SUPPLEMENTAL 

SECURITY INCOME

Wages Reported for 

Recipients Show 

Indications of 

Possible SSN Misuse

Report to Congressional Requesters

July 2014

GAO-14-597

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-597, a report to 

congressional requesters

July 2014

SUPPLEMENTAL SECURITY INCOME

Wages Reported for Recipients Show Indications of 

Possible SSN Misuse

Why GAO Did This Study

In fiscal year 2012, SSA estimated it 

paid over $53.4 billion to SSI 

recipients, of which 8.1 percent, or 

$4.3 billion, SSA estimated to have 

been improper payments. The SSI 

program pays benefits to the aged, 

blind or disabled adults and children 

with limited income and resources.

GAO was asked to analyze potentially 

improper SSA disability payments. This

report identifies potential SSI 

overpayments and indicators of 

possible SSN misuse. SSA provided 

GAO with a onetime file extract of SSI 

recipients as of December 2010 and 

the matching income from both the

quarterly wage and unemployment 

insurance components of the NDNH

database that included fiscal year 

2010. GAO compared the SSI benefit 

and NDNH income data to identify 

potential overpayments. GAO 

randomly selected five individuals for 

case-file review. These cases cannot 

be projected to the overpayment 

population but provide illustrative 

examples of possible SSN misuse.

What GAO Recommends

GAO recommends that the Acting 

Commissioner of Social Security work 

with the Secretary of Homeland 

Security to identify the data useful to 

DHS’s work-site enforcement strategy 

and seek legislative authority to obtain 

such information, as appropriate. DHS 

agreed with GAO’s recommendation

and SSA agreed to the intent of the 

recommendation, but did not agree to 

seek legislative authority. GAO still 

believes this recommendation is valid 

as discussed in the report to help the 

federal government better utilize the 

complementary sources of data 

available at SSA. 

What GAO Found

GAO’s analysis of wages reported in the National Directory of New Hires (NDNH) 

initially showed that the Social Security Administration (SSA) made $19 million in 

potential overpayments to 10,187 recipients through its Supplemental Security 

Income (SSI) program in fiscal year 2010. Using a different methodology that 

includes additional causes of overpayments not considered in GAO’s analysis, 

SSA estimated it made $3.3 billion in SSI overpayments in fiscal year 2010. The 

majority (70 percent) of the estimated overpayment amount GAO identified 

showed indications of possible Social Security number (SSN) misuse, such as 

employers reporting wages for recipients in multiple locations during the same 

quarter. For example, GAO determined that wages for 2,399 SSI recipients were 

reported solely by employers outside the recipient’s state of residence. As the 

figure below shows, one individual in California had wages reported from 11 

different employers in seven other states during the same quarter of calendar 

year 2010. This suggests that multiple individuals may be using the SSI 

recipient’s SSN and name for work. The exact number of individuals who 

received overpayments and the exact amount of overpayments made to those 

individuals cannot be determined without detailed case investigations by SSA. 

GAO analyzed five recipient cases and provided the results to SSA.

Supplemental Security Income (SSI) Recipient with Reported Wages in Seven Different States

GAO analyzed employers with wages for SSI recipients from outside the 

recipient’s state and found nine employers who reported wages for 15 or more 

SSI recipients during the same quarter who lived in different states from the 

employer’s location. For example, a plant located in one state reported wages for 

22 SSI recipients who lived in six other states, indicating possible SSN misuse. 

SSA has previously reported that privacy and disclosure issues have limited its 

ability to routinely share information with the Department of Homeland Security 

(DHS), which is responsible for enforcing employer compliance with immigration 

laws through its work-site enforcement strategy. Reviewing SSI wages at a 

summary level can provide information on certain employers that have high 

incidences of inaccurate wage reports. The ability to share information regarding 

potential unauthorized employment could enhance SSA’s ability to address SSN 

misuse and help DHS better target its work-site enforcement efforts.

View GAO-14-597. For more information, 

contact Seto J. Bagdoyan at (202) 512-6722

or BagdoyanS@gao.gov.
Page i GAO-14-597 Supplemental Security Income 

Letter 1

Background 3

Potential Overpayments to SSI Recipients in Fiscal Year 2010 

Show Indications of Possible SSN Misuse 6

Conclusions 16

Recommendation for Executive Action 16

Agency Comments and Our Evaluation 17

Appendix I Objective, Scope, and Methodology 20

Appendix II Comments from the Department of Homeland Security 24

Appendix III Comments from the Social Security Administration 26

GAO Comments 30

Figures

Figure 1: Overpayment Estimate of Supplemental Security Income 

(SSI) Recipients with Indications of Possible Social 

Security Number (SSN) Misuse in Fiscal Year 2010 8

Figure 2: Supplemental Security Income Recipient with Reported 

Wages in Seven Different States 10

Figure 3: Employer with Reported Wages for Supplemental 

Security Income Recipients in Distant States 12

Contents
Page ii GAO-14-597 Supplemental Security Income 

Abbreviations

DHS Department of Homeland Security

DI Disability Insurance

EIN Employer Identification Number

HSI Homeland Security Investigations

NDNH National Directory of New Hires

OIG Office of the Inspector General

OMB Office of Management and Budget

SSA Social Security Administration

SSI Supplemental Security Income

SSN Social Security number

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Page 1 GAO-14-597 Supplemental Security Income 

441 G St. N.W.

Washington, DC 20548

July 16, 2014

Congressional Requesters

The Supplemental Security Income (SSI) program, which is administered 

by the Social Security Administration (SSA), provides cash assistance to 

financially needy individuals who are aged, blind, or disabled. The SSI 

program is currently 1 of the 13 programs designated by the Office of 

Management and Budget (OMB) as being “high-error” programs for 

improper payments.1 In this regard, during fiscal year 2012, SSA 

estimated it paid over $53.4 billion to SSI recipients, of which 8.1 percent, 

or $4.3 billion, SSA estimated to have been improper payments 

(overpayments and underpayments).2 Furthermore, SSA attributed 59 

percent of SSI improper payments in fiscal year 2012 to verification and 

administration errors—such as the detection of unreported financial 

accounts and wages—among other things. Individuals are not eligible for 

SSI payments for any period during which they have income or resources 

that exceed the allowable amounts established under the Social Security 

Act, which also requires SSA to verify information on income and 

resources to ensure that payments are correct and are only provided to 

eligible individuals.3

Our prior work has found that weaknesses in SSA’s process for reviewing 

recipients’ work activity have hindered the agency’s ability to identify and 

The accuracy of earnings information is important 

since earnings affect a recipient’s SSI eligibility and payment amount.

