BIRTH CERTIFICATE FRAUD

GENERAL 
OFFICE  OF INSPECTOR 
OFFICE OF ANALYSIS AND INSPECTIONS 
1988 
MARCH  OFFICE OF INSPECTOR GENERA

The mission of the Offce of Inspector General (OIG) is to promote the efficiency, effec
tiveness and integrity of programs in the United States Department of Health and 
Human Services (HHS). It does this by developing methods to detect and prevent fraud 
waste and abuse. Created by statute in  General keeps both the 
1976, the Inspector 
rrently informed about programs or management. 
Secretary and the Congress fully and 

problems and recommends corrective action. The OIG performs its mission by conduct
ing audits, investigations and inspections with approximately 1 200 staff strategically lo
cated around the country. 

OFFICE OF ANALYSIS ANI; INSPECTIONS 
This report is produced by the Office of Analysis and Inspections (OAl), one of the three 
abuse. 
major offices within the OIG. The other two are the Office of Audit and the Office of In
vestigations. The OAi conducts inspections which ate  term studies 
tyically short-
designed to determine program effectiveness, efficiency and vulnerabilty to fraud or
THIS REPORT 
This report is entitled Birth Certificate Fraud. It waS prepared following a review con
ducted to help lU-IS and other interested parties to gain a current overvew of (1) the vul
nerabilities to fraud in birth certificate forms and procedures of issuing and user agencies 
and (2) the best practices among State and local jurisdictions to minimie these vul
nerabilities. 
The report was prepared by the Regional Inspector General, Office of Analysis and In
spections, New York Region. Participating on the review were the following: 
Project Staff/Region II  Project leader 
Lucile Cop  Alan S. Meyer, Ph. 
Jack Molnar  egional Inspector General 
Deputy 
Pereta Rodriguez  Region II 
Renee Schlesinger 
Region I  Headquarters 
Thomas Nee  Gail Shelton 
Region IX 
Deborah Harvey  BIRTH CERTIFICATE FRAUD

Richard P. Kusserow 
INSPECTOR GENERAL 
001 
OAI-86-02- MACH 198  PREFACE

. . . the foundation, or breeder document, for almost any other kid ofiden
tification for citizens is the birth certificate. Over 7 000 State and local vital 
records offices issue birth certificates with no uniform standards for issuance 
processes, controls, or quality of dOClments. . In some jurisdictions, birth cer
tificates are easily counterfeited, obtaied through imposture, or created 
from stolen legitimate blan form. II * 
*From Report of the Task Force on Criminal Implications of False Identifica
tion of the Fifth Conference of the Judiciar held by Laws At Work on May 
23- , 1984 in Los Angeles.  ...........................................  
...  ............ ..............
.................. ................
TABLE OF CONTENTS 
Page

PREFACE

......... I

EXECUTIVE SUMMARY .................................. 
INTRODUCTION ... ....... ....  .. 1

FI N DI N GS ............................. ..................  . 3

............................................. 3

I. The Problem 
II. The Issuing 
Agencies....................... 8

II. 
The Birth Documents....................... 10

IV. The Issuing Procedures 
V. The User Agencies .................................... 16

RECOMMENDATIONS ................................................. 21

APPENDICES 
A. Best 
Practices............................................ A 1

B. Comments on Draft Report

and OIG Comments...
 List of Abbreviations 
AFC 
Aid to Famlies with Dependent Children 
VRS 
Association for Vital Records and Health Statistics 
DEFRA  Deficit Reduction Act 
DMV  Department of Motor Vehicles 
EPIC  EI Paso Intellgence Center 
FACFI  Federal Advisory Commttee on False Identification 
HHS  DIedpaertmnentt.i off iHceaaltht aindo Hnum an Servces
Inspector General 
INS  Immgration and Naturalization 
LAW  Laws At Work 
NCHS  National Center for Health Statistics 
NWA 
National Welfare Fraud Association 
OAI  Office of Analysis and Inspections 
Office of Investigations 
OIG  Office of Inpector General 
SSA  Social Security Administration 
SSI  Supplemental Security Income  EXECUTIVE SUMMARY 
PURPOSE AND BACKGROUND 
In 1976, the Federal Advisory Commttee on False Identification (FACFI)of theJustice 
Department pointed out that false identification was a serious national problem. In 1984 
the Task Force on Criminal Implications of False Identification, sponsored by Laws at 
Work (LAW), a national citizen s association interested in law enforcement issues, en- ' 
dorsed a broad range of proposed actions, including a national review of birth cer1ificate 
systems and practices. This inspection is a further study of this problem. 
The purpose of the inspection was to: (1) identify vulnerabilties to fraud in birth certifi
cate forms and issuance procedures and in procedures of user agencies which receive 
birth certificates as documentation; and (2) describe best practices among State and local 
jurisdictions to remove or minimize these vulnerabilties. 
METHODOLOGY 
Eleven States and New York City, representing differing problems and best practices in 
birth certificate forms and procedures, were visited. The sites included a dispropor
tionate number of States with big cities or port or border cities where birth certificate 
fraud is heavily concentrated. Discussions were held with State and local registrars; fraud 
investigators from Immgration and Naturalization Servce (INS), passport servces, and 
various State agencies; and front-line workers in issuing and user agencies. 
The study focused primarily on certified copies of birth records. In this report these cer
tified copies are referred to as " " as distinct from the original birth 
birth certificates
records or birth registrations on which certifed copies are based. 
FINDINGS 
clude: .

