United States Government Accountability Office

GAO Statement for the Record 

To the Subcommittee on Immigration, 

Citizenship, Refugees, Border Security, 

and International Law, Committee on the 

Judiciary, House of Representatives

EMPLOYMENT 

VERIFICATION 

Challenges Exist in 

Implementing a Mandatory 

Electronic Employment 

Verification System 

Statement for the Record by Richard M. Stana, Director 

Homeland Security and Justice Issues 

For Release on Delivery

Expected at 9:00 a.m. EDT

Tuesday, June 10, 2008

 

GAO-08-895T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 10, 2008

EMPLOYMENT VERIFICATION 

Challenges Exist in Implementing a Mandatory 

Electronic Employment Verification System 

Highlights of GAO-08-895T, a statement 

for the record to the Subcommittee on 

Immigration, Citizenship, Refugees, 

Border Security, and International Law, 

Committee on the Judiciary, House of 

Representatives 

In 1996, the former U.S.

Immigration and Naturalization 

Service, now within the 

Department of Homeland Security

(DHS), and the Social Security 

Administration (SSA) began 

operating a voluntary pilot 

program, recently named the EVerify program, to provide 

participating employers with a

means for electronically verifying

employees’ work eligibility.

Legislation has been introduced in

Congress to require all employers 

to electronically verify the work

authorization status of their

employees. In this statement GAO 

provides observations on the EVerify system’s capacity and costs,

options for reducing delays and 

improving efficiency in the 

verification process, ability to 

detect fraudulent documents and 

identity theft, and vulnerability to 

employer fraud and misuse. This 

statement is based on GAO’s 

products issued from August 2005 

through June 2007 and updated

information obtained from DHS 

and SSA in April 2008. We analyzed

data on employer use, E-Verify 

guidance, and other reports on the 

employment verification process, 

as well as legislative proposals and 

regulations. 

What GAO Recommends

In 2005, we recommended that

DHS include an assessment of the 

feasibility and costs of addressing 

program weaknesses, such as 

inability to detect identity fraud, in 

a planned evaluation of the

program. DHS implemented this 

recommendation. This statement 

contains no new recommendations. 

A mandatory E-Verify program would necessitate an increased capacity at 

both U.S. Citizenship and Immigration Services (USCIS) and SSA to 

accommodate the estimated 7.4 million employers in the United States. 

According to USCIS, as of April 2008, more than 61,000 employers have

registered for E-Verify, and about half are active users. Although DHS has not

prepared official cost figures, USCIS officials estimated that a mandatory EVerify program could cost a total of about $765 million for fiscal years 2009 

through 2012 if only newly hired employees are queried through the program 

and about $838 million over the same 4-year period if both newly hired and 

current employees are queried. USCIS has estimated that it would need 

additional staff for a mandatory E-Verify program, but was not yet able to 

provide estimates for its staffing needs. SSA has estimated that 

implementation of a mandatory E-Verify program would cost a total of about 

$281 million and require hiring 700 new employees for a total of 2,325 

additional workyears for fiscal years 2009 through 2013. 

USCIS and SSA are exploring options to reduce delays and improve efficiency

in the E-Verify process. The majority of E-Verify queries entered by

employers—about 92 percent—confirm within seconds that the employee is 

work-authorized. About 7 percent of the queries cannot be immediately 

confirmed as work authorized by SSA, and about 1 percent cannot be 

immediately confirmed as work authorized by USCIS because employees’ 

information queried through the system does not match information in SSA or 

DHS databases. The majority of SSA erroneous tentative nonconfirmations 

occur because employees’ citizenship or other information, such as name 

changes, is not up to date in the SSA database, generally because individuals 

do not request that SSA make these updates. USCIS and SSA are planning to 

implement initiatives to help address these weaknesses and reduce delays. 

E-Verify may help employers detect fraudulent documents thereby reducing 

such fraud, but it cannot yet fully address identity fraud issues, for example 

when employees present genuine documents that may be stolen. USCIS has 

added a photograph screening tool to E-Verify through which an employer 

verifies the authenticity of certain documents, such as an employment 

authorization document, by matching the photograph on the document with 

the photograph in DHS databases. USCIS is exploring options to expand this 

tool to include other forms of documentation, such as passports, with 

databases that store photographic information, but these efforts are in the 

planning stages and require decisions about data sharing and privacy issues. 

E-Verify is vulnerable to acts of employer fraud and misuse, such as 

employers limiting employees’ pay during the E-Verify process. USCIS has 

established a branch to review employers’ use of E-Verify. In addition, 

information suggesting employers’ fraud or misuse can be useful to U.S. 

Immigration and Customs Enforcement (ICE) in targeting worksite 

enforcement resources. USCIS and ICE are negotiating a memorandum of 

understanding to define roles and responsibilities for sharing information. 

To view the full product, including the scope 

and methodology, click on GAO-08-895T. 

For more information, contact Richard M. 

Stana at (202) 512-8777 or stanar@gao.gov. 
Madam Chairwoman, Ranking Member King, and Members of the 

Subcommittee: 

We appreciate the opportunity to comment on electronic employment 

verification issues. As we and others have reported in the past, the 

opportunity for employment is one of the most powerful magnets 

attracting unauthorized immigrants to the United States. To help address 

this issue, in 1986 Congress passed the Immigration Reform and Control 

Act (IRCA), which made it illegal for individuals and entities to knowingly 

hire, continue to employ, or recruit or refer for a fee unauthorized 

workers.1

 The act established a two-pronged approach for helping to limit 

the employment of unauthorized workers: (1) an employment verification 

process through which employers verify all newly hired employees’ work 

eligibility and (2) a sanctions program for fining employers who do not 

comply with the act.2

 