 1

High-error programs are those programs that (1) measured and reported errors above 

the threshold determined by OMB and contributed to the majority of improper payments; 

(2) have not reported an improper payment dollar amount, but have in the past reported 

errors above the threshold; or (3) have not yet reported an overall program improper 

payment dollar amount, but the aggregate of the measured program’s component errors 

are above the threshold. The fiscal year 2010 threshold was $750 million in improper 

payments.

2

Total federally administered payments represent estimated program outlays and may 

vary from actual outlays. SSI statistical precision is at a 95 percent confidence level.

Confidence intervals for fiscal year 2012 are ±0.53 percent for underpayments and ±1.78 

percent for overpayments.

3

42 U.S.C. §§ 1381 et seq.
Page 2 GAO-14-597 Supplemental Security Income 

review recipient income, which affects eligibility for disability benefits.4

This report is the third in a series that responds to your request to 

examine employment-related databases and analyze potentially improper 

SSA disability payments. Accordingly, this report compares SSA data with 

income reported in the National Directory of New Hires (NDNH) to identify 

potential SSI overpayments and indicators of possible Social Security 

number (SSN) misuse.5

For our prior work, SSA provided us with a one-time file extract containing 

SSI recipients as of December 2010 and the matching income information 

from both the quarterly wage and unemployment insurance components 

of the NDNH database that included fiscal year 2010.

The exact number of individuals who received 

SSI overpayments and the exact amount of overpayments made to those 

individuals cannot be determined without detailed case investigations by 

SSA. Hence, we refer to “potential overpayments” throughout this report.

6

 4

Our earlier work focused on SSA’s Disability Insurance (DI) program, which is the 

nation’s largest cash-assistance program for workers with disabilities. See GAO, Disability 

Insurance: Work Activity Indicates Certain Social Security Disability Insurance Payments 

Were Potentially Improper, 

Since this extract 

is the most-recent NDNH data available to us, our analysis of SSI 

beneficiaries with income in the NDNH is limited to fiscal year 2010. To 

determine the subset of recipients who received potential overpayments 

during fiscal year 2010, we identified individuals who received SSI 

benefits in fiscal year 2010 and who also had records in the NDNH 

indicating the receipt of wages or unemployment insurance in the 

corresponding quarter of fiscal year 2010. For each individual, we 

compared the amount of all income in the NDNH to the maximum 

allowable income as specified by SSA and compared this amount to the 

monthly SSI benefit amounts in SSA’s files to determine the total amount 

of overpayment. Through comparison of these benefit amounts and 

income, we were able to identify potential SSI overpayments.

GAO-13-635 (Washington, D.C.: Aug. 15, 2013) and Disability 

Insurance: SSA Can Improve Efforts to Detect, Prevent, and Recover Overpayments, 

GAO-11-724 (Washington, D.C.: July 27, 2011).

5

The Department of Health and Human Services’ Office of Child Support Enforcement’s 

NDNH contains quarterly state wage information, which is more recent than the annual 

wage information that SSA obtains through its current Internal Revenue Service data 

match. SSA currently uses the NDNH to periodically monitor the earnings of SSI 

recipients. According to SSA Office of the Inspector General (OIG), SSN misuse is 

described as one person using another’s name and SSN for work purposes.

6

GAO-11-724 and GAO-13-635.
Page 3 GAO-14-597 Supplemental Security Income 

In addition to our overall analysis, we randomly selected five individuals 

for additional review of detailed SSI case-file information from a 

population of individuals who were reported as receiving wages from four 

or more states other than the state of residence on their SSA record 

during the same quarter.7

To determine the reliability of the SSA disability records and NDNH data, 

we reviewed documentation related to these databases and interviewed 

officials responsible for compiling and maintaining relevant SSI and 

NDNH data. In addition, we performed electronic testing to determine the 

validity of specific data elements in the databases that we used to 

perform our work. We also reviewed detailed SSA case files for the 

nongeneralizable selection of five individuals selected for additional 

analysis to corroborate the NDNH and SSA data. On the basis of our 

discussions with agency officials, our review of related documentation, 

and our own testing, we concluded that the data elements used for this 

report were sufficiently reliable for our purposes. See appendix I for more 

information on our objective, scope, and methodology.

Because we selected a small number of 

individuals for further analysis, the result of these five cases cannot be 

projected to the entire population of individuals. To develop the five 

cases, we reviewed relevant SSA case-file documents and interviewed 

SSI program officials.

We conducted this performance audit from April 2013 to July 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objective.

The SSI program pays benefits to the aged, blind or disabled adults, and 

children who have limited income and resources. To determine whether 

an SSI applicant is financially eligible, SSA is to perform an initial 

determination at the time of application, and to conduct periodic reviews 

to determine whether the recipient remains eligible. SSI recipients are 

 7

Individuals had to have wages reported from four or more separate states during the 

same quarter. “Four or more states” was utilized as a criterion because it is unlikely that 

an individual could work simultaneously in four or more states in one quarter, although it is 

possible for individuals that live near a state border to work in the neighboring state.