Major findings, which confirmed and extended the study results of F ACFI and LAW, in
A birth certificate issued in the States is the key to opening many doors 
in our society -- from citizenship privileges to Social Security benefits. 
Such certificates can then be used as "breeder" documents to obtain 
driver s licenses, passports, Social Security cards or other documents 
with which to create a false identity. An Office of Inspector General 
study entitled Social Security Number Validity in the Aid to Familes 
With Dependent Children Program (AFDC), has shown that invalid 
Social Security cards are a major c use of AFDC errors.  The birth certificate is also a key to creating a false identity and thus has 
great value for undocumented aliens who seek fraudulent citizenship, 
ineligible applicants who seek jobs or benefits, credit defrauders 
fugitives, terrorists, and drug smugglers. Individuals can obtain a valid 
birth certificate through theft, purchase, borrowing, or applying, and 
then impersonate the real owner.. They may produce, steal, or buy a 
counterfeit or altered document. 
While false identification (ID), in general, is estimated to cost society 
bilions of dollars anually, data on the extent of birth certificate fraud 
are limited. With the new immgration law, however, it is likely that 
such fraud will increase. 
Issuance of birth certificates is a State fuction, but almost 7 00 local 
registrars' offices also issue certificates. The resulting multitude of 
certificate forms, official seals, and signatures (an estimated 10 000 
nationwide) makes it extremely diffcult for user agency workers to
detect false documents. 
Privacy and security safeguards to protect birth records from 
unauthorized disclosures vary from State to State. In some cases this is 
attributable to a lack of State statutes on privacy of vital record 
information. Ten States allow the public open access to vital records. 
Even in the restricted States, however, ID is often not required. Weak 
physical security over forms and records, and use of non-safety paper for 
certificates, create additional vulnerabilties. 
Local offices which issue most birth certificates are even more 
vulnerable. They are less likely than their State offices to have safety 
paper, a standard State form, adequate security, or to mark "deceased" 
on birth certificates for dead registrants. Moreover, State control of 
local. offices is stil strongly resisted; 
A variety of measures to fight fraud have been developed. Many States 
limit local issuance and many now provide a standard State birth 
certificate form to their local offices and use safety paper or plan to do 
so. It is becoming increasingly common to match birth and death 
records. (See Best Practices in 
Appendix A.  The primary users of birth certifcates (e.  , Social Security 
Admiistration, passport servces, State welfare agencies, driver 
license agencies, etc.) are faced with a gargantuan task. A birth 
certificate submitted to their workers may be anyone of thousands of 
variations makng it virtually impossible to determne their v  idity. 
The ad hoc nature of commumcation between Federal and State 
agencies has hindered effective prevention and detection of birth 
certificate fraud. Prosecution is hindered by legal limitations and 
difficulties in getting prosecutors to take cases involving birth certificate 
fraud unless linked with other major criminal activity. 
RECOMMENDATIONS 
Efforts to reduce birth certificate fraud take on added urgency in light of the new im
migration law which requires employers to check th  citizenship or work authorization 
and identity documents of potential employees. The new law also requires State agencies 
to verify the immgration status of alien applicants for Federal benefit program. It is ex
pected that more aliens will try to escape this check by claiming citizenship. A birth cer
tificate is one acceptable identity docuent for verifyng citizenship. 
Since the issuance of birth certificates is clearly a State function, recommendations are 
directed to the State level. To be effective, improvements in birth certificate controls 
must include both stricter issuance and more tamper-proof documents. Neither by itself 
is sufficient. 
It is recommended that State registrars, with the support of their Governors, legislatures 
and relevant national associations as needed, should: 
standardize the form and content of birth certificates within their State 
to protect birth documents against alteration and counterfeiting, and 
expand the use of bank note-tye safety paper with security featues; 
promote greater intra-State standardization of birth certificate forms 
and procedures, through State legislation if necessar, by reducing the 
number of local issuing offices and/or exercising greater control over 
them; 
bestablilsh mainimnum stakndards; for  all issuing offices to assure the physical 
security of original vital records, certified copy blanks, and seals against 
theft, and maintain a system of strict accountabilty of all certified copy urge legislatures to amend existing statutes or pass new ones, where 
needed, to protect the privacy of individual vital records by restricting 
physical access and strictly limiting applications for copies; 
assure that States participate fully in and help expand the voluntar 
Interstate Vital Records Exchange System of the Association for Vital 
Records and Health Statistics, by in,cuding the sharng of death records 
for persons substantially beyond infancy, and should apply a "Deceased" 
overlay to all original and certified copies of birth records of persons 
who have died; and 
work cooperatively with the Social Security Administration to establish 
procedures whereby parents can receive a Social Security number for 
their infants at the time a birth is registered, and in the long run help 
rfeduace tlhe ustilitey of  a failse dbirthe cenrtifitcatei as at breyede.r do cum
 ent of a
COMMENTS ON DRAFT REPORT AND OIG RESPONSES 
Department of Health and Human Servces comments were received from the Ad
ministrator of the Health Care Financing Administration (HCF A), the Deputy Assistant 
Secretary for Health Operations of the Public Health Servce (PHS), and the Comms
sioner of Social Security. From outside HHS they were received from the President of 
the Association for Vital Records and Health Statistics (A VRHS) and the Director of the 
Office of Consular Fraud Prevention Program of the U.S. Department of State. 
The PHS commented that the report should distinguish between an original birth record 
and a certified copy of the record. In response, the term "birth certifcate" as used in the 
report wil always refer to a certified copy. 
The A VRHS suggested that additional documentation of the extent of the fraud problem 
would help convince States of the need for change. Additional information on the scope 
of the problem is thus included. 
The Department of State and HCF A made suggestions for more specific recommenda
tions involving a more active Federal role as well as coordinated action by State and local 
registrars. The details of these comments and our responses are summarized in Appen
dix B. 
The A VRHS and PHS offered technical comments on specific findings and on several 
recommendations. In response, appropriate changes were made as indicated in Appen
dix B.  INTRODUCTION 
PURPOSE AND BACKGROUND 
In 1976, the Justice Department's Federal Advisory Commttee on False Identification 
(FACFI) in its report  Identification found fraudulent iden-
The Criminal  Use Of False 

tification to be a national problem costing $15 bilion anually. The F ACFI recom
mended standardization of birth records, matching of birth and death records, limited 
access to records, and other measures to reduce the fraudulent use of birth certificates 
and other documents. In 1977, the U.S. Public Health Servce revised its Model State 
Vital Statistics Act, in part to stregthen efforts to reduce birth certificate fraud. 
Seven years later, in response to continuing problems, the Inspector General (IG) of the 
Department of Health and Human Servces (HHS) and top officials from the Depar
ments of State and Justice co-chaired a Task Force on Criminal Implications of False 
Identification. Sponsored by the Fifth Conference on the Judiciar of "Laws at Work" 
(LAW), the task force proposed a study of birth certificate problems and practices. The 
task force acknowledged the signiicant work done by the HHS IG in investigating birth 
certificate fraud and issuing fraud alerts and recommendations to correct vulnerabilties. 
To further the recommendations of the task force, the HHS IG initiated this national in
spection of the problem of birth certificate fraud and measures to counteract it. The pur
poses of the inspection were to: 

identif vulnerabilities to fraud in birth certifcate form and procedures 
and in procedures of user agencies which receive birth certificates as 
documentation; and 
describe best practices among State and local juridictions to remove or 
minimize these vulnerabilities. 
The birth certificate is a key document in applying for benefits, privileges, or servces 
from a variety of Federal and State program such as Social Security, Aid to Famlies 
with Dependent Children (AFDC), Medicaid or Food Stamps. The birth certificate is 
also used to obtain other important documents such as a passport or driver s license. The 
birth certificate has been caned a "breeder" document because with a false one a person 
can obtain other false identification (ID) documents with which to defraud Governent 
or business, or create a new identity. 
The release of this report, cornng after the enactment of the Immgration Reform and 
Control Act of 1986 (IRCA), should be especially timely for States in their efforts to 
strengthen document security and issuance practices and for user agencies in tightening 
eligibility verification procedures.  METHODOLOGY 
The IG's Office of Analysis and Inspections (GAl) in New York, with support from Bos
ton, San Francisco, and Seattle, visited 12 jurisdictions (11 States and 1 city). The sites 
visited were: California, Florida, Ilinois, Massachusetts, Michigan, Minesota, New 
York City, New York State, Texas, Vermont, Virginia and Washington. Since New York 
City has its own registrar, it is treated as a State. Discussions in New Jersey pre-tested 
the study design and provided data for analysis. The study focused primarly on certified 
copies of birth records. 
In this study, the certified copies are referred to as "
birth certificates " as distinct from the 
original birth records or registration on which certified copies are based. 
Pre-inspection discussions were held with officials of the U.S. Deparments of State and 
Justice and of HHS' s Social Security Administration (SSA) and National 
Center for 
Health Statistics (NCHS). The Association for Vital Records Health Statistics (A vRHS)
and the National Welfare Fraud Association (NWFA) provided useful assistance. Also 
helpful were central and regional staff from the Offce of Investigations (01) who 
provided case material. 
Sample States were selected to include major 
tyes of vulnerabilties to birth certificate 
fraud, and best practices in counteracting these vulnerabilties. The sample contai a 
disproportionate number of States with large metropolitan areas and port or border cities 
where problems involving fraudulent use of birth certificates are most likely to be found. 
The States include a mi with regard to the number of local registrars, the ease with 
which someone can obtain a birth certifcate, and geographical region. 
In each of the 12 States, team members met with State and local registrars, fraud inves
tigators, and front-end workers in issuing and user agencies. The investigators were from 
State human services and motor vehicles agencies, INS special agents, passport agency
fraud coordinators, SSA Regional Security Offcers, and 01 and other agencies. Team
members held over 200 discussions.  FINDINGS 
THE PROBLEM,