Following the passage of IRCA, the U.S. Commission on Immigration 

Reform and various immigration experts indicated a number of problems 

with the implementation of immigration policies and concluded that 

deterring illegal immigration requires, among other things, strategies 

involving a more reliable employment eligibility verification process that 

focuses on disrupting the ability of unauthorized immigrants to gain 

employment. In particular, the commission report and other studies found 

that the single most important step that could be taken to reduce unlawful 

migration is the development of a more effective system for verifying work 

authorization. In the over 20 years since passage of IRCA, the employment 

eligibility verification process has remained largely unchanged. Legislation 

has been introduced in Congress to reform immigration laws and 

strengthen electronic employment verification. Some of this legislation 

includes proposals that would require employers to use a mandatory, 

functional electronic employment verification program for verifying the 

 1

8 U.S.C. §1324a(a). 

2

IRCA provided for sanctions against employers who do not follow the employment 

verification (Form I-9) process. Employers who fail to properly complete, retain, or present 

for inspection a Form I-9 may face civil or administrative fines ranging from $110 to $1,100

for each employee for whom the form was not properly completed, retained, or presented. 

Employers who knowingly hire or continue to employ unauthorized aliens may be fined 

from $275 to $11,000 for each employee, depending on whether the violation is a first or 

subsequent offense. Employers who engage in a pattern or practice of knowingly hiring or 

continuing to employ unauthorized aliens are subject to criminal penalties consisting of 

fines up to $3,000 per unauthorized employee and up to 6 months imprisonment for the

entire pattern or practice. 

Page 1 GAO-08-895T 
work authorization of all newly hired employees. Some of these proposals 

would also require employers to use an electronic employment verification 

program to verify the work authorization status of existing employees. In

addition, some proposals would provide sanctions for employers who do 

not use electronic verification to verify the work authorization status of 

employees equivalent to sanctions for employers who do not comply with 

the employment verification process established by IRCA. 

Currently, U.S. Citizenship and Immigration Services (USCIS), a 

component within the Department of Homeland Security (DHS), in 

conjunction with the Social Security Administration (SSA), operates a 

voluntary electronic employment verification program, called E-Verify. 

While participation in this program remains voluntary, some states are 

moving to require all employers in the state to verify newly hired 

employees using E-Verify. For example, as of January 1, 2008, the “Legal

Arizona Workers Act” requires all employers in Arizona to verify the 

employment eligibility of newly hired employees through the E-Verify 

program. This act also provides civil penalties, including the possible 

suspension or permanent revocation of all Arizona business licenses, for 

employers who are found to intentionally or knowingly employ an 

unauthorized alien. In 2008, Mississippi passed the “Mississippi 

Employment Protection Act,” under which the state will phase in 

mandatory newly hired employee eligibility verification with E-Verify for 

all employers between July 1, 2008, and July 1, 2011. Other states, 

including Idaho, Minnesota, Rhode Island, and Oklahoma, require 

employers in certain sectors, such as government employers and 

contractors, to verify their employees’ work authorization status. 

This statement is an update of our prior work regarding employment 

verification and worksite enforcement. Specifically, this statement 

includes our observations on the E-Verify program’s capacity and costs, 

options for reducing delays and improving efficiency in the verification 

process, ability to detect fraudulent documents and identity theft, and 

vulnerability to employer fraud and misuse. 

Page 2 GAO-08-895T 
In preparing this statement, we reviewed our past work on employment 

verification and worksite enforcement efforts.3

 In April 2008, we updated

information from our past work. Specifically, we analyzed updated 

information provided by U.S. Immigration and Customs Enforcement 

(ICE), USCIS, and SSA officials on the E-Verify program and challenges 

their agencies may face if an electronic employment verification program 

were made mandatory. We examined legislative proposals, regulations, 

guidance, and other studies on the employment verification process. We 

also analyzed a report on the results of an independent evaluation of the EVerify program, then known as the Basic Pilot program, issued by Westat 

Corporation, a contractor evaluating the program, in September 2007.4

 We 

reviewed the scope and methodology used by Westat in conducting the 

evaluation and, based on this review, found that the report findings were 

sufficiently reliable to provide a general indication of the types of ways in 

which employers have used the program. Furthermore, we received

updated data on employer use of the current electronic employment 

eligibility verification system. We reviewed these data for accuracy and 

completeness and determined that these data were sufficiently reliable for 

the purposes of our review. We conducted these performance audits and 

our 2008 update 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 objectives. 

A mandatory E-Verify program would necessitate an increased capacity at 

both USCIS and SSA to accommodate the estimated 7.4 million employers 

in the United States.5

As of April 2008, more than 61,000 employers have 

registered for E-Verify, about half of whom have been active users. Under 

a mandatory E-Verify program, USCIS has estimated that annual employer 

queries of newly hired employees would be an average of 63 million. 

Summary 

 3

GAO, Immigration Enforcement: Weaknesses Hinder Employment Verification and

Worksite Enforcement Efforts, GAO-05-813 (Washington, D.C.: Aug. 31, 2005) and GAO, 

Employment Verification: Challenges Exist in Implementing a Mandatory Electronic 

Verification System, GAO-07-924T (Washington, D.C.: June 7, 2007).

4

Westat, Findings of the Web Basic Pilot Evaluation (Washington, D.C.: September 2007). 

5

In 2005, the most recent year for which data are available, there were approximately 7.4 

million employer establishments in the United States. 