Background
Page 4 GAO-14-597 Supplemental Security Income 

required to report events that may affect their financial eligibility for 

benefits, including changes in income, resources, marital status, and 

living arrangements. SSI generally reduces the monthly benefit by $1 for 

every $2 of monthly earnings after the first $85.8

SSA matches computerized data from other federal and state agencies to 

help verify that the recipients’ case information is correct. SSA accesses 

the NDNH by means of routine file matches to verify eligibility and 

payment amounts under the SSI program.9 During SSA’s incomeverification process, SSA systems generate an alert when a match 

between the SSA record and the verified quarterly wage file shows there 

are significant overreported or underreported wages. SSA uses 

established criteria, such as tolerances, to generate the alerts and post 

them to the recipient’s record for future review and development by fieldoffice staff to determine whether the discrepancies affect SSI benefits.10

The NDNH database, administered by the Department of Health and 

Human Services, contains employment data on newly hired employees 

(form W-4), quarterly wage data on individual employees, and 

unemployment insurance data. In order to verify the accuracy of data in 

the NDNH, the department transmits the NDNH data to SSA to verify the 

accuracy of the SSN and its related name against information in the SSA 

database. When the NDNH receives notification that the SSN is verified, 

 8

According to SSA, the first $65 (up to a maximum of $85 if the individual has no income 

other than earnings) of any monthly earned income plus one-half of remaining earnings 

are excluded for SSI benefit computation purposes. 

9

SSA matches the SSI data against the NDNH database, looking for significant wage 

discrepancies between reported income by SSI recipients and income reported by 

employers.

10An alert is generated when the wage amount for a quarter exceeds the Supplemental 

Security Record wage amount for that quarter by more than the “tolerance.” The tolerance 

for a recipient’s wage is $250 for a quarter. An alert will not be generated for selfemployment income because it is reported annually, not quarterly.
Page 5 GAO-14-597 Supplemental Security Income 

the system then adds the data to the NDNH database. If the SSN is not 

verified it is either rejected or posted to separate files within the NDNH.11

GAO and the SSA Office of the Inspector General (OIG) have previously 

identified patterns of errors and irregularities in wage reporting, including 

SSN misuse. For example, in January 2001 the SSA OIG reported that 

employers in the agriculture industry submit thousands of wage items for 

which the employee’s name or SSN does not match SSA records.12 In 

April 2005, the SSA OIG also identified the top 100 employers in each of 

the service, restaurant, and agriculture industries that contribute the most 

reporting irregularities.13 Several of the employers and industry 

associations that spoke with the SSA OIG for its April 2005 report stated 

that unauthorized noncitizens contribute to SSN misuse. In 2005, we 

reported that employers in certain industry categories are more likely than 

others to submit reports with invalid worker identity information. Some 

employers exhibit a pattern of errors year after year, such as using one 

SSN for more than one worker in multiple tax years.14

According to SSA, SSN misuse can cause errors in wage reporting when 

earnings for one individual are incorrectly reported to the record of 

another person having a similar surname. An individual, such as an 

unauthorized noncitizen obtaining work in the United States, can also 

deliberately use the name and SSN of another individual, which 

contributes to SSN misuse. When an individual assumes another 

person’s identity to work in the United States using the number holder’s 

actual SSN and name to do so, wages reported for that individual will be 

 11Some states’ quarterly wage records include only a partial set of letters, or no letters, in 

the employees’ names. When these states send their records to the NDNH, the system 

checks the SSN to determine whether it is within the range of SSNs that have been issued 

to date by SSA. Records with SSNs outside the issued range are rejected. If the SSN is 

within the range, the system attempts verification. If the SSN/name combination is not 

verified, the system accepts the record and stores it in the quarterly wage Non-Verifiable 

or Unverified files.

12Social Security Administration, Office of the Inspector General, Obstacles to Reducing 

Social Security Number Misuse in the Agriculture Industry, A-08-99-41004 (Jan. 22, 

2001).

13Social Security Administration, Office of the Inspector General, Social Security Number 

Misuse in the Service, Restaurant, and Agriculture Industries, A-08-05-25023 (Apr. 29, 

2005).

14See GAO, Social Security: Better Coordination among Federal Agencies Could Reduce 

Unidentified Earnings Reports, GAO-05-154 (Washington, D.C.: Feb. 4, 2005).
Page 6 GAO-14-597 Supplemental Security Income 

posted to the true number holder’s account. According to SSA policy, if 

earnings are identified that do not belong to the number holder, the 

individual may submit a signed statement “disclaiming” the wages as his 

or her own and have the earnings removed from his or her Master 

Earnings File.15

According to SSA, in 2010, the SSI program made a total of $44.6 billion 

in payments to 8.9 million recipients. Our analysis of income reported in 

the NDNH initially showed that SSA made $19 million in potential SSI 

overpayments to 10,187 SSI recipients in fiscal year 2010, but 

approximately 70 percent of the total overpayment amount showed 

indications of possible SSN misuse, such as individuals with wages 

reported from employers in multiple states during the same quarter, so we 

were unable to determine whether the recipients actually received SSI 

overpayments.16

Based on comparisons of SSI beneficiary records with quarterly wage 

and unemployment records included in the NDNH, we initially estimated 

that SSA made $19 million in potential SSI overpayments to 10,187 SSI 

recipients in fiscal year 2010. Using a different methodology that includes 

additional causes of overpayments not considered in GAO’s analysis, 

SSA estimated to have made $3.3 billion in SSI overpayments in fiscal 

year 2010.

We also found employers with high incidences of 

inaccurate wage reports and identified information that could be shared 

with the Department of Homeland Security (DHS) to help address 

possible SSN misuse.

17

 15The Master Earnings File is the main source of SSA’s earnings data. SSA uses earnings 

information received from the Internal Revenue Service, including quarterly earnings 

records, and annual income-tax forms to calculate benefit amounts, and stores this 

earnings information as the Master Earnings File.

