SOCIAL SECURITY ADMINISTRATION

BROOKLYN SOCIAL SECURITY
CARD CENTER'S COMPLIANCE WITH
POLICIES AND PROCEDURES
WHEN PROCESSING
NONCITIZEN SOCIAL SECURITY
NUMBER APPLICATIONS

August 2004

A-08-04-14061

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: Brooklyn Social Security Card Center's Compliance with Policies and Procedures When Processing Noncitizen Social Security Number Applications (A-08-04-14061)

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 the Brooklyn Social Security Card Center (BSSCC).

BACKGROUND

In November 2002, SSA established a pilot center in Brooklyn, New York - the BSSCC - that specializes in enumeration. BSSCC is the only location where residents of Brooklyn, both United States citizens and noncitizens, can apply for an original SSN. 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. Almost 9 out of every 10 applications for original SSNs at the BSSCC are from noncitizens. In Fiscal Year 2003, SSA assigned over 26,000 original SSNs to noncitizens who applied at the BSSCC. 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 the Department of State (State) before SSN assignment. In addition, 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 BSSCC compliance with these policies and procedures, we identified a population of 2,502 noncitizens to whom SSA assigned original SSNs in March 2003 based on applications processed at the BSSCC. We then randomly selected and reviewed a sample of 100 SSNs. We also visited the BSSCC to meet with management and staff and observe personnel processing SSN applications. Appendix C includes a detailed description of our scope, methodology and sample appraisal.

RESULTS OF REVIEW

Although SSA has instituted numerous policies and procedures designed to prevent improper SSN assignment, they can only be effective if personnel processing SSN applications comply with the controls. We estimate that BSSCC personnel did not fully comply with policies and procedures in about 15 percent of the noncitizen SSN applications they processed during March 2003. The most common occurrence of noncompliance was BSSCC personnel's failure to document the verification of immigration status with DHS. Although our review did not identify any noncitizens who inappropriately obtained an SSN, we are concerned that failure to comply with policies and procedures may increase the Agency's risk of exposure to improper SSN assignment and misuse, and identity theft. To help ensure BSSCC 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 BSSCC personnel did not fully comply with SSA policies and procedures when processing 375 SSN applications for noncitizens in March 2003. This figure represents about 15 percent of the 2,502 original SSNs the Agency assigned to noncitizens who applied at the BSSCC during this period.

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

TYPES OF NONCOMPLIANCE

The most common occurrences of BSSCC personnel's noncompliance with policies and procedures were failure to record on the SSN application: (1) evidence of verification of immigration status with DHS; and (2) the applicant's nonimmigrant class of admission. Table 1 shows the specific occurrences of noncompliance we identified.

Table 1: Specific Occurrences of Noncompliance in Sampled Items
Characteristics Identified Number of Instances
Verification of immigration status with DHS not recorded 7
DHS class of admission not recorded (nonimmigrants) 3
DHS document not recorded 2
Evidence of age not properly documented 2
SSA employee did not sign the SSN application 2
Evidence of lawful noncitizen status was inadequate 1
Identification for individual applying on behalf of another not recorded 1
Number of occurrences identified 18
Multiple occurrences identified (more than one occurrence per case) 3
Number of SSNs in sample not in compliance with policies and procedures 15
Percentage of noncompliance cases to sample (15/100) 15%

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

A BSSCC employee recorded, on the SSN application, an Immigration and Naturalization Service Form I-797A, Notice of Action, as proof of the applicant's noncitizen status. However, this form is not acceptable evidence of noncitizen status for SSA purposes. Because the employee did not comply with policies and procedures, SSA did not have documented assurance of the applicant's noncitizen status.

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 BSSCC agreed that MES enhancements, as discussed above, would assist personnel in complying with policies and procedures. SSA has discussed plans to modify MES to capture more discrete information about the evidence submitted during the SSN application process. We understand that such modifications must be considered as part of the Agency's information technology prioritization process. Nevertheless, we encourage the Agency to begin the systems planning process for MES enhancements.

CONCLUSION

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 field office personnel comply with policies and procedures when processing noncitizen SSN applications. Because these recommendations address the noncompliance issues we identified at the BSSCC, we are not making recommendations in this report.
Appendix D provides the recommendations from our report on field offices' compliance with policies and procedures when processing noncitizen SSN applications.

AGENCY COMMENTS AND OIG RESPONSE

SSA stated that because a number of the noncompliance issues identified for the BSSCC were the same as those identified in the previously mentioned audit report regarding field office enumeration compliance (Appendix D), the Agency will ensure it includes the BSSCC in any corrective action activities planned in response to the recommendations made in that report. 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
BSSCC Brooklyn Social Security Card Center
DHS Department of Homeland Security
State Department of State
EAE Enumeration at Entry
GAO Government Accountability Office
MES Modernized Enumeration System
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 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, 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 2,502 noncitizens to whom SSA assigned original Social Security numbers (SSN) for SSN applications processed by the Brooklyn Social Security Card Center (BSSCC). 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 the BSSCC. We met with management and staff to obtain their views on the Agency's policies, procedures, and practices for processing noncitizen SSN applications. We observed personnel processing 10 original noncitizen SSN applications.