They are definitely being used for fraudulent purposes. We may be seeing the tip of 
the iceberg. Birth certifcates are needed for our life style. A person needs a birth cer
II --
tifcate to participate in  fale  A New 
England Fsrociaetuy. dFor   Inidevntitey, ist is twhati is gneedaed. tor 

Certificate Fraud Takes Many Forms 
Birth 
Birth certificate fraud involves one or more of the following ilegal acts: stealing, 
transferring or sellng valid birth certificates; counterfeiting, sellng, or using 
bogus documents; using or sellng altered documents; and using someone. else 
valid certificate by impersonating the owner. 
Impersonation was most often mentioned by investigators and registrars as the 
most common way of obtainng a birth certificate for fraudulent purposes. In 
some areas, counterfeiting is a big business. Use of a counterfeit birh certifcate 
was, in fact, mentioned second as a way of commtting birth certificate fraud. Al
teration of a valid certificate was mentioned third. Theft was mentioned least 
often, though a variety of incidents were reported. 
The following cases from the Office of Investigations strikigly ilustrate the im
personation method of commtting birth certifcate fraud: 
Many years ago, a baby died in infancy. Recently, a young man (under 
the age of 20 and employed as a caretaker in a local cemetery) requested 
from a registrar s office a copy of the birth certificate of the dead inant. 
Since this State considers birth records public information and allows 
practically anyone to request and obtain anyone else s birth certificate, 
he was able to get the dead infant' s birth certificate. With this, he 
attempted to open a ban account using the identify of the 
. long-deceased infant. Much to his surprise, he was apprehended afer 
being recognized by the ban teller, who was the mother of the dead boy. 
A Supplemental Security Income (SSI) beneficiary, age 41, was using 
fake medical data under false names to receive multiple SSI payments. 
The subject obtained death certificates of two persons, both born within 
With these, he then obtained birth certificates 
1 or 2 years of his birth. 
from the counties of their births. He used these birth certificates to 
obtain Department of Motor Vehic1es (D MV) identification. With the 
birth certificate and DMV identification of one person, the subject  appeared at an SSA district office to apply for an Social Secudty number 
(SSN), satisfied the SSA requirement of two ID documents and was 
assigned an SSN. In the same manner, he was given an SSN for a second 
person through another SSA district offce. Once the false identities 
were established, he filed multiple claims for SSI in different SSA 
offices. 
. Between April 1985 and June 1986, a legally blind, escaped convict 
fraudulently obtained at least three SSN cards and $1 313 in SSI 
presumptive disabilty payments. He used fraudulently obtained 
legitimate birth certificates to establish fictitious identities prior to filng 
for the SSN cards. He then filed for SSI disabilty using the false il and 
newly acquired SSN. Investigation revealed he was a fugitive from a 
Federal correctional facilty in Caliornia, where he had been servng a 
IS-year sentence for fraudulently obtaining over $140;000 in SSI 
payments over a 7-year period. He had established at least 38 known 
fictitious identities. 
Many other cases were reported by registrars and other investigators ilustrating 
fraud through counterfeiting and alteration of documents. For example: 
A counterfeiter in a southwest city printed birth cards on safety paper. 
He sold the cards for $40 to $50 each and they were resold by a 
trafficker in false ID for $1 100 to $1 500 each. 
An SSA employee invented 25 fictitious beneficiares over a period of 
10 years. To do this, she took a photocopied birth certificate from a 
legitimate beneficiary file, whited-out the real name and tyed in the 
fictitious information on the birth certificate. She then made a 
photocopy of the altered certificate for the fake beneficiar s fie. 
Before being discovered, she had received approximately $360,000. 
Perpetrators Use Birth Certificates To Help Establish False Identity For 
Other Ilegal Purposes 
Almost all perpetrators of birth certificate fraud go through a two-step process. 
As Figure 1 below ilustrates, the two steps are: (1) to fraudulently use a birth cer
tificate to obtain false ID documents and thus create a false identity; and (2) to 
use one or more of these false ID documents to obtain government benefits or 
privileges to which one is not entitled, or to commit other crimes under an as
sumed name. The first step is to use a birth  breeder" document 
certificate as a "
and the second step is to use the resulting false identity as a modus operandi, or 
method of operating, to defraud business or Governent, and/or avoid legal sanc
tions.  . ...": ..............  .............  ..., ............ ...... ...:....... ......:.:.:. ........ ."'''''' .:. .:.:.
FIGURE 1 
The Two-Step Process of Fraudulent Use of Birth Certficates: 
Step 1  Step 2 
Establishing a False Identity  Commt Other Offenses 
f-t 44mk  tlk 
QtJt 
J3jdb 
iiifidl.t 
.:i 
breeder 
as 
document 
other 
to obtain: 
false 
IDto: 
b) 
...H 
as sufficient 
.....E 
in itself to: 
:.:.Fa1$  J....... 
i#ii9.  i(. ##tY: 
modus 
operandi 
Commt 
to: 
Other 
Offenses 
Most Perpetrators Are Career Criminals Or Ilegal Aliens 
were mentioned most often by respondents as 
Ilegal aliens and career criminals 
the kinds of persons most likely to commt birth certificate fraud. While there is 
some overlap between individuals in these two categories, each group tends to 
commit birth certificate fraud for different reasons.  Career Criminals Include: 
those who use false identities to engage in such activities as drug 
smuggling, insurance fraud, cashing bad checks, counterfeiting and/or 
sellng birth and other documents, entering sham marriages for a price 
credit care or bank fraud, securities fraud, money laundering, organzed 
crime, and ilegal departure from and entry into the country; 
terrorists, espionage agents, and fugitives who use false documents to 
avoid identification and detection; . 
ineligible beneficiaries who habitually use the fraudulent paper route to 
obtain such governent benefits as AFDC (based on non-existent 
and 
children), other public assistance, unemployment insurance, SSI, Social 
Security (i.e., retirement, survvor or disabilty payments), college grants 
and loan, and sometimes duplicate benefits under diferent identities;
some employees of issuing or user agencies who, by ilegally issuing or 
accepting birth certificates, facilitate birth certificate fraud by the above. 
kinds of criminals. 

Some otherwse law abiding citizens also get caught up in using altered 
or other ilegal birth certificates to gain privileges or avoid legal 
penalties. Common examples include: parents of miors whose birth 
record ages are changed to make them eligible for Little League teams; 
minors to get a driver s license or buy alcoholic beverages; adults who 
change their recorded age for what is called "vanty fraud" or to speed up 
or delay retirement, Medicare, or Social Security benefits; and those 
lawbreakers who assume an alternate identity to avoid fines. 
Illegal Aliens tyically use fraudulent birth certificates for gainig a legal status 
benefit or privilege to which they are not entitled. Those that misuse birth certfi
cates seek to: 
become a U.S. citizen or legal alien;

get a Social Security card to work or to collect unemployment benefits;

become eligible for welfare benefits; 
obtain a passport; or

get a lower college tuition rate or certain college grants or loan.
 While these ilegal acts can be committed by persons in any alien status category, 
, who face deportation if ap
most concern was expressed about ilegal alens
pfrerhoendmed w itahoult  ppropaer rdotcusm eonts.f T htoshe weho  mwisusoe brirlthd ce.rti fcates come
Unknown 
Extent Of  The Problem Is 

Most State and local registrars and user agency investigators did not know of any 
statistics on fraudulent birth certificate cases being kept by their own or other 
agencies. Only three State registrars said they kept track of fraud cases. .