SSA also considers other causes of overpayments such as 

pensions; resources such as real estate, bank accounts, cash, stocks,

and bonds; and living arrangements. The 10,187 recipients we identified 

16Due to indications of potential SSN misuse, we refer to our SSI overpayment population 

as “potential” overpayments. It is important to note that it is not possible to determine from 

data analysis alone the extent to which SSA made improper benefit payments to these 

individuals since a detailed evaluation of all the facts and circumstances must be 

conducted for each recipient. This evaluation would include contacting the recipient and 

the employer to gather information. 

17Figure obtained from Social Security Administration, Fiscal Year 2011 Performance and 

Accountability Report.

Potential 

Overpayments to SSI 

Recipients in Fiscal 

Year 2010 Show 

Indications of 

Possible SSN Misuse

Analysis of 2010 Data 

Identified Potential 

Overpayments and 

Possible SSN Misuse
Page 7 GAO-14-597 Supplemental Security Income 

received a monthly SSI payment when, based on our analysis, they were 

potentially not entitled to any benefits. All of these individuals appeared to 

receive income in fiscal year 2010 above the maximum SSI program 

threshold—$1,433 per month—while also receiving SSI payments.

However, as discussed below, we found indications of some possible 

SSN misuse and were therefore unable to determine the extent to which 

SSI overpayments were due to income earned by the recipient and 

reported in the NDNH.

As shown in figure 1 below, more than 40 percent of our identified 

population of 10,187 SSI recipients (4,228 SSI recipients) and about 70 

percent of our original overpayment estimate ($13.2 million) showed 

indications of possible SSN misuse.
Page 8 GAO-14-597 Supplemental Security Income 

Figure 1: Overpayment Estimate of Supplemental Security Income (SSI) Recipients with Indications of Possible Social 

Security Number (SSN) Misuse in Fiscal Year 2010

Note: The exact number of individuals with possible SSN misuse cannot be determined without a 

detailed case investigation by SSA.

During our analysis, we identified instances in which SSI recipients were 

reported as having received wages by employers from different states 

than what was reported as their state of residence on their SSA record.

We conducted additional analysis of our potential overpayment population 
Page 9 GAO-14-597 Supplemental Security Income 

to determine the extent to which such out-of-state wages occurred. We 

determined that for our potential overpayment population of 10,187 

recipients, wages for 2,399 SSI recipients were reported solely by 

employers located outside the recipient’s state of residence. Of those 

2,399 individuals, 21 were reported as receiving wages by employers 

from four or more different states than what was reported as their state of 

residence on their SSA records during the same quarter. We randomly 

selected 5 recipients from this group of 21 for additional review of detailed 

SSI case-file information.

Our case-file reviews for these five recipients are nongeneralizable (i.e., 

cannot be projected to the entire population of individuals) but identify 

possible instances of SSN misuse. For each of the five cases, wages 

reported in the NDNH triggered alerts to SSI caseworkers for follow-up. 

However, all five of the recipients had evidence in their case files of 

wages being disclaimed. Under SSA’s procedures for disclaiming wages, 

recipients can provide SSA with a signed statement attesting that the 

wages being reported for their SSN were not earned by them. One of the 

recipients disclaimed wages as far back as 2004, and has repeatedly 

disclaimed wages every year from 2009 to 2012. Once a recipient 

disclaims wages, the SSI caseworker then is to take an additional step to 

remove the disclaimed earnings from the Master Earnings File. According 

to SSA, the agency had already referred four of the five recipients to 

SSA’s OIG for further investigation. SSA OIG stated that it reviewed the 

four cases, but the cases were subsequently closed due to insufficient 

details that hindered its ability to make a determination as to which 

individual was possibly misusing the SSN.

The five cases we reviewed also indicated possible SSN misuse. For 

example, as shown in figure 2 below, one individual living in California 

had wages reported in the NDNH from 11 different employers in seven

other states that were many miles away during the same quarter of 

calendar year 2010. This suggests that multiple individuals may have 

been using the SSI recipient’s SSN and name for work purposes. We 

recognize there are instances when individuals could work for multiple 

employers simultaneously. However, it is questionable that one person 

could work for multiple employers simultaneously in different regions of 

the country during the same quarter.
Page 10 GAO-14-597 Supplemental Security Income 

Figure 2: Supplemental Security Income Recipient with Reported Wages in Seven Different States

Of the 10,187 individuals we identified as having received potential SSI 

overpayments, we also identified another 582 SSI recipients with wages 

reported from employers both outside and within their home state during 

the same quarter. Wages reported for the remaining portion of our 

overpayment population were solely from employers inside their state.

However, this subset of recipients also showed indications of possible 

misuse. A total of 1,247 in-state recipients had multiple employers report 
Page 11 GAO-14-597 Supplemental Security Income 

wages during the same quarter. For example, we identified one individual 

who, according to SSA’s records, lives in a border town in south Texas, 

but had wages reported in the NDNH from four different employers during 

the same quarter of calendar year 2010 located hundreds of miles away 

in the Dallas / Fort Worth and Houston, Texas, areas.

We recognize that it is possible for individuals that live near a state border 

to work in the neighboring state or for individuals to change their 

employer within a 3-month quarter for which wages are reported.

However, without a detailed case-file review that includes contacting the 

recipient to determine if reported wages should be disclaimed, it is 

impossible to determine whether the wages reported by employers in 

other states that are many miles away are attributable to a single SSI 

recipient or to other individuals misusing the recipient’s SSN.

After determining the extent to which individuals had wages reported from 

outside their state, we analyzed the employers that reported those wages.

As another sign of possible SSN misuse, our analysis identified nine 

employers who reported wages for 15 or more SSI recipients during the 

same quarter that, according to SSA’s records, lived in different states 

from the employer’s location. For example, as shown in figure 3 below, 

one meat plant with a single Indiana location reported wages for 22 SSI 

recipients whose SSA records indicated that they lived in other states that 

were many miles away: namely California, Louisiana, Massachusetts, 

New York, Pennsylvania, and Texas. According to SSA’s records, none of 

the SSI recipients we detected in the wages reported by this employer 

actually lived in Indiana. This suggests that the Indiana plant workers may 

have been improperly using the SSNs of SSI recipients living in other 

states, or that the SSI recipients were actively working in other states 

while claiming SSI.

