process relates to whether an individual is seeking asylum or other nonimmigrant category, or is a refugee, permanent resident alien, or parolee. SSA's policies and procedures require that FO staff verify noncitizen evidentiary documentation through visual inspection, including use of a black light where appropriate, and with DHS through online or manual verification. Verification of evidentiary documentation with DHS is mandated in all noncitizen 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) database, included as part of SAVE, contains certain biographic information and current status on over 25 million aliens. Each FO must verify immigration documents submitted via the ASVI system. With this database, FO staff can enter an alien's registration number or admission number and determine whether the information alleged by the applicant is valid. If ASVI cannot verify the document, a manual verification is required using the additional processes described next.

Direct DHS Verification: A Form G-845, Document Verification Request, 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. Procedures instruct DHS to check other data sources and respond to SSA within 20 days of receipt.

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

Los Angeles Immigration Status Verification Unit (LOSISV): A new procedure was implemented on January 5, 2004, to verify immigration status for exchange visitors and foreign students when the individual's data cannot be verified through SAVE. Additional documents, such as a Form I-20, Certificate of Eligibility for Nonimmigrant Student Status, completed by the school, and school letters or certification of employment, when the student is authorized to work, are needed if the person has been in the United States for at least 10 days and no online SAVE data is available. Verification of the documents must be requested through the Los Angeles Immigration Status Verification Unit (LOSISV).

To perform this verification, a fax cover sheet along with a completed Form G-845 and appropriate documents (such as Form I-20), are either faxed or sent via express mail service (as appropriate) to LOSISV. This will verify the exchange visitor or foreign student's status when the person has been in the United States for at least 10 days and no online SAVE data is available. Procedures instruct LOSISV to respond to SSA via Fax within 5 business days from the date sent.

Appendix D
Sampling Methodology and Results
Results and Projections
Population1 size in items (One Segment of Numident files)2 1,358
Population size in items (All 20 Segments of Numident file) 27,160
Sample size in items 100
Attribute Projections
Sample cases - Number of Numident Records with More Than One Individual 3
Projection - Number of Numident Records with More Than One Individual in a Numident Segment 413
Projection lower limit 12
Projection upper limit 100
Estimate - Number of Numident Records with More Than One Individual in the Numident files (Records in 1 segment x 20 segments) 8203
We made all projections at the 90-percent confidence level.

Notes:
1. We identify our population as Numident records containing more than one date of birth and place of birth.

2. A segment represents one-twentieth of the Numident files. The Numident files are separated into 20 segments based on the last 2 digits of the Social Security number. Since these last digits are not specific to a region or period of issuance, each segment should be representative of the entire file.

3. Any differences are due to rounding.

Appendix E
Agency Comments

SOCIAL SECURITY

MEMORANDUM

Date: June 4, 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 "Review of Social Security Numbers with More Than One Owner" (A-03-03-23003)--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 to
Candace Skurnik, Director, Audit Management and Liaison Staff, at extension 54636.

Attachment:
SSA Response

COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL (OIG) DRAFT REPORT "REVIEW OF SOCIAL SECURITY NUMBERS (SSN) WITH MORE THAN ONE OWNER" (A-03-03-23003)

Thank you for the opportunity to review and comment on the draft report. We appreciate OIG's work to evaluate the integrity of our enumeration process and are pleased with the conclusion that our current enumeration procedures will minimize the potential of assigning an SSN to more than one individual. Our response to the specific recommendation is provided below and we are providing some technical comments to enhance the accuracy of the report.

Recommendation 1

We recommend that the Social Security Administration (SSA) take appropriate action on the cases with improper payments discussed in this report.

Response

We agree. Action has been taken on the cases identified and we are working to resolve all earnings posting payment issues.

[In addition to the items listed above, SSA also provided technical comments which
have been addressed, where appropriate, in this report.]

Appendix F
OIG Contacts and Staff Acknowledgments
OIG Contacts
Walter Bayer, Director, Mid-Atlantic Division, (215) 597-4080
Cylinda McCloud-Keal, Audit Manager, (215) 597-0572

Acknowledgments
In addition to those named above:
Mildred Soto, Auditor-in-Charge
Walter Mingo, Senior Auditor

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-03-03-23003.

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, rather than detecting problems after they occur.

Office of Executive Operations

The Office of Executive Operations (OEO) supports the Office of the Inspector General (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.