Page 3 GAO-08-895T 
USCIS has tested the E-Verify computer system and found that the system 

could process up to 240 million queries per year with the purchase of five 

additional servers. A mandatory E-Verify program would require additional 

USCIS and SSA resources to operate the program, including conducting 

monitoring and compliance and status verification activities. Although 

DHS has not prepared official cost figures, USCIS officials estimated that a 

mandatory E-Verify program could cost a total of about $765 million for 

fiscal years 2009 through 2012 if only newly hired employees are queried 

through the program and about $838 million over the same 4-year period if

both newly hired and current employees are queried. USCIS has estimated 

that it would need additional staff for a mandatory E-Verify program, but 

was not yet able to provide estimates for its staffing needs. USCIS has 121 

E-Verify staff nationwide and, according to the agency, would increase its 

staffing level based on a formula that considers monitoring and 

compliance and status verification staffing needs as the number of 

employers using E-Verify increases. SSA has estimated that expansion of a 

mandatory E-Verify program would cost a total of about $281 million for 

fiscal years 2009 through 2013 and require hiring 700 new employees for a 

total of 2,325 additional workyears over the same 5-year period. 

USCIS and SSA are exploring options to reduce delays and improve 

efficiency in the E-Verify process. According to USCIS, under the current 

voluntary program the majority of E-Verify queries entered by

employers—about 92 percent—confirm within seconds that the employee 

is authorized to work. About 7 percent of the queries cannot be 

immediately confirmed as work authorized by SSA, and about 1 percent 

cannot be immediately confirmed as work authorized by USCIS because 

the employee information queried through the program does not match 

information in SSA or DHS databases. 6 With regard to SSA tentative 

nonconfirmations, USCIS and SSA officials told us that the majority of 

erroneous tentative nonconfirmations occur because employees’ 

citizenship or other information, such as name changes, is not up to date

in the SSA database, generally because individuals have not contacted SSA 

to update their information when changes occurred. USCIS and SSA are 

planning to implement various initiatives to help address these 

weaknesses and reduce delays in the verification process. For example, in 

 6

In general, in cases when the E-Verify system cannot confirm an employee’s work

authorization status through the initial automatic check, the system issues the employer

either an SSA or a DHS tentative nonconfirmation of the employee’s work authorization

status, which requires the employee to resolve any data inaccuracies if he or she is able or 

chooses to do so. 

Page 4 GAO-08-895T 
May 2008 USCIS implemented an initiative to modify the electronic 

verification process so that employees whose naturalized citizenship 

status cannot be confirmed by SSA will be also checked against DHS 

databases, helping to reduce the number of naturalized citizens who would 

need to visit an SSA office to resolve a tentative nonconfirmation and 

improving efficiency in the verification process. 

E-Verify may help employers detect fraudulent documents, thereby 

reducing such fraud, but it cannot yet fully address identity fraud issues, 

for example, when employees present borrowed or stolen genuine 

documents. USCIS has taken steps to improve E-Verify’s ability to help 

reduce fraud. For example, USCIS has added a photograph screening tool

to E-Verify through which an employer verifies the authenticity of certain

DHS-issued identity documents, such as an employment authorization 

document, by matching the photograph on the card or document with the 

photograph stored in DHS databases. USCIS is exploring options for 

expanding this tool to include other forms of documentation with related 

databases that store photographic information, such as passports issued 

by the Department of State and driver’s licenses issued by states. These 

efforts are in the planning stages and require policy decisions regarding 

data-sharing processes and consideration of privacy issues. 

E-Verify is also vulnerable to acts of employer fraud and misuse, such as 

employers limiting work assignments or pay while employees undergo the 

verification process, that can adversely affect employees queried through 

the E-Verify program. USCIS has taken actions to help address employer 

fraud and misuse by, for example, establishing a Monitoring and 

Compliance branch to review employers’ use of the E-Verify program. 

USCIS is working to staff this office and implement monitoring and 

compliance activities. However, these implementation efforts are in the

early stages, and it is too early to tell whether these efforts will fully 

ensure that all employers are properly using E-Verify and following 

requirements under a mandatory program. In addition, information 

suggesting employer fraud or misuse of the system could be useful to 

other DHS components in targeting worksite enforcement resources and 

promoting employer compliance with employment laws. Under the current 

voluntary program, case referrals and requests for information between 

ICE and USCIS have been infrequent and informal. ICE and USCIS are 

negotiating a memorandum of understanding (MOU) to define roles, 

responsibilities, and mechanisms for sharing E-Verify data, and USCIS is 

developing a system for tracking case referrals made to ICE. 

Page 5 GAO-08-895T 
In 1986, IRCA established the employment verification process based on 

employers’ review of documents presented by employees to prove identity

and work eligibility. On the Form I-9, employees must attest that they are 

U.S. citizens, lawfully admitted permanent residents, or aliens authorized 

to work in the United States. Employers must then certify that they have

reviewed the documents presented by their employees to establish identity 

and work eligibility and that the documents appear genuine and relate to 

the individual presenting them. In making their certifications, employers 

are expected to judge whether the documents presented are obviously 

counterfeit or fraudulent. Employers are required to retain the Form I-9 

and provide it, upon request, to officers of the Departments of Homeland 

Security and Labor and the Department of Justice’s Office of Special 

Counsel for Immigration Related Unfair Employment Practices for 

inspection.7

 Employers generally are deemed in compliance with IRCA if

they have followed the Form I-9 process, including when an unauthorized 

alien presents fraudulent documents that appear genuine. Following the 

passage of IRCA in 1986, employees could present 29 different documents 

to establish their identity and/or work eligibility. In a 1997 interim rule, the 

former U.S. Immigration and Naturalization Service (INS) reduced the

number of acceptable work eligibility documents from 29 to 27.8

 

Background 

The Illegal Immigration Reform and Immigrant Responsibility Act 

(IIRIRA)

9

 of 1996 required the former INS and SSA to operate three 

voluntary pilot programs to test electronic means for employers to verify 

an employee’s eligibility to work, one of which was the Basic Pilot 

Program.10 The Basic Pilot Program was designed to test whether pilot 

verification procedures could improve the existing employment 

 7

Employers are required to retain the Form I-9 for 3 years after the date the person begins 

work or 1 year after the person’s employment is terminated, whichever is later. 

