SOCIAL SECURITY ADMINISTRATION

COMPLIANCE WITH
POLICIES AND PROCEDURES
WHEN PROCESSING
NONCITIZEN SOCIAL SECURITY
NUMBER APPLICATIONS AT
FOREIGN SERVICE POSTS

August 2004

A 08-04-14060

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.

SOCIAL SECURITY

MEMORANDUM

Date: August 30, 2004

To: The Commissioner

From: Acting Inspector General

Subject: Compliance with Policies and Procedures When Processing Noncitizen Social Security Number Applications at Foreign Service Posts (A-08-04-14060)

OBJECTIVE

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 Foreign Service Posts (FSP).

BACKGROUND

The Department of State (State) acts as the representative abroad for SSA. SSA and State have established Federal Benefits Units at FSPs located in American Embassies and Consulates in certain countries. SSA assigned managerial and technical experts to State to assist it with Social Security responsibilities, including enumeration services. Noncitizens living outside the United States can apply for an SSN at FSPs. FSPs operate in the same manner as a domestic field office (FO), except that FSPs without access to SSA's systems forward SSN applications and copies of original evidentiary documents to SSA's Office of International Operations (OIO) in Baltimore, Maryland for review and processing.

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. In Fiscal Year 2003, we estimate SSA assigned about 3,600 original SSNs to noncitizens who applied at FSPs. 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, SSA personnel now verify noncitizen evidentiary documents with the Department of Homeland Security (DHS) and/or State before SSN assignment. In addition, SSA 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 SSA personnel's actions taken during SSN application processing.

To accomplish our objective, we reviewed SSA policies and procedures for assigning original SSNs to noncitizens. To evaluate compliance with these policies and procedures, we identified a population of 338 noncitizens to whom SSA assigned original SSNs in March 2003 based on applications processed at FSPs. We then randomly selected and reviewed a sample of 100 SSNs. We also visited the OIO in Baltimore, Maryland and talked with six Regional Federal Benefits Officers and their staff by telephone to discuss the policies, procedures, and practices for processing noncitizen 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 these controls. We estimate that FSP and OIO personnel did not fully comply with policies and procedures in about 37 percent of the noncitizen SSN applications they processed during March 2003. The most common occurrences of noncompliance were personnel's failure to document on the SSN application: (1) a valid reason for a nonwork SSN card and (2) evidence of verification of immigration status with DHS. We identified two instances in which SSA assigned SSNs to noncitizens that already had an SSN and another instance in which SSA assigned the same SSN to two individuals. Furthermore, SSA personnel classified 12 percent of our sample applicants as noncitizens, even though evidentiary documents provided by the applicants showed them to be U.S. citizens. To help ensure 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 and procedures.

PERSONNEL DID NOT FULLY COMPLY WITH POLICIES AND PROCEDURES WHEN PROCESSING NONCITIZEN SSN APPLICATIONS

We estimate FSP and OIO did not fully comply with SSA policies and procedures when processing 125 SSN applications for noncitizens in March 2003. This figure represents about 37 percent of the 338 original SSNs the Agency assigned to noncitizens who applied at FSPs during this period. This figure is conservative because we did not determine whether SSA complied with policies and procedures in 16 percent of our sampled cases (SSA could not locate 4 percent of the SSN applications and misclassified 12 percent of the sample applicants as noncitizens when evidentiary documents showed them to be U.S. citizens).

Figure 1: Estimated Percentage of Compliance with Policies and Procedures When Processing Noncitizen SSN Applications

TYPES OF NONCOMPLIANCE

The most common occurrences of personnel's noncompliance with policies and procedures were failure to record on the SSN application: (1) a valid reason for a nonwork SSN and (2) evidence of verification of immigration status with DHS. Table 1 shows the specific occurrences of noncompliance we identified.

Table 1: Specific Occurrences of Noncompliance in Sampled Items

Characteristics Identified Number of Occurrences
Nonwork reason for SSN not recorded 17
Verification of immigration status with DHS not recorded 8
Applicant identity document not recorded 5
Alien or admission number not recorded 3
Country of passport not specified 2
SSA employee did not sign the SSN application 2
SSA improperly assigned SSNs to noncitizens that already had an SSN 2
Documentation of lawful alien status not recorded 1
Identification for individual applying on behalf of another not recorded 1
SSA assigned same SSN to two individuals 1
Number of occurrences identified 42
Multiple occurrence (more than one occurrence per case) 5
Number of SSNs in sample not in compliance with policies and procedures 37
Percentage of noncompliance cases to sample (37/100) 37%

We believe the following instances of personnel's noncompliance with policies and procedures illustrate SSA's risk of exposure to improper SSN assignment and misuse.