ases 
J;assport' s Offce of Evaluation and Standards maintains statistics of 
referred to investigative agencies by each field offce. During Fiscal Year 1987 
845 referrals were made prior to issuance of a passport. However, these do not 
include the applicatiQns estimated to be fraudulent based on determations after 
bissuiarncteh of  a cpasesporrtt. iTfheisce caasets eares lar.g ely, if not entirely, based on bogus
The EI Paso Intellgence Center (EPIC), established by INS to receive reports 
from anywhere in the country on the use of fraudulent documents, received 16 130 
reports of fraudulent birth certificates during FY 1986 and 9,456 during FY 1987. 
However, most of these reports are from Texas, Californa, and ilnois and do not 
represent all cases nationwide. While not currently national in scope, EPIC' s in
formation is a potential clearinghouse on fraudulent ID. 
When asked how many birth certificate fraud cases had come to the attention of 
their agency last year, a third of the respondents were unable to give a figure. 
Among those who could, State registrars and investigators reported an average of 
134 cases a year; local registrars reported on the average only one case a year. 
Only a fifth of the local registrars interviewed thought that birth certificate fraud 
was a problem. Although most of the States had few, if any, statistics, 7 of 11 State 
registrars interviewed considered birth certificate fraud a big problem in their 
State. The other four would not venture a judgement. 
The lack of any national, State, or local figur  s on the extent of birth certifcate 
fraud suggests that such data collection generally has low priority at all levels. 
This could be because Federal and State agencies have not yet focused suffcient 
attention on this tye of fraud. 
The pessimistic conclusion of some respondents was that the system is out of con
trol and that the war is being won by those who would use birth certificates as an 
important link in a chain establishing false identify for ilegal purposes. In 1982 
the U.S. Senate s Permanent Subcommttee on Investigations' study estimated  that fraudulent ID in general cost society upwards of $24 bilion. Since there is no 
reason to assume that the problem today is less severe, the cost to society, taking 
into account infation, would currently approximate $30 bilion. 
At a hearing on the False Identification Crime Control Act before the House 
Commttee on the Judiciary in 1982, a Justice Department official testified that 
the problems identified in the F ACFI report stil exist and may even have wor
sened in light of the increased number of ilegal aliens, international terrorists 
and drug-smuggling rings in recent years. State legislators are reportedly con
cerned with the increasing evidence of a link between false il documents, includ
, and ilegal drug trafficking. Referring to bogus birth 
ing birth certificates
certificates as a particular form of false ID, one registrar in a western State ob
Birth certificate fraud is maiilya question of ' green.' The problem 
served that: "
will exist as long as there is money to be made. 
II.  THE ISSUING AGENCIES 
II -- An Eastern.
I've tried to get the system more centralized
, but it's too political. 
State Registrar 
Nearly 7,000 Local Offices Stil Issue Bir1h Certificates 
Certified copies of birth records, as well as of other vital events, are issued by 
State and local registrars, stamped with an offcial seal and signed by them, and 
provided to applicants who meet the issuing agency s requirements. These agen
cies are usually located in State or local health departments but may operate out 
of other local offices or even homes. 
In 1976, FACFI counted about 7 000 local offices nationwide which issued birth 
certificates. In 1981, NCHS survey data showed about the same number. This in
spection found only a 1 percent drop in local offices from the NCHS data in the 12 
States visited. The multitude of local offices ,has thus continued. Most copies of 
birth certificates are reportedly issued by these local offices. 
Central Control Over Local Offices Is Resisted In Most States 
Existing statutes in many of the States visited call for State direction and super
vision of local registrars' offices. These States have authority to set policy and pro
cedures and to monitor local compliance. In actual practice, however, most States 
exert minimal control.  In about half the States visited, local registrars used their own forms and proce
dures instead of, or in addition to, those of the State. Although hal of the State 
registrars said they closely monitored local offices, two;.thirds ofthe locals in these 
offces 
same States said their offces were not closely monitored. Only two State 
All but one of the State 
made site visits to local offices at least once ayear. 
registrars said they had concerns about the controls over blan certificates and 
seals in local offices.

The 1977 revision of the model State Vital Statistics Act disseminated by NCHS 
calls for centralization of State registrars' offices. Although many State registrars 
recommend the reduction, if not the elimination, of local issuing offces, there has 
been little recent movement in that direction. Thirty States and Puerto Rico al 
lowed their local offices to issue birth certificates. 
Resistance on the part of the thousands of county, city, and town offices across the 
country is based on a combination of local CUstom and pride, convenien e to ap
plicants, financial gain from fees collected (especially where the forms are sup
plied free by the State), and local political patronage. Concerns about birth 
certificate fraud, and the fact that a multitude of local issuing offces makes such 
fraud easier to commt, has not sufficiently motivated legislators and executives to 
overcome these resistances in most States. Nevertheless, some progress has been 
made. (See Appendix 

Ten Thousand Varieties Of Birth Certificate Seals, Signatures, Or Forms 
Are Used Nationwide; 6,000 Used In 13 States Visited 
The 1976 F ACFI report estimated that over 1 000 different birth certificate forms 
were then issued nationwide. Ths meant that workers in user agencies -- those 
agencies to which birth certificates are submitted to docuent eligibilty for 
benefit or a privilege -- had to deal with over 1 000 different forms. 
However, this inspection found that user agency workers are faced with a much 
more difficult task. They not only see different formats with their differing con
tent, but also see a different certifyng seal and registrar s signature from each 
local registrar which issued the certificates. Unless the worker knows what seal 
tic.
and signature was used by the paricular local issuing office at the time the birth 
registration was fied  was signed, there is no way of knowing 
or the certified copy 
that the document, even if it is an appropriate form for that city or town is authen-
The F ACFI report concluded that the wide variety in document format and 
authenticating seals encourages the passing of counterfeit documents. Indeed 
one of our respondents commented on the confsion about seals:  Someone walks in with a birth certifcate which is completely alien to what the 
workers are familiar with. Even the seal itself varies. We said once it shouldn't say 
seal,  then we found soine that do. 
From the worker s point of view it would appear to be more accurate to count dif
ferences in seals and signatures, as well as difference in forms themselves, in 
describing how big the problem really is. 
In about 4 000 issuing offices in the 13 States visited (including the pretest State), . 
each had their own unique seal and signature as well as place name. Lage city of
fices issue an average of two forms. It is a conservative estimate that these 4 000 
uoffices isssue.aet leastd 6 000 (.1.5  times the number of offces) vareties of birdt odoecus  
ments with unique seals or signatures, or printed on different form. This 
not take into account the fact that State and local offices also issue copies of older 
certificates which have seals, signatures, and forms different than the current ones
Based on our conservative estimate of a 1.5 to 1 ratio of documents to offices in 
the States visited, it is reasonable to assume that the approximately 2 900 local of
fice in the remaining States issue about 4 30Q varieties of birh documents dif
ferentiated by unique seals, signatures, or form. We estimated that there are at 
least 10 000 different seals, signatures or forms currently used around the country. 
Including the many older forms issued over the years and stil in use, the estimate 
would be higher. Thus, the problem of variety is even more overwhelmng than 
was suggested by F ACFI. 
II.  THE BIRTH DOCUMENTS 
Print the birth certifcates on a certain type of safety paper that no one else can buy. 
Cut off the supply of paper to counteifeiters.  -- An Eastern State Investigator: 
Most States Visited Provided A Standard Form To Local 
Ofices; But Only 
Some Locals Used Them 
Three quarters of the States contacted reported having a standard birt certificate 
available for local offices to use. However, in only two States were the standard 
forms used throughout the State. In another three States, only some local offces 
used the standard form. Even in the five jurisdictions where a standard form was 
sometimes used, a total of 19 forms, including the standard ones, were used. 
When local offices use these standard forms, which are generally provided free by 
the State, they always add the seal, registrar s signature, and place name of the 
local issuing office. None of the States visited used just one standard form 
throughout their State.  ) .