Certain Employers Had 

High Incidence of 

Questionable Wage 

Reporting
Page 12 GAO-14-597 Supplemental Security Income 

Figure 3: Employer with Reported Wages for Supplemental Security Income Recipients in Distant States
Page 13 GAO-14-597 Supplemental Security Income 

According to an August 2013 SSA OIG report, SSA staff stated that some 

employers hire unauthorized workers because they know SSA has no 

legal authority to levy fines and penalties, and they are not concerned 

about potential Internal Revenue Service sanctions.18 DHS is responsible 

for granting aliens permission to work in the United States, and for 

enforcing compliance of employers with immigration laws. Under the law, 

employers who employ individuals who they know are not authorized to 

work in the United States may face civil fines, or in some cases, criminal 

penalties. The U.S. Immigration and Customs Enforcement, Homeland 

Security Investigations (HSI), has a three-pronged approach to address 

work-site enforcement: enforcement (criminal arrests of employers); 

compliance (employment-eligibility verification inspections, civil fines, and 

suspension and debarment); and outreach (education and training).

According to HSI officials, HSI prioritizes its work-site enforcement 

investigations by focusing on the most-egregious violators, such as 

employers that knowingly hire unauthorized workers, utilize unauthorized 

workers as a business model, mistreat or exploit their workers, aid in the 

smuggling of their alien workforce into the United States, or create false 

identity documents or facilitate document fraud. HSI officials further stated 

that the agency continues to prioritize the protection of our nation’s critical 

infrastructures and key resource sectors and industries by ensuring that 

unauthorized workers do not have access to sensitive facilities or 

information. As part of the effort to target unauthorized employment, a law 

was established allowing SSA to share data with DHS on noncitizens who 

have earnings recorded under a nonwork SSN.19

 18Social Security Administration, Office of the Inspector General, Employers Who Report 

Wages with Significant Errors in the Employee Name and Social Security Number, A-08-

12-13036 (Aug. 9, 2013).

Under certain 

circumstances, SSA may assign nonwork SSNs to noncitizens who are in 

the United States but are not authorized to work. Individuals earning 

wages under a nonwork SSN represent potential noncitizens who are 

working without DHS authorization. Furthermore, DHS officials stated that 

if the data on possible SSN misuse we identified could be routinely 

shared with them, similar to sharing the nonwork SSN data, it may assist 

them in their enforcement efforts. For example, they stated that the data 

on possible SSN misuse we identified may add to the depth of DHS 

investigations by identifying indicators of potentially egregious employers 

who knowingly hire unauthorized workers, and support DHS’s work-site 

198 U.S.C. § 1360(c).

SSA Could Better Share 

Information to Help 

Address SSN Misuse
Page 14 GAO-14-597 Supplemental Security Income 

enforcement strategy efforts. Specifically, rather than identifying work 

discrepancies on a case–by-case basis, DHS officials agreed that our 

summary analysis may provide useful information on certain employers 

that have a high incidence of reporting inaccurate wages, indicating 

possible SSN misuse.

Although SSA is able to identify possible SSN misuse for SSI recipients 

when alert notices are generated and wages are ultimately disclaimed by 

the recipient, SSA has previously reported that privacy and disclosure 

issues have limited its ability to combat SSN misuse.20 For instance, 

according to SSA, data-sharing restrictions limit its ability to routinely 

share information with DHS regarding employers who file large numbers 

of wage statements with inaccurate SSNs.21

Similarly, in February 2005 we recommended that the Secretary of 

Homeland Security take steps to determine how DHS can best use SSAsupplied data on potential illegal work activity and specific industries 

associated most frequently with such activity to support its work-site 

enforcement efforts.

In 2001, SSA OIG 

recommended that SSA reevaluate its application of existing laws or seek 

legislative authority to remove barriers that would allow the agency to 

share information regarding chronic problem employers who submit 

duplicate or unassigned SSNs with DHS. At the time, SSA disagreed with 

the recommendation, stating that it continued to provide appropriate 

disclosure guidance within its existing authority. In addition, SSA stated in 

its response to the SSA OIG’s 2001 report that there was no need for the 

agency to reevaluate its disclosure policies or to seek legislation in this 

area because SSA’s existing regulations authorized it to disclose 

information for law-enforcement purposes, including requests for 

investigation or prosecution purposes.

22

 20Social Security Administration, Office of the Inspector General, Employers Who Report 

Wages with Significant Errors in the Employee Name and Social Security Number.

In its response to our 2005 report, DHS had stated 

that it was taking the necessary steps to determine the best use of SSAprovided listings of persons with earnings who lack work authorization. In 

February 2006 we further concluded that coordination between DHS and 

SSA to leverage usable and useful data is essential to ensure that limited 

21Social Security Administration, Office of the Inspector General, Obstacles to Reducing 

Social Security Number Misuse in the Agriculture Industry.

22GAO-05-154.
Page 15 GAO-14-597 Supplemental Security Income 

DHS work-site enforcement resources are targeted effectively.23 In 2005, 

SSA OIG reiterated its support for the 2001 recommendation to seek 

legislative authority that would allow SSA to share information regarding 

employers who had the most reporting irregularities, such as invalid, 

unassigned, and duplicate SSNs. In 2013, SSA OIG identified employers 

who report wages with significant errors in the employee name and SSN 

and also recommended that SSA continue working with DHS to develop a 

coordinated strategy to reduce SSN misuse.24

Both Congress and the executive branch have recognized the need for 

improved collaboration across the federal government. In addition, in our 

past work, we have concluded that collaboration is critical for achieving 

meaningful results in efforts involving multiple federal agencies.