An employee processed two SSN applications for noncitizens who already had SSNs. Because this employee did not follow policies and procedures, SSA improperly assigned these SSNs.

An employee processed SSN applications for twins with the same identifying information (except for the middle names). The employee did not forward the SSN application to SSA headquarters for review and manual processing, as required by policies and procedures. Furthermore, the employee did not record a description of the identification document for the parent applying on behalf of the children. Because the employee did not follow policies and procedures, SSA improperly assigned the same SSN to both children.

An individual applied for a nonwork SSN on behalf of a child, who needed the SSN to receive SSA survivor benefits. The SSA employee did not record, on the SSN application, the individual's relationship to the child. The SSA employee listed a passport as one of the evidentiary documents reviewed, but did not indicate whether this document belonged to the individual or child. Furthermore, the employee did not list the SSN of the individual under whose SSA account the child was filing for benefits. 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.

PERSONNEL MISCLASSIFIED U.S. CITIZENS AS NONCITIZENS

SSA personnel classified 12 percent of the applicants in our sample as noncitizens, even though evidentiary documents provided by the applicants showed them to be U.S. citizens. For these cases, the SSA employee recorded, on the SSN application, that the applicant provided a Form FS-240, Consular Report of Birth Abroad of a Citizen of the United States of America, which is acceptable evidence of U.S. citizenship according to SSA's policies and procedures. Additionally, SSA assigned nonwork SSNs to seven of these individuals. Misclassification of citizenship not only causes problems for SSN applicants, but creates additional work for SSA when these individuals visit an SSA office to have their citizenship and work authorization status corrected and/or when they file for SSA benefits.

OPPORTUNITY TO HELP ENSURE COMPLIANCE WITH POLICIES AND PROCEDURES

When SSA 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 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 SSA 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 compliance with policies and procedures, we believe SSA should consider MES enhancements that would prevent SSN assignment when 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 personnel do not enter such information. Such controls would assist SSA personnel through the SSN application process and help prevent improper SSN assignment.

Management and staff at the FSPs and OIO 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.

CONCLUSIONS AND RECOMMENDATIONS

Despite SSA's safeguards to prevent improper SSN assignment to noncitizens, the Agency remains at risk to such activity when SSA 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 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.

In a separate report, we recommended that SSA take additional steps to ensure that FO personnel comply with policies and procedures when processing noncitizen SSN applications. Because these recommendations address the noncompliance issues we identified at FSPs and OIO, we are not repeating these recommendations in this report. Appendix D provides the recommendations from our report on FOs' compliance with policies and procedures when processing noncitizen SSN applications.

However, because we also identified instances in this audit in which SSA improperly (1) assigned SSNs to 2 applicants who already had SSNs, (2) assigned the same SSN to twins and (3) classified 12 U.S. citizens as noncitizens, we are making the following additional recommendations in this report. We will provide the detail for these occurrences under separate cover.

We recommend SSA:

1. Cross-reference the new and existing SSN records for the two applicants who received second SSNs.

2. Assign a unique SSN to one of the twins to whom SSA improperly assigned the same number as the other twin.

3. Correct the Numident records for the 12 U.S. citizens who SSA classified as noncitizens.

AGENCY COMMENTS AND OIG RESPONSE

SSA agreed with our recommendations. Additionally, a number of the noncompliance issues identified for the FSPs were the same as those identified in our other audit reports regarding field office (Appendix D) and the Brooklyn Social Security Card Center's (A-08-04-14061) enumeration compliance. Accordingly, the Agency stated it will ensure that FSPs are included in any corrective action activities planned in response to the recommendations made in those reports. The Agency also provided technical comments that we considered and incorporated, where appropriate. The full text of SSA's comments is included in Appendix E. We believe the Agency's actions demonstrate its commitment to strengthen the integrity of the SSN.

Patrick P. O'Carroll, Jr.

Appendices
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 - Recommendations from our Report Entitled Field Offices' Compliance with Policies and Procedures When Processing Noncitizen Social Security Number Applications (A-08-04-14005)
APPENDIX E - Agency Comments
APPENDIX F - OIG Contacts and Staff Acknowledgments

Appendix A
Acronyms
ASVI Alien Status Verification Index
DHS Department of Homeland Security
State Department of State
EAE Enumeration at Entry
FO Field Office
FSP Foreign Service Post
GAO Government Accountability Office
MES Modernized Enumeration System
OIO Office of International Operations
POMS Program Operations Manual System
SSA Social Security Administration
SSN Social Security number

Appendix B
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 a 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.