8

Eight of these documents establish both identity and employment eligibility (e.g., U.S. 

passport or permanent resident card); 12 documents establish identity only (e.g., driver’s

license); and 7 documents establish employment eligibility only (e.g., Social Security card).

9

 Pub. L. No. 104-208, div. C, §§ 401-404, 110 Stat. 3009-546, 3009-655-65. 

10The other two pilot programs mandated by IIRIRA—the Citizen Attestation Verification 

Pilot Program and the Machine-Readable Document Pilot Program—were discontinued in

2003 due to technical difficulties and unintended consequences identified in evaluations of 

the programs. See Institute for Survey Research and Westat, Findings of the Citizen 

Attestation Verification Pilot Program Evaluation (Washington, D.C.: April 2003) and 

Institute for Survey Research and Westat, Findings of the Machine-Readable Document 

Pilot Program Evaluation (Washington, D.C.: May 2003). 

Page 6 GAO-08-895T 
verification process by reducing (1) false claims of U.S. citizenship and 

document fraud, (2) discrimination against employees, (3) violations of 

civil liberties and privacy, and (4) the burden on employers to verify 

employees’ work eligibility. 

In 2007, USCIS renamed the Basic Pilot Program the Employment 

Eligibility Verification program and later in the year changed the name to 

E-Verify. E-Verify provides participating employers with an electronic

method to verify their employees’ work eligibility. Regardless of whether 

employers participate voluntarily in E-Verify, they are still required to 

complete Forms I-9 for all newly hired employees in accordance with 

IRCA. After completing the forms, those employers participating in the 

program query E-Verify’s automated system by entering employee 

information provided on the forms, such as name and social security 

number, into the E-Verify Web site within 3 days of the employee’s start 

date. The program then electronically matches that information against 

information in SSA’s Numident database and, if necessary, DHS databases 

to determine whether the employee is eligible to work.11 E-Verify 

electronically notifies employers whether their employees’ work 

authorization was confirmed. Those queries that the DHS automated 

check cannot confirm are referred to USCIS staff, called immigration 

status verifiers, who check employee information against information in 

other DHS databases. The E-Verify program process is shown in figure 1. 

 11 Through a process known as enumeration, SSA assigns a unique social security number

to each individual who meets the requirements for one. Social security numbers are issued 

to most U.S. citizens at birth. They are also available to noncitizens lawfully admitted to the

United States with permission to work. Numident contains demographic information on 

every social security number holder. 

Page 7 GAO-08-895T 
Figure 1: E-Verify Program Verification Process 

Work authorization 

not confirmed (by 

SSA’s database)

Immigration

Status Verifier reviews

Form I-9 information 

and checks other 

DHS databases

Information

 is compared 

with DHS 

database

SSA tentative nonconfirmation issued

Employee 

contests 

finding; Must visit 

SSA local 

office

Employee 

contests 

finding; Must 

call or visit 

DHS

Employee does not 

contest finding or does 

not resolve issue with 

SSA local office within 

8 days

Employee does not 

contest finding or does 

not resolve issue with 

DHS within 

8 days

Employer informs employee of the finding

DHS Tentative non-confirmation issued

Authorized

Authorized

Authorized

Authorized

Authorized

Final 

nonconfirmation

Final 

nonconfirmation 

DHS tentative nonconfirmation issued

Employer informs employee of the finding

Noncitizens

Citizens

Social Security Administration

Department of Homeland Security

Source: GAO analysis based on USCIS information.

Employer enters 

new employee

Form I-9 data

Information

 is compared with SSA

database through

DHS system

In cases when E-Verify cannot confirm an employee’s work authorization 

status either through the automatic check or the check by an immigration 

status verifier, the system issues the employer a tentative nonconfirmation 

Page 8 GAO-08-895T 
of the employee's work authorization status. In this case, the employers 

must notify the affected employees of the finding, and the employees have

the right to contest their tentative nonconfirmations by contacting SSA or

USCIS to resolve any inaccuracies in their records within 8 federal 

working days. During this time, employers may not take any adverse 

actions against those employees, such as limiting their work assignments 

or pay. After 8 days, employers are required to either immediately 

terminate the employment, or notify DHS of the continued employment, of

workers who do not successfully contest the tentative nonconfirmation 

and those whom the program finds are not work-authorized.12 

The E-Verify program uses the same system as USCIS’s Systematic Alien 

Verification for Entitlements Program, which provides a variety of 

verification services for federal, state, and local government agencies. 

USCIS estimates that more than 150,000 federal, state, and local agency

users verify immigration status through the Systematic Alien Verification 

for Entitlements Program. SSA also operates the Web-based Social 

Security Number Verification Service, which employers can use to assure 

that employees’ names and social security numbers match SSA’s records. 

This service, designed to ensure accurate employer wage reporting, is 

offered free of charge. Employer use is voluntary, and approximately 

12,000 employers requested more than 25.7 million verifications in 2005, 

according to the SSA Office of the Inspector General.13

 

USCIS contracted for an independent evaluation of the E-Verify program. 

Westat, the organization that conducted the evaluation, issued a report on

its evaluation findings in September 2007. According to this report, the 

Westat evaluation examined how well the federal government 

implemented modifications made to the original Basic Pilot Program and 

the extent to which the program met its goals to (1) reduce employment of 

unauthorized workers, (2) reduce discrimination, (3) protect employee 

civil liberties and privacy, and (4) prevent undue burden on employers. 

Based on its findings, Westat made recommendations to USCIS and SSA 

intended to help improve the program. 

 12 According to the E-Verify User Manual, a participating employer can notify DHS that it is 

not terminating an employee whose employment was not authorized by E-Verify or who did 

not contest a tentative nonconfirmation. 