Most respondents recommended standardizing birth certificates within each State 
to reduce the variety of forms. 
Half The State Offices Visited Were Not Using Safety Paper; 
Locals Generally Did Not 
Six of 12 States did not use safety paper, although three of these States were plan
ning to do so. Highly secure safety paper includes such features as intaglio print
ing, latent images, high resolution borders, and colored background. design. 
These features are commonly found in bank p.ote paper. Local offices in only four 
of the States reported using safety paper, and they also issued some copies on non-
safety paper as well. An INS investigator in the Midwest pointed out that to save 
money, small counties use inexpensive paper ''which you can buy in a comer drug 
store. II 
The extra expense of bank note paper was often cited as an obstacle to its use by 
local registrars and even by some State offices. One registrar estimated the extra 
ents more per copy.
cost of the bank note paper to be at least 13 

The non-safety paper stil used by some States and most localities presents 
numerous problems. Cited as most vulnerable to fraud through alteration or 
counterfeiting were photocopies, plain white paper certificates, and plastic 
registration cards. (See Best Practices in Appendix A.

Seals were also seen as a weak link. Not only were original seals. and certifyg 
stamps at the local level described as ilegible, but respondents noted that the 
stamps and seals can be easily duplicated. 
Physical Security And Document Controllmprovin9 But Stil Spotty, 
As awareness of birth certificate fraud has increased, State efforts to secue birth 
registration and certificate forms appear to have improved. Blank form and seals 
drawers or lockers at J1ght and kept away from public ac
are tyically locked in 
cess during the day. There are exceptions. One State registrar said his two seals 
were put away in a desk but the desk was notlocked. Some States allow the same 
person to handle the processing and answering of requests for copies. This may 
provide more opportunity for theft or fraud to go unnoticed. (See Best Practices 
in Appendix A. 
Insufficient control over blank forms was also noted at the State level. Not all 
States prenumber their forms. While most, if not all, State offices have developed 
systems of numbering, logging numbers as used, and reconcilng against dollars 
collected for fees, there are stil some gaps in security. Examples include:  blank birth certificates and seal stored in the open; 
a microfim file of birth records kept behind the counter; 
documents kept at home by a local registrar; and 
theft of a city's birth certificate forms from a city print shop. 
These examples underline the need to increase security at all stages, from printing 
through issuance of birth documents. The most secure paper is only as safe as the 
procedures for printing, distributing, locking and accounting for it. 
A major reason for local office vulnerabilty to theft, loss, alteration, and counter
feiting is the lack of guidance, standards, or active oversight from most State of
fices regarding security. Accessing indexes and fies of original birth registrations 
is one effective way to get the information needed to apply --legally or ilegally -
for the birth certificate of another person. Persons with fraudulent intent can 
peruse either birth or death records to get the name, date, place of birth, and 
other items (e.g., mother s maiden name) which may be required. 
States' laws and regulations regarding access to vital records var greatly. Either it 
is practically impossible for the public to get into the vault or room where original 
birth registrations or indexes are kept, or it is practically impossible to keep the 
public out during office hours. States with "open records" laws are more vul
nerable to fraud through easy access to records. 
IV.  PROCEDURES
ISSUING 
'Almost anyone can go over to the State and get someone else:S birth certfiate.  -- A, 
An "Open Record" State 
Welfare Fraud Investigator  In 
Fraud; "Open R  States More So 
All  States Vulnerable  To  cord" 
Five of the 12 States visited -- Caliornia, Massachusetts, Minnesota, Vermont and 
Washington -- had laws which classify them as "open record" States. These are 
States, as succinctly stated by a local registrar, in which: "By law, the original birth 
registration is a public record. Anyone can see it and get a copy of it. We have no 
authority to question." Nationwide, 10 of 57 central office issuing jurisdictions had 
open records;" in 43 the records were relatively more protected. The four other 
jurisdictions (Virgin Islands, Guam, American Samoa, and the Trust Territory of 
the Pacific Islands) were not included in this analysis. 
The five "open" States visited allow any individual with the minimum information 
necessary to apply for and obtain a copy of anyone s birth certificate. Offices in 
these States generally do not require any ID from the applicant. States with 
protected record statutes allow copies to be issued only to certain categories of  ... , " 
persons. Typically, those eligible include registrants over 18, parents  guardian or 
legal representatives. However, even in the seven stricter States visited, only two 
reported requiring any ID at the State Registrar s Offce. An investigator in a 
protected" State described a vulnerabilty in the issuing agency s procedures as 
follows: liThe problem in issuing is clerks not knowing who is standing in front of 
them. There s a lack of interest in many local offices in thwarting fraud. It doesn 
seem to affect them. 
As some States and localities move to tighten issuance procedures  How To 
manuals, supplemented by word of mouth, are spreading the word about what 
, for example, an underground-tye publication 
areas to avoid. The  Paper Trip 

on how to create a false identity, warns against requesting a birth certificate in cer
tain States and cities and advises its readers  that you not get dicouraged that 
your efforts appear stymied in a particular area. Go to the next county--or State--and 
try again. Nine times out of 10 you won t believe how 
eas it is. 
All States, whether protected or not, are vulnerable to fraud because  seldom 
il is 
required, fraud prevention has a low priority particularly in local offices, and 
death records can frequently be obtained. 
The Application Process Is Generally Weak, Especially By 
Mail Or Telephone 
All the States visited used application forms for persons requesting a birth certifi
cate. However, most required them only of the 15 to 20 percent of applicants who 
walk into the State offce. In the large majority of requests to the State offce 
which are made by mail (or, in a small but increasing number of cases, by 
telephone), application forms were not generally used. 
The situation was reversed in local offces: walk-ins constituted about 60 percent 
of all applicants, and applications were generally required. The remaining 40 per
cent who requested a copy by mail or telephone did not 
fil out applications. 
Applicants who mail or telephone in their requests, without application form 
usually did not have to give any identification or even provide their signatures. 
Registrars saw mail requests as the most vulnerable mode of request because 
there is no opportunity to question the person as with "walk-ins" and even "phone
ins. 
In the last several years, a growing number of State and local registrars have 
begun to accept applications by telephone. This procedure has been faciltated by 
computer technology. Registrar clerks key into a terminal the necessary informa
tion given by the telephone applicants, including a credit card name and number  to cover the fee. Since there is no way of verifying that the caller is the same per
son whose name is on the credit card or, forthat matter, is eligible for the re
quested certificate, impersonation by telephone is as easy as by maiL 
Even if all applicants were required to complete an application, the current forms 
contained weaknesses. Twenty-one application forms (10 State and 11 local) were 
examined and compared to the Model Application Form for Birth Certifcates 
prepared for FACFI. Among the items contained in nearly all the form, only one 
is not easily known to an outsider: the mother s maiden name. This can be ob
tained from a death certificate. 
As many as a third of the forms failed to call for the following items: the hospital 
or address at which the registrant was born, the full name at birth, and the 
applicant's signature. Even when forms did contain the above items , all of which 
were included in the F ACFI model, the applicant was not routinely required to 
answer each question. In some offices, for example, the applicant' s signature was 
optionaL 
Other items, some of which are hard for potential impostors to know, were not 
generally included. The following items, for example, were included on the 21 
forms less than half the time: 
Percent of Times 
ITM 
Included on Forms 
Purpose of application  43% 
Warning against fraudulent application 
Mother s place of birth 
Father s place of birth 
Mother s address at time of birth 
Number of prior births 
No matter how well the application is designed to discourage fraud, however, it 
wil not be an effective countermeasure unless it is required of mail and telephone 
requesters as well as of "walk-ins. 
Another measure to reduce fraud is to tally the number of requests and flag fre
quently-issued certificates to avoid inappropriate issuance. Many States have not 
taken advantage of this preventive tooL  States Are Matching Birth And Death Records 
A frequently used technique to obtain a birth certificate is the "Infant Death Iden
tity" scheme (Le., getting a certificate for a dead infant with identifyng informa:
tion gleaned from old newspapers or death registers). To combat this, FACFI 
recommended matching of birth and death records. 