In its written response to 

the August 2013 SSA OIG report, SSA agreed with this recommendation 

and stated it would continue to promote methods for employers to verify 

employee names and SSNs that would result in fewer wage-reporting 

irregularities. For example, DHS’s E-Verify is a free, largely voluntary, 

Internet-based system that allows employers to verify the employment 

eligibility of newly-hired employees with the SSA database and DHS 

immigration databases. Currently, DHS estimates that 9 percent of 

employers utilize E-Verify with approximately 1,600 additional employers 

enrolling every week.

25

 23See GAO, Social Security Numbers: Coordinated Approach to SSN Data Could Help 

Reduce Unauthorized Work, 

Following key practices for effective collaboration can help agencies 

address a range of challenges, such as information sharing and 

communication. One of these key practices is directly relevant to SSA’s 

efforts to collaborate with DHS: establishing compatible policies, 

procedures, and other means to enhance information sharing and 

communication across agency boundaries. We previously identified tools 

that can facilitate such collaboration between agencies, such as shared 

databases and web portals. Establishing a negotiated data-sharing 

GAO-06-458T (Washington, D.C.: Feb. 16, 2006).

24Social Security Administration, Office of the Inspector General, Social Security Number 

Misuse in the Service, Restaurant, and Agriculture Industries, A-08-05-25023; and 

Employers Who Report Wages with Significant Errors in the Employee Name and Social 

Security Number.

25See GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).
Page 16 GAO-14-597 Supplemental Security Income 

arrangement could be beneficial for effective collaboration between SSA 

and DHS.

As previously mentioned, a component of DHS’s work-site enforcement 

strategy includes focusing on employers who knowingly hire unauthorized 

workers. Our analysis provides important newly identified summary 

information on employers that file high numbers of inaccurate wage 

reports with valid and assigned SSNs that appear to be misused. Such 

information could be used by DHS to target unauthorized employment in 

support of its work-site enforcement efforts. In addition to providing 

specific data in response to requests from law enforcement for particular 

investigations, routine data-sharing capabilities that include employers 

who have high incidences of inaccurate wage reports may augment 

DHS’s existing work-site enforcement strategies by identifying potential 

unauthorized employment.

Wages reported by employers in the NDNH for SSI recipients can be 

used to identify recipient employment activity as well as the possible 

misuse of SSNs. Our analysis shows that reviewing these discrepancies 

between income reported by SSI recipients and income reported by 

employers at a summary level can provide important information on 

certain employers that have a high incidence of reporting inaccurate 

wages for SSI recipients, indicating possible SSN misuse. This employerlevel information could be useful to DHS as part of its work-site 

enforcement strategy, which includes focusing on employers who 

knowingly hire unauthorized workers. However, due to privacy and 

disclosure laws, SSA is limited in its ability to share this employer-level 

information with DHS. This leaves the federal government unable to 

“connect the dots” using data it already has at its disposal. Hence, 

additional actions could facilitate the sharing of this information. Obtaining 

legislative authority to enable the sharing of information regarding 

potential unauthorized employment, including about employers who file 

high numbers of wage statements with potentially misused SSNs, could 

enhance SSA’s ability to address SSN misuse and help DHS better target 

its work-site enforcement efforts.

To help strengthen SSA’s efforts to monitor the SSI program, and pay 

accurate SSI benefits, as well as to enhance DHS’s investigative efforts 

on behalf of its work-site enforcement strategy, we recommend that the 

Acting Commissioner of Social Security work with the Secretary of 

Homeland Security to identify the specific data useful to DHS’s work-site 

enforcement strategy, including the new summary information that we 

identified on employers who file high numbers of wage reports with 

Conclusions

Recommendation for 

Executive Action
Page 17 GAO-14-597 Supplemental Security Income 

potentially misused SSNs, along with the corresponding privacy and 

disclosure restrictions, and seek legislative authority to allow the 

Secretary to obtain such information, as appropriate.

We provided a draft of our report to the Secretary of Homeland Security

and the Acting Commissioner of Social Security for comment. We

adjusted the initial language of the recommendation based on a request 

from SSA officials to allow the flexibility to coordinate with DHS and 

identify specific data that would be useful to DHS’s work-site enforcement 

strategy prior to seeking any new legislative authority. We received 

written comments from both DHS and SSA, which are reproduced in 

appendix II and III. SSA and DHS also provided technical comments, 

which we have incorporated as appropriate.

In its written comments, DHS said that it concurred with the 

recommendation and that HSI will work with SSA to identify information 

that may be useful to DHS’s work-site enforcement efforts and establish a 

formal point of contact for doing so, although DHS did not provide a time 

frame for implementing the recommendation. In its written comments, 

SSA said it agreed with the intent of the recommendation but will not 

pursue any legislative authority that may be required to share data not 

already allowed under current law because it does not want to be a 

conduit for sharing data between other agencies. GAO still believes that 

appropriate legislative authority should be pursued as necessary to allow 

DHS and SSA to more-effectively share information, and better “connect 

the dots” with the data they already have at their disposal. Since SSI 

program data converges with complementary data from the Department 

of Health and Human Services and the Department of the Treasury, these

data would be useful in supporting DHS’s work-site enforcement efforts. 

We continue to believe action is needed in response to our 

recommendation because, with neither SSA nor DHS pursuing potentially 

needed data-access authority, the information on potential SSN misuse 

and on employers with a high incidence of questionable wage reporting 

identified by GAO will remain unutilized.

We are sending copies of this report to appropriate congressional 

committees, the Acting Commissioner of Social Security, the Secretary of 

Homeland Security, and other interested parties. In addition, the report 

will be available at no charge on the GAO website at http://www.gao.gov.

Agency Comments

and Our Evaluation
Page 18 GAO-14-597 Supplemental Security Income 

If you or your staff have any questions regarding this report, please 

contact me at (202) 512-6722 or BagdoyanS@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report.