13 Social Security Administration Office of the Inspector General, Monitoring the Use of

Employee Verification Program, A-03-06-36122 (Washington, D.C.: Sept. 26, 2006). 

Page 9 GAO-08-895T 
Mandatory electronic employment verification would substantially 

increase the number of employers using the E-Verify program, which 

would place greater demands on USCIS and SSA resources. As of April 

2008, more than 61,000 employers have registered to use the program, 

about 28,000 of whom were active users, according to USCIS.14 USCIS has 

estimated that approximately 4,000 employers are registering per month. 

In fiscal year 2007, USCIS processed about 3.2 million employer queries 

and for the first 6 months of fiscal year 2008, processed about 2.6 million 

queries. If participation in the E-Verify program were made mandatory, the 

program would have to accommodate all of the estimated 7.4 million 

employers in the United States. USCIS has projected that employers would 

submit an average of 63 million queries on newly hired employees per year 

under a mandatory E-Verify program.15 USCIS officials stated that they 

have tested the capacity of the E-Verify computer system to handle about 

four times the projected load of queries that would occur if E-Verify 

participation were made mandatory for all employers. These tests showed

that the E-Verify system can process up to 240 million queries per year, 

with the purchase of 5 additional servers, exceeding USCIS’s projection of

an average of 63 million queries per year under a mandatory E-Verify 

program. 16 

Mandatory E-Verify 

Will Require an 

Increase in Capacity 

at USCIS and SSA 

USCIS has developed cost and staffing estimates for operating a 

mandatory E-Verify program. Although DHS has not prepared official cost 

figures, USCIS officials estimated that a mandatory E-Verify program 

could cost a total of about $765 million for fiscal years 2009 through 2012 if

only newly hired employees are queried through the program and about 

$838 million over the same 4-year period if both newly hired and current 

 14Active users are those employers who have run at least one query in fiscal year 2008. 

15USCIS used employment data from the Bureau of Labor Statistics to develop these query

projections. According to these statistics, employers hire an average of 9 new employees 

per year. The total number of employers is 7.4 million, based on these statistics, which 

amounts to approximately 63 million employment verifications per year. 

16USCIS officials told us that under the current voluntary E-Verify program, which uses one 

server, the program has been tested to handle about 40 million queries per year. In 

addition, under the current voluntary program, the program has been tested to handle 

about 45,000 employer registrations per day and, with two additional servers, could handle 

up to 145,000 employer registrations per day.

Page 10 GAO-08-895T 
employees are queried.17 Mandatory implementation of E-Verify would also 

require additional USCIS staff to administer the program, but USCIS was 

not yet able to provide estimates for its staffing needs. Under the voluntary 

program, USCIS operated E-Verify with 12 headquarters staff members in 

2005, which has grown to about 121 full-time employees nationwide, with 

21 staff members for monitoring and compliance and 11 for status 

verification operations. According to USCIS, the agency would increase its 

staffing level based on a formula that considers monitoring and 

compliance and status verification staffing needs as the number of 

employers using E-Verify increases.

A mandatory E-Verify program would also require an increase in SSA’s 

resource and staffing requirements. SSA has estimated that 

implementation of a mandatory E-Verify program would cost a total of 

about $281 million for fiscal years 2009 through 2013 and require hiring 

700 new employees for a total of 2,325 additional workyears over the same 

5-year period.18 According to SSA, these estimates represent costs if the 

current E-Verify system is expanded, and any changes to the current 

process could have significant additional costs to the agency. The 

estimates include costs for start-up, such as system upgrades, training for 

current SSA employees, and training, space, and workstations for new 

employees, and ongoing activities, such as field office visits and system 

maintenance. SSA’s estimates assume that under a mandatory expansion 

of the current E-Verify program, for every 100 E-Verify queries, about 1.4 

 17The 4-year phased-in implementation proposal used by USCIS in making this estimate 

assumes that the federal employers with over 250 employees would be required to use EVerify the first year. Mandatory use of E-Verify would be required for all employers with 

more than 100 employers in the second year, employers with more than 30 employees in 

the third year, and all remaining employers in the fourth year. 

18In developing these estimates, SSA assumed that that the federal government, federal 

contractors, and employers with over 250 employees would be required to use E-Verify the 

first year. Mandatory use of E-Verify would be required for all employers with more than

100 employers in the second year, employers with more than 30 employees in the third 

year, and all remaining employers in the fourth year. SSA assumed that employers must 

ensure that their current employees have been verified through E-Verify within 4 years. 

SSA also assumed that the first group of employers will have to begin verifying newly hired 

employees by the end of fiscal year 2009. Moreover, in developing the estimate SSA

assumed that there will be a gradual increase in verification requests from fiscal years 2009 

through 2012, peaking at 110 million in fiscal year 2012, before settling off at a consistent 

volume of 60 million verification requests each year, with some employers participating 

voluntarily in E-Verify to verify new and current employees before they are required to do 

so. 

Page 11 GAO-08-895T 
individuals will contact SSA regarding a tentative nonconfirmation.19

According to SSA officials, the cost of mandatory E-Verify would be driven 

by the increased workload of its field office staff due to resolving SSA 

tentative nonconfirmations, as well as some of the computer systems 

improvements and upgrades that SSA would need to implement to address 

the capacity of a federal mandatory program. Moreover, the final number 

of new full-time staff required would depend on both the legislative 

requirements for implementing mandatory E-Verify and the effectiveness 

of efforts USCIS has underway to decrease the need for individuals to visit 

SSA field offices. SSA officials told us that SSA would need time and a 

phased-in approach for implementation of a mandatory E-Verify program 

in order to handle the increased workload for SSA field offices. 