More States were found to have begun to match their own birth and de  th records 
in the last few years. The Association for Vital Records and Health Statistics has 
obtained agreement from the States to exchange birth and death and other vital 
records with each other on a regular basis. (See Appendix A. 
A number of problems inhibit the smooth exchange of birth and death certificates 
among the States (and even within States). One problem is the time gap between 
a person s death and the time at which the record is received and the birth record 
marked "deceased. II As long ago as 1971, in anticipating the possibilty of cross 
referencing among States, The Paper Trip I advised: 'There would be a time delay 
loophole in the birth/death matching. Updating would occur probably only once 
per month, which would allow a clever Tripper time enough to obtain a birth cer
tificate of a recently deceased person. 
Some States which match births and deaths did not send notices to local offices to 
enter on their records. Thus, impostors could stil obtain birth certificates of dead 
persons from these local offices. 
Another obstacle to effective matching among the States is the variation in the 
upper age limit for matching deaths. This limit ranged from infancy to 
middle age 
among the States visited. Nor did State registrars 
always agree on the Interstate 
Agreement' s upper age for sending children s death notices to the State of birth. 
The cost of conducting birth/death matches was cited by respondents as a problem 
which could affect the feasibilty of matching records on some sort of national 
basis. Only half the local registrars endorsed the idea and several mentioned fund
ing problems. While the great majority of State registrars and investigators stated 
their belief that such matching was both desirable and feasible, a third of the State 
registrars cautioned about the cost. 

Both A VRHS and NCHS continue to explore ways to expand birth/death match 
activities. The A VRHS has recently surveyed its membership to ascertain the 
readiness of State vital statistics offices to extend their interstate birth/death
matches beyond infancy into adulthood.  .. 
, " 
A project to link infant birth and death records nationally was launched in late 
1986 by NCHS. Although initiated for statistical purposes, the project is further 
developing birth/death match technology. NCHS has also asked States to 
describe their procedures for flagging birth records of deceased infants. The 
results of this evaluation project will be shared with States. 
While there is no agreement on anyone solution, consensus regarding the need 
exists. As stated by a western welfare investigator  If birth records were matched 
with death records and birth certificates were stamped ' deceased' across the front 
they could not be used for fraud. 
In a somewhat related action, the Social Security Administration has been piloting 
a project in three States to issue SSNs to infants at birth at the request of their 
parents. One positive effect of implementing this demonstration nationally would 
be to increase the integrity of the SSA's process for issuing Social Security cards. 
Since most applications for cards made subsequent to the time of birth would be 
for replacement cards only, SSA's built-in internal review of the original applica
tion documents would minimize the use of fraudulent birth certificates as breeder 
documents to falsely obtain Social Security cards. Specifically; SSA does not 
rmecoegninze thte b irthc ceratificrate das asn id.enti fica
 tion document when issuing replace
THE USER AGENCIES 
There are so many diferent types of legitimateform issued by the States, counties, 
and cities that it is impossible to be  few States.  -- An As
familiar with those of even a 
sociate Commissioner Of The Immigration And Naturalization Servce 
Federal And State Agencies Use Birth Certificates Heavily. 
Heavy users of birth certificates submitted by applicants as evidence of eligibilty 
include the following two Federal and two S!ate agencies: 
Social Security Administration. District office claims and servce 
representatives ask for birth certificates as proof of age and citizenship 
when persons first apply for Social Security cards, as proof of age for 
retirement benefits and as proof of both age and citizenship for SSI. 
Birth certificates are also used as proof of age and/or relationship for 
dependents of the primary worker for such programs as Retirement 
Survvor s and Disabilty Insurance. 
Passport Services Of The Department Of State. Examiners, clerks of 
court, and designated post office employees ordinarily require birth 
certificates of first-time passport applicants as proof of citizenship.  , " 
. .
State Human Servces Agencies. Intake and eligibilty workers request 
birth certificates as proof of age or relationship of applicants for: 
Federally-funded programs likeAFDC, Food Stamps, and Medicaid; 
and for State-funded general assistance programs. Besides the problem 
of fraudulent birth certificates, missing or fraudulent social security 
pcarrdso, asg nortead emarliesr, w sereu focunhd to  bae sa m aAjor sFourDce oCf err.o rs
 in
State Driver' s License Agencies. Desk clerks in these user agencies 
prefer birth certificates for proof of age with young applicants. 
Each of these agencies requests a birth certificate when the applicant says it exists. 
However, the agencies differ in the documentation they will ultimately accept. 
Passport servces is most insistent. While SSA will send an applicant home to get 
a certificate or ask a district office in the area where the applicant was born to 
check on the existence of a valid birth record, State agency workers have more 
leeway in accepting alternate documents. When no birth certificate exists, all of 
the agencies wil review such alternate documents as baptismal certificates and 
census documents. 
Most Workers Receive Minimal Training On Birth Certificates 
Workers in user agencies review anywhere from 30 to 350 birth certifcates a 
week. As many as 40 percent of these are from out of State, makng it harder to 
evaluate their authenticity. The situation waS summed up by an investigator with 
a user agency in the South who said: IThere s no way to determne what is authen
talg 
tic with a reasonable degree of success. It' s a big problem. We re  about 
thousands of documents issued from so many sources. There s no control. 
As a result, agency workers reported recognizing an average of only two or three 
suspicious-looking birth certificates in a month, and few of them ended up being 
rejected as invalid. More than one worker echoed the words of a supervsor of a 
multi-service center in a midwestern State who said  I wouldn t know a counter
feit if! saw one. 
The amount of training which workers get inbirth certificate fraud varies by agen
for its field office 
cy. The passport servces has the most active training program 
personnel but it is less extensive for post office employees and clerks of court who 
handle the majority of passport applications. . Senior examners and passport fraud 
coordinators provide on-the-job training in the field offices, and a traing manual 
lists criteria of a good birth certificate.  , " 
, '
Social Security provides some training for its district office staff. It consists 
primarily of initial instruction in document review, followed by distribution of pro
cedures manual updates, regional circulars and other written materials. These 
cite known fraudulent activities, including theft and counterfeiting of birth certifi
cates, which could affect acceptance of applications. 
The majority of SSA workers, however, indicated a need for more training in this 
area. One worker said it was 10 years since she was trained. Another SSA repre
'Training is not intense; it' s sporadic and depends on the inter
sentative said that 
est of the worker." An SSA security officer described the result: liThe amouIit of 
knowledge among workers varies. One persqnwill quote you chapter and verse 
and the person next to him won t know a thing." Nevertheless, SSA offcials state 
that even an extra emphasis on training will not give workers the degree of exper
tcisei theay nleed  tod detoectc falsue dmoceumenntst --  an lexpaertibse susu.ally  fou
 nd only in spe
State welfare and driver s license agencies generally have less well developed 
training programs for their staffs. Several welfare office supervsors said there 
was no awareness among their staffs of the topic since there were no problems in 
their areas. (See Best Practices in Appendix A. 
A special problem was noted in those States where local welfare agencies process 
applications for Social Security numbers on behal of SSA. An earlier HHS/OIG 
report, Controls Over The Social Security Number Application Process, found 
that such local welfare workers receive inadequate trainig in detecting false birth 
certificates. 
The driver s license agencies tyically have had little or no traing for their 
counter clerks regarding birth certificate fraud. One State agency offcial had not 
known any problem with birth certificates existed. (See exceptions in Appendix 
Agency "Service" Mission And Employee Evaluation Criteria Act As 
Disincentives To Ferreting Out Fraud 
The primary mission of SSA, passport services, State welfare, and driver s license 
agencies is to serve the public. While most of them have investigative units, the 
agencies' service philosophies tend to perm  ate the staff even as they try to 
defend against fraud. The emphasis is on moving large numbers of cases efficient
ly through the system. In the words of an investigator  A birth certificate is one 
more check on a blank form; because of the volume, it' s not feasible to do a lot of 
checking. II  Workers were also asked how high a priority their agency placed on stopping 
fraudulent use of birth certificates. While two- thirds of the workers from 
passport servces said it had medium or high priority, none of the SSA staf said 
so. Compounding these obstacles to greater anti-fraud activities is the lack of iIi
centives for workers to do more. For example, no credit is given by SSA fordetec
tion of fraudulent documents under its system of performance evaluation. 
Poor Communication Hinders Deterrence And Detection 
Communication and cooperation among Federal, State, and local investigators 
and between the investigators and State and local registrars took place in every 
State we visited. The extent and effectiveness of such efforts, however, varied 
from good to poor. 
While effective coordination efforts were observed in some cities and States 
visited (see Appendix A), the overall picturepresented to the inspection team 
around the country was that of poor communication among agencies. The spotty 
nature of these efforts was ilustrated by the following items: 
It's one-way communication -- we never hear back. 
ve been waiting over a year for SSA to straighten cases out. 
I've notified the Secretary of State -- it' 
s like talking to a wal1." 
We work close with INS but get no feedback on action it takes on 
referrals. 
Cooperation between State registrars and investigative agencies also varied wide
ly. The California State Registrar, for example, had loaned a microfilm fie of 
vital records to the Los Angeles Passport Office for onsite access (see Appendix 
A). A registrar in another State, however, reportedly would not expeditiously 
verify birth certificates for the passport office there. The lack of formal and coor
dinated information sharing among agencies impacts negatively the abilty of in
vestigators and registrars alike to develop comprehensive plans to effectively 
prevent and detect birth certificate fraud. 
When asked what the Federal government should do to help prevent birth certifi
cate fraud, respondents were most likely to urge closer coordination and com
munication between Federal and State agencies, including developing nationwide 
information networks and sponsoring interagency meetings. A State registrar in 
the West summed it up: "The issue has national impact and therefore demands a 
cooperative effort between Federal and State Governents.  Inadequate Laws And Priority On "Big Bucks" Cases Hinders Prosecution 
Effective sanctions against perpetrators of birth certificate fraud are hindered by 
laws viewed as inadequate and by resistance to prosecuting individuals who 
misuse birth certificates unless large sums of money are involved. 
The historical inadequacy of Federal and State laws for charging in9ividuals who 
are involved in birth certificate fraud was described in theF ACFI report. As a 
result of its recommendations, Title 18 USC, Section 1028 was passed as par of 
the False Identification Crime Control Act of 1982 which closed some ofthe exist
ing loopholes in Federal statutes. This new statute has been used 
successfully to 
prosecute and convict persons involved in birth certificate fraud. Overall, it is 
viewed as a positive step. 
Two problems were noted with Section 1028. One investigator felt it was too 
limited because it does not make possession of a fraudulent State document such 
as a birth certificate, an offense unless there is either a Federal doromentin
volved, evidence of defrauding the United States or the use of the mails. Another 
problem mentioned was the lack of publicity given to the availabilty and ad
vantages of the statute. 
Progress in obtaining new State legislation has been slow. A few States have 
passed statutes aimed at fraudulent identification and/or restricted access to vital 
records. A number of respondents, however, emphasized the lack of adequate 
laws in their own States. 