Seto J. Bagdoyan

Acting Director, Audits

Forensic Audits and Investigative Service
Page 19 GAO-14-597 Supplemental Security Income 

List of Requesters

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Carl Levin

Chairman

Permanent Subcommittee on Investigations

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Claire McCaskill

Chairman

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate
Appendix I: Objective, Scope, and 

Methodology

Page 20 GAO-14-597 Supplemental Security Income 

Both Congress and the executive branch have recognized the need for 

improved collaboration across the federal government. In our past work, 

we concluded that collaboration is critical when meaningful results that 

the federal government seeks to achieve required the coordinated efforts 

of more than one federal agency.1

For our prior work on SSA’s programs, SSA had provided us with a file 

containing SSI recipients as of December 2010 and the matching income 

information from both the quarterly wage and unemployment insurance 

component of the NDNH database that included fiscal year 2010.

This report examines potential 

Supplemental Security Income (SSI) overpayments by comparing Social 

Security Administration (SSA) data with income reported in the National 

Directory of New Hires (NDNH) database and identifies indicators of 

possible Social Security number (SSN) misuse.

2

To determine the subset of recipients who received overpayments during 

fiscal year 2010, we identified individuals who received SSI benefits in 

fiscal year 2010, and who also had records in the NDNH indicating the 

receipt of wages or unemployment insurance in the corresponding quarter 

of fiscal year 2010. For each individual, we used the monthly SSI benefit 

amounts in SSA’s files and the amount of all income in the NDNH to 

determine the total amount of overpayment. Through comparison of these 

benefit amounts and income, we were able to identify potential SSI 

overpayments. Our analysis of the potential overpayments is limited to 

SSA 

also provided us an updated extract of SSI recipients as of September 

2013, which separated the state and federal portion of the SSI benefit 

payment. We utilized the income reported in the NDNH and the federal 

portion of the SSI benefit payment to determine the extent that individuals 

potentially received SSI overpayments in fiscal year 2010. Since the file 

containing SSI recipients and the corresponding NDNH data provided by 

SSA is the most-recent NDNH data available to us, our analysis of SSI 

beneficiaries with income in the NDNH is limited to fiscal year 2010.

 1

See GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).

2

Our earlier work focused on SSA’s Disability Insurance (DI) program, which is the 

nation’s largest cash-assistance program for workers with disabilities. See GAO,

Disability Insurance: Work Activity Indicates Certain Social Security Disability Insurance 

Payments Were Potentially Improper, GAO-13-635 (Washington, D.C.: Aug. 15, 2013) 

and Disability Insurance: SSA Can Improve Efforts to Detect, Prevent, and Recover 

Overpayments, GAO-11-724 (Washington, D.C.: July 27, 2011).

Appendix I: Objective, Scope, and 

Methodology
Appendix I: Objective, Scope, and 

Methodology

Page 21 GAO-14-597 Supplemental Security Income 

income data from the NDNH and SSI payments from SSA. The exact 

number of individuals who received SSI overpayments and the exact 

amount of overpayments made to those individuals cannot be determined 

without detailed case investigations by SSA. Thus, we refer to “potential 

overpayments” throughout this report.

We also reviewed detailed SSI case files for a nongeneralizable selection 

of five individuals to illustrate potential cases of SSN misuse in overall 

overpayment population. We randomly selected a sample of five 

individuals from our population who were reported as receiving wages 

from four or more different states other than the state of residence that 

was reported on their SSA record. In order to be included in our sample, 

individuals had to have wages reported from four or more separate states 

during the same quarter. Because we selected a small number of 

individuals for further analysis, the results of these five cases cannot be 

projected to the entire population of individuals who received SSI 

overpayments. To develop the cases, we reviewed relevant SSA case-file 

documents and interviewed SSI program officials.

Of our population of SSI recipients that we identified who were reported 

as receiving wages from a different state than the state of residence that 

was reported on their SSA record during the same quarter, we analyzed 

the Employer Identification Number (EIN) for their employers and found 

nine employers who had 15 or more SSI recipients who lived out of state 

working for that employer in the 2nd quarter of 2010. To avoid the 

possibility that an employer might have locations in multiple states, we 

researched each of the nine EINs in LexisNexis to determine the number 

of states in which the employer had locations. Of the nine EINs, four were 

not found in LexisNexis, and four had locations in multiple states. The 

remaining one had locations in only one state. We selected this employer 

as an example of an employer who reported wages for SSI recipients in 

distant states during the same quarter.

To determine the reliability of the SSA disability records and NDNH data, 

we reviewed documentation related to these databases and interviewed 

officials responsible for compiling and maintaining relevant SSI and 

NDNH data. In addition, we performed electronic testing to determine the 

validity of specific data elements in the databases that we used to 

perform our work. We also reviewed detailed SSA case files for the 

nongeneralizable selection of five individuals selected for additional 

analysis to corroborate SSA data. On the basis of our discussions with 

agency officials, our review of related documentation, and our own 
Appendix I: Objective, Scope, and 

Methodology

Page 22 GAO-14-597 Supplemental Security Income 

testing, we concluded that the data elements used for this report were 

sufficiently reliable for our purposes.

We conducted this performance audit from April 2013 to July 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objective.

The timing and nature of NDNH income data we received present 

limitations to the data’s capacity to identify overpayments in accordance 

with SSA’s program rules. First, the quarterly amounts on the NDNH 

represent 3 months of income; however, SSA calculates overpayments 

based on monthly earnings amounts. To facilitate our analysis, we 

calculated monthly income for each month in a quarter by dividing the 

quarterly NDNH amount by three. For example, if the NDNH reported 

quarterly income of $3,000 in the first quarter of 2010, we calculated the 

monthly income to be $1,000 for January, February, and March of 2010. 

This monthly computed income amount could differ from the actual 

monthly income. For instance, using the previous example, the actual 

monthly income in January 2010 could be $3,000, and actual income in 

February or March could be $0. In addition, because we were limited to 

SSI beneficiaries with income in the NDNH for fiscal year 2010, our 

analysis may understate the extent of individuals receiving potential 

overpayments due to possible SSN misuse.