SSA 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 SSA personnel send Form G-845, Document Verification Request, along with photocopies of the applicant-provided documents, to DHS. If documents appear valid, SSA personnel query DHS' Alien Status Verification Index (ASVI) database to verify the immigration and work status of noncitizens. If ASVI information is not available, SSA personnel send Form G-845 to DHS. In addition, SSA 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.

SSA 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, SSA 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).

Appendix C
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 338 noncitizens to whom SSA assigned original Social Security numbers (SSN) for SSN applications processed by Foreign Service Posts (FSP) and the Office of International Operations (OIO). From this population, we randomly selected and reviewed a sample of 100 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 immigration status with the 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 SSA 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 OIO in Baltimore, Maryland. We met with management and staff to obtain their views on the Agency's policies, procedures, and practices for processing noncitizen SSN applications. We also interviewed, by telephone, Regional Federal Benefits Officers and their staff located in: Ciudad Juarez, Mexico; Athens, Greece; Frankfurt, Germany; Manila, Philippines; London, England; and Rome, Italy to obtain their views on the Agency's policies, procedures and practices for processing 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 FSPs and OIO 338
Sample size 100

Number of instances in sample where FSP and OIO personnel did not comply with policy and procedures 37
Estimate of instances in population where FSP and OIO personnel did not comply with policy and procedures 125
Projection lower limit 101
Projection upper limit 150

Projection made at the 90-percent confidence level.

Appendix D
Recommendations from our Report Entitled:
Field Offices' Compliance with Policies and Procedures When Processing Noncitizen Social Security Number Applications (A-08-04-14005)

1. Reemphasize to field office (FO) personnel the importance of following all policies and procedures, including the use of black lights to detect counterfeit documents, when processing Social Security number (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 Modernized Enumeration System enhancements that would prevent SSN assignment to noncitzens when FO personnel do not comply with policies and procedures.

Appendix E
Agency Comments

MEMORANDUM

Date: August 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 "Compliance with Policies and Procedures When Processing Noncitizen Social Security Number Applications at Foreign Service Posts" (A-08-04-14060)--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.

SSA Response

COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL (OIG) DRAFT REPORT "COMPLIANCE WITH POLICIES AND PROCEDURES WHEN PROCESSING NONCITIZEN SOCIAL SECURITY NUMBER (SSN) APPLICATIONS AT FOREIGN SERVICE POSTS (FSP)" (A-08-04-14060)

Thank you for the opportunity to comment on the draft report. We appreciate OIG's continuing efforts to evaluate the integrity of our enumeration process. We are also pleased that the erroneous SSN assignments identified in this report were not indicative of fraud.

Our Office of Central Operations has taken a proactive role to address specific compliance issues with Foreign Service National (FSN) and the Office of International Operations (OIO) staff by: 1) providing additional technical support; 2) reporting the specific findings of this report to the FSPs; 3) providing reminder items on areas that need improvement; and 4) including enumeration policies and procedures topics during FSN training seminars. Efforts to monitor accuracy in this area include having FSPs perform periodic reviews. In addition, our Center for Program Support (CPS) is planning to conduct operational reviews in this area.

Since a number of noncompliance issues identified for the FSPs were the same as those identified in the Field Office (Audit No. A-08-04-14005) and Brooklyn Social Security Card Center's (Audit No. A-08-04-14061) compliance reports, we will ensure that the FSPs are included in any corrective action activities planned in response to the recommendations made in those reports.

Because the review of the enumeration process at FSPs identified instances in which staff improperly assigned SSNs to applicants who already had SSNs, assigned the same SSN to a set of twins, and classified U.S. citizens as noncitizens, we are taking additional steps to address those specific issues. A description of the actions we have already taken or plan to take as well as some technical comments are provided below.

Recommendation 1

SSA should cross-reference the new and existing SSN records for the two applicants who received second SSNs.

Response

We agree. Corrective action was taken in November 2003.

Recommendation 2

Assign a unique SSN to one of the twins to whom SSA improperly assigned the same number as the other twin.

Response

Currently the MBR reflects that the beneficiary record upon which the SSN was issued is in non-payment status (i.e., alien suspension status). Therefore, we are not assigning a unique SSN at this time as it is unlikely that benefits will be paid. We have taken corrective action to remove erroneous data from the Numident record.

Recommendation 3

Correct the Numident records for the 12 U.S. citizens who SSA classified as noncitizens.

Response

We agree. Corrective action was taken in June 2004

Appendix F
OIG Contacts and Staff Acknowledgments
OIG Contacts
Kimberly A. Byrd, Director, (205) 801-1605
Jeff Pounds, Audit Manager, (205) 801-1606

Acknowledgments
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) 965-3218. Refer to Common Identification Number A-08-04-14060.

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.