. In addition, there is a reluctance on the part of most prosecutors and some inves
tigators to pursue individual perpetrators of birth certificate fraud. They are 
usually charged with the crime committed under a false identity, rather than with 
the birth certificate fraud itself. A low priority is  cries of ob
tyically given to 
taining false identity because, until subsequent criminal activities occur, few dol
lars are likely to be involved.  RECOMMENDATIONS

Since the production and issuance of legal birth certificates are clearly State and local 
functions, recommendations are directed to officials at the State level. It is hoped that 
the findings of this national inspection will encourage a concerted effort by State 
registrars to attain greater standardization of birth certificate forms (Le., certifed copies) 
and procedures, expanded use of safety paper, increased security of documents, stricter 
access and application procedures, and increased participation in national efforts to 
prevent birth certificate fraud. To be effective, such efforts must include both stricter is
suance and more tamper proof documents. Neither by itself is sufficient. 
Such efforts by registrars will be most effective where they have the support of their 
Governors, their legislatures, and such national assQciations as the National Governors 
Association and the Association for Vital Records and Health Statistics. 
, should: 
It is recommended that State registrars, with the support of their Governors and the 
above groups as needed
Standardize the form and content of birth certificates within their State 
including the incorporation of document security features to protect birth 
documents against alteration and counterfeiting. Such document security 
should include the use of bank note-tye safety paper with unique security 
characteristics, such as intaglio printing, high resolution borders, latent 
images, varying color tones, hidden errors, and latent "void" markings. 
Promote greater intra-State standardization of birth certificate form and 
issuance procedures, through State legislation if necessar, by reducing 
substantially the number of local issuing offices and/or by exercising greater 
control over local forms and procedures. 
Establish minimum standards for the physical security of vital records 
certified copy blanks, and seals against theft by providing secure storage, 24 
hours a day, of blank forms and record fies, and by a system of strict 
accountabilty for all certified copy blans through prenumbering and other 
controls. 
Urge legislatures to amend existing statutes, or pass new ones, to protect 
the privacy of individual vital records by restricting physical access to such 
records, and by strictly limiting applications for certified copies to those who 
have direct and tangible interest and can provide adequate identification.  Assure that their States participate fully in and help expand A VRHS' 
voluntary Interstate Vital Records Exchange SysteInto include the.sharng 
of death records.for persons substal1tially beyond infancy for purposes of 
matching with birth records; and adopt a standard procedure for overlaying 
the word "Deceased" on original and certified copies of birth records of 
persons who have died. 
Work cooperatively with the Social Security Administration in its pilot 
efforts to establish procedures whereby a parent can receive an infant' 
Social Security card at the time the infant's birth is registered, and in the 
long run help reduce the utilty of a false birh certificate as a breeder 
document of a false identity.  APPENDIX A. 
BEST PRACTICES 
The inspection team noted a number of State and local fraud prevention activities on the 
part of registrars and State user agencies which it considers to be best practices. They are 
described here so that other States and localities may consider adapting them. They in
clude best practices with respect to centralization issuance, standardization of docu
ments, security of paper, security of documents, secure issuing procedures, user agency 
staff training, and effective communication. They are not meant to be a complete listing 
of existing models even in States visited. 
Centralization of Issuance 
While most State registrars allow their local offices to issue birth 
certificates, 16 States (Arkansas, Arizona, Delaware, Hawaii, Idaho 
Kansas, Kentucky, Louisiana, Marland, Missouri, Nebraska, Nevada 
New Mexico, Tennessee, Wyoming, and Virginia) plus New York City 
and the District of Columbia, according to information available, either 
sharply curtailed local issuance or had no local offices. About 14 of 
these jurisdictions permitted issuance only by the State office, and 
another five limited local issuanceto less than a handful of large local 
offices. 
Two States visited (Florida and Ilinois) sent field representatives to 
monitor local offices at least once a year. 