Our analysis of the NDNH match file identified individuals who received 

SSI payments in fiscal year 2010 and had computed monthly income that 

exceeded the corresponding monthly threshold for the program.3

 3

The maximum SSI monthly earnings threshold for calendar year 2010 was $1,433.

To 

calculate the potential SSI overpayments for each month, we compared 

the income to the maximum benefit amounts as specified by SSA by 

subtracting the total countable income from the 2010 monthly SSI benefit 

rate of $674. SSI has program rules for the exclusion of a certain amount 

of income in considering whether the monthly SSI benefit rate should be 

Limitations to Using 

NDNH Data

SSI Overpayments
Appendix I: Objective, Scope, and 

Methodology

Page 23 GAO-14-597 Supplemental Security Income 

reduced.4 As such, we took these exclusions into consideration to capture 

the amount of exclusion used and the remaining exclusion amount.

Specifically, we calculated countable unearned income, countable earned 

income, and the total countable income. Since this population included 

individuals with indications of expenses incurred or income set aside that 

are typically excluded from countable income when calculating the SSI 

benefit amount,5 individuals with these types of expenses were also 

excluded from our overall population. About 0.25 percent of the SSI 

recipients in our population had any indication of exclusions to income 

present.

 4

The SSI federal monthly benefit rate for fiscal year 2010 was $674. This standard amount 

is then reduced by any countable income. The reduction for unemployment and pension 

income, which is considered unearned income, is dollar for dollar after a $20 general 

income exclusion. The reduction for quarterly wage income, which is considered earned 

income, is $1 for every $2 after an $85 exclusion ($20 general exclusion + $65 earnings 

exclusion).

5

SSA allows recipients to deduct out-of-pocket costs for Impairment Related Work 

Expenses from the amount of earnings used to figure the SSI benefit. Impairment Related 

Work Expenses may be nonreimbursed expenses related to the disability and needed in 

order to work. Earned income used to meet Blind Work Expenses is not counted in the 

SSI eligibility and payment amount decision. Blind Work Expenses may be expenses 

needed to earn income, and do not have to be related to the individual’s blindness. A Plan 

to Achieve Self Support is an SSI provision to help individuals with disabilities return to 

work. Plan to Achieve Self Support lets a disabled individual set aside money and things 

he or she owns to pay for items or services needed to achieve a specific work goal.
Appendix II: Comments from the Department of Homeland 

Security

Page 24 GAO-14-597 Supplemental Security Income 

Appendix II: Comments from the Department 

of Homeland Security
Appendix II: Comments from the Department of Homeland 

Security

Page 25 GAO-14-597 Supplemental Security Income 
Appendix III: Comments from the Social 

Security Administration

Page 26 GAO-14-597 Supplemental Security Income 

Appendix III: Comments from the Social 

Security Administration

Note: GAO comments supplementing 

those in the report text appear at the 

end of this appendix.

Page numbers in the draft report may 

differ from those in this report
Appendix III: Comments from the Social 

Security Administration

Page 27 GAO-14-597 Supplemental Security Income 

See Comment 1

See Comment 2

See Comment 3
Appendix III: Comments from the Social 

Security Administration

Page 28 GAO-14-597 Supplemental Security Income 

See Comment 4

See Comment 5
Appendix III: Comments from the Social 

Security Administration

Page 29 GAO-14-597 Supplemental Security Income 

See Comment 6

See Comment 7
Appendix III: Comments from the Social 

Security Administration

Page 30 GAO-14-597 Supplemental Security Income 

The following are GAO’s comments on the Social Security 

Administration’s (SSA) letter dated July 3, 2014.

1. In the report, we added a reference to SSA’s Fiscal Year 2011 

Performance and Accountability Report as the source of the estimate. 

Including SSA’s own estimate of Supplemental Security Income (SSI)

overpayments shows that overpayments are a recognized issue with 

the program. 

2. As mentioned in the report, we recognize that it is possible for 

individuals that live near a state border to work in the neighboring 

state or for individuals to change their employer within a 3-month 

quarter for which wages are reported. However, without a detailed 

case-file review that includes contacting the recipient to determine if 

reported wages should be disclaimed, it is impossible to determine 

whether the wages reported by employers in other states that are 

many miles away are attributable to a single SSI recipient or to other 

individuals misusing the recipient’s Social Security number (SSN). 

According to the Bureau of Labor Statistics, workers are reported in 

the state of the physical location of their job. Our report describes a 

case where an SSI recipient that lives in California had wages 

reported by 11 different employers in seven different states, none of 

which bordered California, for the same 3-month period. We believe 

this is an indication of potential SSN misuse.

3. As mentioned in our report, the Department of Homeland Security 

(DHS) stated that the data on possible SSN misuse we identified may 

add to the depth of DHS investigations by identifying indicators of 

potentially egregious employers who knowingly hire unauthorized 

workers.

4. We revised the report to clarify GAO had National Directory of New 

Hires (NDNH) data that included fiscal year 2010.

5. As mentioned in the report, we state that the exact number of 

individuals who received SSI overpayments and the exact amount of 

overpayments made to those individuals cannot be determined 

without detailed case investigations by SSA. Thus, we refer to 

“potential overpayments” throughout this report. In addition, the report 

states that approximately 70 percent of the total overpayment amount 

showed indications of possible SSN misuse, such as individuals with 

wages reported from employers in multiple states during the same 

quarter, so we were unable to determine whether the recipients 

GAO Comments
Appendix III: Comments from the Social 

Security Administration

Page 31 GAO-14-597 Supplemental Security Income 

actually received SSI overpayments. Additional limitations to our 

methodology are described in detail in appendix I. 

6. We revised the footnote to address SSA’s specific comment.

7. We added the footnote to address SSA’s specific comment.

(192430)
Appendix III: Comments from the 

Social Security Administration

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