In prior work, we reported that secondary verifications lengthen the time

needed to complete the employment verification process. The majority of 

E-Verify queries entered by employers—about 92 percent—confirm the 

employee is authorized to work within seconds. About 7 percent of queries

are not confirmed by the initial automated check and result in SSA 

tentative nonconfirmations, while about 1 percent result in DHS tentative 

nonconfirmations.20 With regard to the SSA tentative nonconfirmations, 

USCIS officials told us that the majority of erroneous tentative 

nonconfirmations occur because employees’ citizenship status or other 

information, such as name changes, is not up to date in the SSA database, 

generally because individuals have not notified SSA of information 

USCIS and SSA Are 

Implementing Plans 

to Reduce Delays and 

Improve Efficiency in 

the E-Verify Process 

 19According to SSA, the vast majority of individuals visit an SSA field office, and a small 

percentage contact SSA’s 1-800 number. SSA officials told us that in fiscal year 2007, for 

every 100 E-Verify queries, 1.7 individuals contacted SSA, on average, about 1.5 times, or a 

total a total of 2.6 contacts per 100 queries. Based on planned changes to the E-Verify 

process, SSA currently estimates that for every 100 queries submitted to E-Verify in fiscal 

year 2008, 1.4 individuals will contact SSA, on average about 1.5 times each, for a total of 

2.1 contacts per 100 queries. This 1.4 estimate accounts for planned modifications to the EVerify program through which (1) individuals whose naturalized citizenship status cannot

be confirmed by SSA will also be queried against DHS’s databases; and (2) individuals who 

receive a tentative nonconfirmation because their citizenship status does not match SSA’s 

records can contact USCIS via a 1-800 number to resolve the tentative nonconfirmation

rather than having to visit an SSA field office to do so. 

20These data on the results of initial E-Verify queries may not serve as a basis for projecting

the number of queries that will be automatically confirmed or receive a tentative 

nonconfirmation under a mandatory E-Verify program. According to USCIS, there are

preliminary indications that because of system improvements, the percentage of initial 

queries that are automatically confirmed as work authorized is increasing, and the 

percentage of initial queries that result in tentative nonconfirmations is decreasing. 

Page 12 GAO-08-895T 
changes that occurred. SSA updates its records to reflect changes in 

individuals’ information, such as citizenship status or name, when 

individuals request that SSA make such updates. USCIS officials stated 

that, for example, when aliens become naturalized citizens, their 

citizenship status, updated in DHS databases, is not automatically updated 

in the SSA database. When these individuals’ information is queried 

through E-Verify, a tentative nonconfirmation would be issued because 

under the current E-Verify process, those queries would only check 

against SSA’s database; they would not automatically check against DHS’s 

databases. Therefore, these individuals would have to go to an SSA field 

office to correct their records in SSA’s database.

USCIS and SSA are planning to implement initiatives to help address SSA 

tentative nonconfirmations, particularly those issued for naturalized 

citizens, with a goal of reducing the need for employees to visit SSA field 

offices. For example, in May 2008 USCIS launched an initiative to modify

the electronic verification process so that employees whose naturalized 

citizenship status cannot be confirmed by SSA will also be checked against

DHS’s databases. 21 A query that could not be confirmed by SSA would be 

automatically checked against DHS’s databases. If the employee’s 

information matched information in DHS’s databases and the databases 

showed that the person was a naturalized U.S. citizen, E-Verify would 

confirm the employee as work authorized. USCIS and SSA intend for this 

modification to enable USCIS to check naturalization status before an SSA 

tentative nonconfirmation is issued as a result of the naturalized citizen’s 

information not matching citizenship information in SSA’s database. 

According to USCIS, this should help eliminate the need for the employee 

who is a naturalized citizen to travel to an SSA field office before being 

confirmed as work authorized. USCIS has projected that as it implements 

this modification, the number of tentative nonconfirmations should also 

be reduced. It remains to be seen by how much the number of tentative 

nonconfirmations will be reduced as a result of this modification. 

Furthermore, in May 2008 USCIS modified the E-Verify process so that 

naturalized citizens who receive a citizenship-related mismatch can call 

DHS directly to resolve this mismatch rather than having to visit an SSA 

 21As of May 2008, USCIS will use the following databases to confirm employee work 

authorization: DHS Central Index System; Computer Linked Automated Information

Management System 3; Interagency Border Inspection System I-94 data; Image Storage and 

Retrieval System; SSA Numerical Identification File; Interagency Border Inspection System

Real Time Arrival; and the Computer Linked Automated Information Management System 4 

and the Reengineered Naturalization Automated Casework System. 

Page 13 GAO-08-895T 
field office in-person to resolve the mismatch. In addition USCIS and SSA 

are exploring options for updating SSA records with naturalization 

information from DHS records. Although this could help to further reduce 

the number of SSA tentative nonconfirmations, USCIS and SSA are still in 

the planning stages, and implementation of this initiative may require 

significant policy and technical considerations, such as how to link 

records in SSA and DHS databases that are stored according to different 

identifiers.22

 

USCIS and SSA are also implementing additional options to reduce delays 

and improve the efficiency of the verification process. USCIS stated that it

is adding databases to the E-Verify program, increasing the number of 

databases against which queries of employees’ information are checked. 

For example, USCIS stated that it is incorporating real-time arrival data for 

noncitizens from the Inter-Agency Border Inspection System (IBIS) 

database, which tracks individuals, to help reduce the number of tentative 

nonconfirmations issued for newly arrived noncitizens queried through EVerify.23 SSA has also coordinated with USCIS to develop an automated 

notification capability, known as the Employment Verification SSA 

Tentative Nonconfirmation Automated Response (EV-STAR) system. This 

system, available in all SSA field offices, became operational in October 

2007 and allows SSA field office staff to view the same information that is 

provided to employers through E-Verify. In addition, SSA field office staff

can notify the employer of the status of and any actions taken on the 

employee’s record to resolve the tentative nonconfirmation and, through 

EV-STAR, this information is directly updated in E-Verify.24 USCIS and 

SSA officials stated that EV-STAR has helped to reduce the burden on SSA, 

employers, and employees in resolving SSA tentative nonconfirmations. 