Standardization of Birth Documents 
Virginia, with no local offices issuing birth certificates, used several 
standardized State forms of certified copies throughout the State. New 
York City similarly issues standardized forms throughout its five 
boroughs. 
Three States (Californa, Vermont, and Washington) reported that State 
forms issued to local offices (free of charge in the latter two) were
routinely used. 
Security of Paper 
Of the seven visited States using some tye of security, five (Caliornia 
Ilinois, Texas, Virginia, and Vermont) were using highly secure paper  including such features as intaglio printing, latent images, high 
resolution borders, and colored background design. 
The city registrar in Detroit issued birth certificate copies on safety 
paper that was watermarked and would reveal the word "Void" if 
photocopied or treated with ink eradicator. 
Secure Issuing Procedures 
several State offices (e.  , Michigan and Washington), incidents of
In 
theft and fraud led to a separation of duties among staff responsible for 
processing and answering requests for copies. Such action precluded 
anyone person from responsibilty for all steps in the process. 
Following the lead of States like California, all but one of the visited 
States routinely matched birth and death records. Also, most marked 
deceased" on the birth records which are then released with the 
deceased" overlay, or are flagged for non-release. 
This increase in matching activity is due in part to the efforts of the 
A VRHS in promoting its Agreement for Administering the Interstate 
Vital Records Exchange System. These agreements signed by all State 
Registrars Offices, New York City, the District of Columbia, Guam, 
Puerto Rico, the Virgin Islands, and Canadian Provinces call for: (1) 
sending birth, death, and other records relating to non-residents to the 
State or Province where the individual usually resided; and (2) sending 
death certificates for infants under 1 year old to the State of birth. 
One factor cited to support national birth/death matches is the 
increasing computerization of State vital records. Of the 12 States 
surveyed, five issued computerized copies and five more had plan to do 
so. 
User Agency Staff Training 
The outreach program established by the Bureau of Client Fraud 
Investigation in New York City has developed a training and awareness 
program for selected welfare staff: 
The Michigan Department of State has developed a pilot training 
document for staff in the Detroit area; and the Florida Division of 
Driver s Licenses had an aggressive program for its employees 
statewide. This training reportedly led to an increase in arrest rates.  , " 
When training has been provided to workers in user agencies, it has 
often been with the cooperation of fraud investigators from their own 
and other agencies. The INS special agents, and passport fraud 
coordinators in particular, have joined with SSA Security Officers, 
HHS/OIG agents, welfare investigators and State and local registrars to 
provide such training. 
Effective Communication 
Where communication and collaboration does take place, it is often the result of 
informal networking among individuals-- investigators and registrars--who have 
developed working relationships. In Detroit, for example, the following joint ac
tivities were reported: 
City and suburban bank investigators met monthly together with State 
and local police, Secret Servce, the Postal Inspector and others to 
il. 
discuss problems of fraudulent 
The Detroit Office of the Secretary of State sent details of fraudulent 
driver s license requests to the bank investigators' group as well as to the 
State registrar. The bank, in turn, gave fraudulent driver s license 
numbers to the Secretary of State. 
The City registrar alerted the State registrar to fraudulent requests so 
they could tag the birth certificate in the State office. If there was a 
Inspector. . 
problem with mail requests, the City referred them to the Postal
According to the INS investigator  If the passport offce in Chicago has 
a case that appears to be an immgration case, they send it to us and we 
send them a copy of a finished report." 
An example of effective coordination between a State registrar and passport agen
cies was observed in California as follows: 
In 1983, the California State registrar agreed to loan copies of birth and 
death records to the passport office in San Francisco. The project was 
so successful in expediting the verification of record authenticity that it 
was expanded to include the Los Angeles Passport Office. In 1985, the 
San Francisco office detected at least eight birth certificates for 
deceased individuals which were sllbmitted with applications.  APPENDIX a

COMMENTS ON DRAFT REPORT AND OIG COMMENTS 
The HHS comments on the draf report were received from the Administrator of Health 
Care Financing Administration, the Deputy Assistant Secretar for Health Operations of 
the Public Health Service and the Commssioner of Social Security. From outside HHS 
they were received from the President of the Association for Vital Records and Health 
Statistics, and the Director of the Offce of Consular Fraud Prevention Program of the 
S. Department of State. 
The Public Health Servce commented that the use of the term "birth certificate 
throughout the report made no clear distinction between original birth records and cer
tified copies based on those records. Several technical comments were also made by 
PHS regarding the number of issuing jurisdictions, whether any States did not routinely 
match birth and death records, and which States curtail local offce issuances of birth cer
tificates. 
A statement is added at the beginnng of the report which 
The DIG response. 

clearly states that in the report we refer to certified copies as "birth certificates" as 
distinct from the original birth records or registration on which certified copies 
are based. We also checked each technical comment and made appropriate chan
ges. 
The A VRHS expressed concern about the lack of documentation of the scope of the 
fraud problem and suggested a stronger statement to help convince States of the need for 
change. 
We added additional statements supporting the view that 
The DIG response. 

problems of false identification in general  fraud in par
ap.d of birth certificate 
ticular are likely to be increasing as a result of the Immigration Reform and Con-
trol Act. 
The A VRHS also pointed out that the National Center for Health Statistics is not in a 
birt 
position to match records since States do not provide NCHS with identifiers on 
records. 
Reference to NCHS as a possible coordinating agency with 
The DIG response. 

regards to a national birth/death match is deleted. We also refer to an A VRHS 
survey of States' wilingness to expand their interstate exchange of birth and death 
information to include deceased persons substantially beyond infancy.  The recommendation (#2) that States reduce the number of local issuing offices and/or 
exercise greater control over them, according to A VRHS, would require legislative ac
tion in many States. 
This point is acknowledged in the recommendation.
The DIG response. 

The recommendation (#5) which calls for strengthening A VRHS' voluntary Interstate 
Vital Records Exchange, was viewed favorably by PHS. The agency noted, however, that 
the exchange would have to be expanded beyond inant deaths to be effective against 
fraud. 
The wording was changed from "strengthen" to "expand..to in
The DIG response. 

clude the sharing of death records for persons substantially beyond infancy. 
The recommendation (#6) that States work cooperatively with SSA to establish proce
dures for issuing infants an SSN at the time of birth was the subject of two comments. 
update on their pilot project was provided by SSA;and PHS did not see the relevance of 
the recommendation to birth certificate fraud. 
Our description of SSA's pilot project in the findings was up
The DIG response. 

dated and its potential relevance to birth certificate fraud was indicated. 
The Department of State and HCF A both suggested more specific recommendations. 
The HCFA, while acknowledging the limitations of the Federal role, suggested the 
report "include more definitive guidelines for actively coordinating efforts among the 
various parties..." The State Department offered two specific recommendations. The 
first is for State and local registrars to develop a set of criteria to be required on applica
tions for birth certificate copies. The second is that "registrars should be furnshed with a 
pur
set of data which must be provided for documents to be acceptable for Federal 
poses." Specific items were suggested. 
Having carefully considered what Federal actions might be
The DIG response. 

feasible and effective in coordinating efforts to reduce birth certificate fraud, it 
was concluded that States hold the key to stricter issuance and more tamper-proof 
documents. The OIG recommendations call for coordinated actions by registrars 
with the support of their Governors, the National Governors Association and 
A VRHS. Best practices in collaboration among public and private agencies are 
listed for others to consider. On the matter of application form criteria, we have 
referred to the Model Application Form prepared by F ACFI which includes many 
items generally not included on State forms. Finally, we agree it would be useful 
as a long-range strategy to have Federal agencies agree on minium information 
which they would require for birth certificates to be acceptable for Federal pur
poses. We felt, however, that other actions were more feasible at this time.