The SSA entity reviewed was the Office of the Deputy Commissioner for Operations. We relied primarily on MES to complete our review, and determined that the MES data used in the report is sufficiently reliable given the audit objective and use of the data.

We conducted our work from May 2003 through February 2004 in accordance with generally accepted government auditing standards.

Table 1 shows our sample size, results, and appraisal.
Table 1: Results and Projection

SAMPLE ATTRIBUTE APPRAISAL
Total population of original SSNs assigned to noncitizens from SSN applications processed at the BSSCC 2,502
Sample size 100
Number of instances in sample where BSSCC personnel did not comply with policy and procedures 15
Estimate of instances in population where BSSCC personnel did not comply with policy and procedures 375
Projection lower limit 239
Projection upper limit 551
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: July 30, 2004

To: Patrick P. O'Carroll, Jr.
Acting Inspector General

From: Larry W. Dye
Chief of Staff

Subject: Office of the Inspector General (OIG) Draft Report "Brooklyn Social Security Card Center's (BSSCC) Compliance with Policies and Procedures When Processing Noncitizen Social Security Number (SSN) Applications" (A-08-04-14061)--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 "BROOKLYN SOCIAL SECURITY CARD CENTER'S (BSSCC) COMPLIANCE WITH POLICIES AND PROCEDURES WHEN PROCESSING NONCITIZEN SOCIAL SECURITY NUMBER APPLICATIONS" (A-08-04-14061)

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 pleased that the report acknowledges our efforts to improve the accuracy of SSN applications and that the review found no instances where noncitizens inappropriately obtained an SSN.

Since a number of the noncompliance issues identified for the BSSCC were the same as those identified in the Field Office (Audit No. A-08-04-14005) enumeration compliance reports, we will ensure that the BSSCC is included in any corrective action activities planned in response to the recommendations made in those reports.

Some of the steps the Agency has already taken or has in progress to strengthen the integrity of the enumeration process in the BSSCC and other field offices include:

o Training- In April 2004, we conducted an Interactive Video Training session focusing on the identification of fraudulent documents, including the use of black lights to verify the various check points on the Department of Homeland Security's (DHS) and other documents. We have made these procedures available online so they can be accessed easily by interviewing employees. We are currently revising Program Operations Manual System (POMS) instructions to clearly stress these procedures and policies in reviewing immigration documents, and we will release a reminder to FO personnel in July 2004 emphasizing the need to utilize all tools available for verifying documents.

o Monitoring- as of October 2002, all SSA regional offices had plans in place to monitor FO compliance with the collateral verification requirements, such as reviewing samples of completed SS-5 applications. We have also included an assessment of FO staff compliance with verification requirements as part of our ongoing enumeration quality reviews. The published findings from these reviews are currently limited to addressing those enumeration failures classified as "critical errors" (a misassigned SSN that is either assignment of an SSN that belongs to someone else or a multiple SSN that is not cross-referred on the existing records) or "major errors" (errors that can result in an additional or incorrect action in subsequent enumeration transactions or claims actions because information on the applicant's record is incorrect or incomplete). Based on the results of this review, we will provide an analysis and assessment of documentation failures in future reports. Finally, we continue to monitor compliance through our Comprehensive Integrity Review Process program and develop process improvements to address any identified weaknesses or errors.

In addition to these ongoing reviews, the recently developed New York Region's Modernized Enumeration System (MES) Workload Management Information application provides information on SS-5 applications from foreign-born individuals who were assigned SSNs in one day, but whose immigration documents were subject to verification; US-born individuals over the age of one who were assigned SSNs in one day, but whose birth records were subject to verification; and individuals who reside outside the State or service area of the processing field office. The MES application serves as a valuable resource for managers to identify: 1) employees who may not be following current collateral verification procedures; 2) local weaknesses in the enumeration process; and 3) any SS-5 workloads that appear to be unusual for particular offices.

o Enhancements to the Modernized Enumeration System-- We are considering certain changes as suggested to the MES as part of our Long Term MES Enhancements Initiative. We will consider revising the evidence collection fields in MES to collect evidentiary data in specific fields, however, any identified modifications will have to be considered as part of our Information Technology prioritization process.

In the interim, the New York Region has developed a front-end software program to improve FO compliance with the policies and procedures for processing SS-5 applications. The SS-5 Assistant application assists FOs to comply with the collateral verification procedures by providing greater control over, and improving the accuracy of, SSN applications filed by noncitizens. We expect to release Version 2.0 of the SS-5 Assistant in early fiscal year 2005. The new features of this version will: 1) serve as the front-end input system that will collect all necessary data in mandatory fields and propagate it to the current MES screens; 2) collect data in an intelligent manner as a data-driven system that will understand the policy requirements and facilitate capturing the mandated information from the user, include drop-down selections, and ensure the character lengths for certain fields are appropriate; and 3) automatically query the Systematic Alien Verification for Entitlements system of DHS for the user at the time the application is being entered (as the interface will require that verification is received) before permitting processing of the SS-5 application.

We anticipate that the implementation of Release 2 of the SS-5 Assistant application will eliminate the noncompliance situations identified in the report.

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-08-04-14061.

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.