 22In general, SSA records are stored according to social security numbers, while DHS

records are stored according to alien numbers, known as A-numbers. 

23E-Verify is using IBIS data to verify the work authorization of non-citizens whose data are

not found in the DHS Central Index System. The Central Index System contains

information on the status of applicants/petitioners seeking immigration benefits to include, 

among others, lawful permanent residents, naturalized citizens, U.S. border crossers, and 

aliens who illegally entered the United States. 

24Prior to the establishment of EV-STAR, employers were not automatically notified 

through the E-Verify system after an SSA-issued tentative nonconfirmation was resolved. 

Rather, after resolving the tentative nonconfirmation, the employee had to present the

tentative nonconfirmation notification, containing SSA’s notice of resolution of the

tentative nonconfirmation, to the employer and the employer then had to access E-Verify to 

resolve the tentative nonconfirmation in the system. 

Page 14 GAO-08-895T 
These efforts may help improve the efficiency of the verification process. 

However, they will not entirely eliminate the need for some individuals to

visit SSA field offices to update their records, as USCIS and SSA efforts do 

not address all types of changes that may occur in individuals’ information 

and result in the issuance of tentative nonconfirmations, such as 

individuals’ name changes. 

In our prior work, we reported that E-Verify enhances the ability of 

participating employers to reliably verify their employees’ work 

eligibility.25 The program also assists participating employers with 

identification of false documents used to attempt to obtain employment. 

When newly hired employees present false information, E-Verify will not 

confirm the employees’ work eligibility because their information, such as

a false name or social security number, would not match SSA and DHS 

databases. However, the current E-Verify program cannot help employers 

detect forms of identity fraud, such as cases in which an individual 

presents genuine documents that are borrowed or stolen because the 

system will verify an employee when the information entered matches 

DHS and SSA records, even if the information belongs to another person. 

USCIS has Identified 

Areas where E-Verify 

is Vulnerable to 

Fraud, but Proposed 

Actions Do Not 

Address All Types of 

Fraud and Raise 

Privacy Concerns 

USCIS has taken steps to reduce fraud associated with the use of genuine

documents in which the original photograph is substituted for another. A 

photograph screening tool was incorporated into E-Verify in September 

2007 and is accessible for most employers registered to use E-Verify.26

According to USCIS officials, the photograph screening tool is intended to

allow an employer to verify the authenticity of a lawful permanent resident

card (“green card”) or an employment authorization document, both of 

which contain photographs of the document holder. As a part of the EVerify program, the photograph screening tool is used in cases when an 

employee presents a green card or employment authorization document to 

prove his or her work eligibility. The employer then inputs the card 

number into E-Verify, and the system then retrieves a copy of the 

employee’s photograph that is stored in DHS databases through the 

photograph screening tool. The employer is then supposed to match the 

 25GAO-05-813. 

26As of April 2008, E-Verify employers who use a designated agent (another company or 

individual who runs queries on behalf of the company) or Web services (an access method 

that allows employers to use their own software to access E-Verify) cannot access the 

Photo Screening Tool. 

Page 15 GAO-08-895T 
photograph shown on the computer screen with the photograph on the 

original or photocopy of the employee’s lawful permanent resident card or

employment authorization document and make a determination as to 

whether the photographs match.27 In completing the Form I-9, the 

employer is required to review the documents presented by an employee 

to prove identity and work eligibility and to certify that the documents 

appear genuine and relate to the individual presenting them. According to

USCIS, for about 5 percent of employee queries that are run through EVerify, employees present a green card or employment authorization 

document as identification.28

 

The use of the photograph screening tool is currently limited because 

newly hired employees who are queried through the E-Verify system and 

present documentation other than green cards or employment 

authorization documents to verify work eligibility—about 95 percent of EVerify queries—are not subject to the tool. Expansion of the photograph 

screening tool would require incorporating other forms of documentation 

with related databases that store photographic information, such as 

passports issued by the Department of State and driver’s licenses issued 

by states. Efforts to expand the tool have been initiated, but are still in the 

early planning stages. For example, according to USCIS officials, USCIS 

and the Department of State have begun exploring ways to include visa 

and U.S. passport documents in the tool, but these agencies have not yet 

reached agreement regarding the use of these documents. The 

Department of State is working with DHS to determine the business 

processes and system requirements of linking passport and visa databases 

to E-Verify. Additionally, USCIS is negotiating with state motor vehicle 

associations to incorporate driver’s license photographs into E-Verify, and 

is seeking state motor vehicle agencies that are willing to participate in an 

image-sharing pilot program. As of April 2008, no motor vehicle agencies 

have yet officially agreed to participate in the pilot program. 

As USCIS works to address fraud through data sharing with other 

agencies, privacy issues—particularly in regards to sharing employee 

information with employers—may be a challenge. In its 2007 evaluation of

 27Employers are supposed to notify USCIS of their determination of whether the 

photographs matched, or if they could not make a determination, through the E-Verify 

system. If an employer determines that the photographs do not match, a tentative 

nonconfirmation is issued. 

28This number excludes queries submitted by a designated agent or through Web services. 

Page 16 GAO-08-895T 
E-Verify, Westat reported that some employers joining the Web Basic Pilot 

were not appropriately handling their employees’ personal information. 

For example, some employers did not privately inform employees that 

queries of the employees’ information through E-Verify resulted in 

tentative nonconfirmations. The report also pointed out that anyone 

wanting access to the system could pose as an employer and obtain access 

by signing a MOU with the E-Verify program. USCIS officials told us that 

taking actions to ensure that employers are legitimate when they register 

for E-Verify is a long term goal for the program. However, according to 

USCIS officials, implementing such controls to verify employer

authenticity may require access to information from other agencies, such 

as Internal Revenue Service-issued employer identification numbers, to 

which USCIS currently does not have access. Additionally, some states 

and agencies have raised the issue of employee privacy. Representatives of 

motor vehicle agencies have expressed concerns in regards to the 

potential threats to customer privacy should their digital images be 

accessible to employers. USCIS is working to address these privacy 

concerns. However, it remains to be seen whether USCIS will be able to 

fully address all privacy concerns related to data and photograph sharing 

and use among agencies and employers. 

E-Verify is vulnerable to acts of employer fraud, such as when the 

employer enters the same identity information to authorize multiple 

workers. Moreover, although Westat has found that most participating 

employers comply with E-Verify program procedures, some employers 

have not complied or have misused the program, which may adversely 

affect employees. The findings from the Westat report showed that while 

changes to the E-Verify program appear to have increased employer 

compliance with program procedures compared to the previous version of 

the program, employer noncompliance still occurred. For example, 

Westat reported that some employers used E-Verify to screen job 

applicants before they were hired, an activity that is prohibited under EVerify procedures. Additionally, some employers took prohibited adverse 

actions against employees—such as restricting work assignments, 

reducing pay, or requiring employees to work longer hours or in poor 

conditions—while they were contesting tentative nonconfirmations. 

Finally, Westat found that some employers did not always promptly 

terminate employees after receiving confirmation that the employees were 

not authorized to work in the United States. USCIS reported that it is 

working to address these issues by, for example, conducting education 

and outreach activities about the E-Verify program. 

While USCIS Created 

a Monitoring and 

Compliance Branch, 

Work Remains to Staff 

the Branch, Develop 

Tools, and Finalize 

Enforcement 

Protocols 

Page 17 GAO-08-895T 
In 2005, we reported that E-Verify provided a variety of reports that could 

help USCIS determine whether employers followed program requirements 

intended to safeguard employees—such as informing employees of 

tentative nonconfirmation results and referring employees contesting 

tentative nonconfirmations to SSA or DHS—but that USCIS lacked 

sufficient staff to review employers’ use of the program. Since then, 

USCIS has added staff to its Verification Office, created a Monitoring and 

Compliance branch to review employers’ use of the E-Verify system, and 

identified planned activities for the branch.29 As of April 2008, the 

Monitoring and Compliance branch had 21 staff and planned to hire 32 

additional staff in fiscal years 2008 and 2009. Additionally, by January 

2009, USCIS plans to establish a regional verification office with 135 staff 

members to conduct status verification and monitoring and compliance 

activities.30 

With regard to compliance and monitoring activities, USCIS has identified

53 employer and employee behaviors of noncompliance and monitors the 

program for some of these behaviors. These behaviors include, among 

others, 

• the use of counterfeit documents or substituted identities; 

• use of the E-Verify system that does not follow procedures 

identified in the MOU between employers and DHS, such as 

failures to complete training or perform verifications within 

specific time frames; 

• misuse of E-Verify to discriminate and/or adversely affect

employees such as verifying existing employees, prescreening, 

firing employees who received tentative nonconfirmations, or not 

firing unauthorized employees; and 

• detecting instances where privacy information is compromised, 

such as by sharing of passwords or nonemployer access of the 

system. 

 29The mission of USCIS’s Monitoring and Compliance branch is to: (1) prevent fraud,

discrimination, or illegal use of E-Verify; (2) educate employers and provide assistance 

with compliance procedures; (3) follow up with employers on misuse of the system; and 

(4) monitor E-Verify system usage and refer identified instances of fraud, discrimination, or

illegal use of the system to enforcement authorities such as ICE or the Department of

Justice’s Office of Special Counsel. 

30According to USCIS officials, as participation in the E-Verify program grows, the agency

will need 3 additional field monitoring officers and 25 additional field compliance officers 

for every 100,000 employers. 

Page 18 GAO-08-895T 
Using some of these behaviors, among other things, to monitor employers’ 

use of E-Verify, USCIS plans to interact with employers who might not be 

complying with program procedures in four main ways: (1) sending letters 

or e-mails to advise employers of misuse of the system and to provide 

appropriate remedies, (2) follow-up phone calls when employers fail to 

respond to the initial letters or e-mails, (3) audits through which USCIS 

requests documents and information be sent to the agency from

potentially noncompliant employers, and (4) site visits for in-person 

interviews and document inspection when desk audits reveal cause for 

further investigation. Under the current voluntary program, USCIS plans to 

contact about 6 percent of participating employers regarding employer 

noncompliance. USCIS estimates that under a mandatory E-Verify 

program, the percentage of employers the agency would contact regarding 

employer noncompliance would decrease to about 1 to 3 percent. If, as a 

result of its monitoring activities, USCIS found that it needed to contact 

more than 3 percent of employers, USCIS officials stated that the agency 

plans to modify its approach for addressing employers’ noncompliance. 

As of April 2008, USCIS plans to allocate its monitoring and compliance 

efforts as follows: 45 percent of its activities would involve sending letters

and e-mails to employers; 45 percent would involve follow-up phone calls; 

9 percent would involve desk audits; and 1 percent would involve site 

visits. As part of a mandatory program, USCIS would modify this 

distribution of monitoring activities by, for example, using letters, e-mails, 

and phone calls for a larger percentage of interactions with employers. 

However, USCIS is still in the early stages of implementing its monitoring

and compliance activities. Therefore, it is too early to tell whether these 

activities will ensure that all employers fully follow program requirements 

and properly use E-Verify under a mandatory program, especially since 

such controls cannot be expected to provide absolute assurance. 

The Monitoring and Compliance branch could help ICE better target its 

worksite enforcement efforts by providing information that indicates cases 

of employers’ egregious misuse of the system. Although ICE has no direct 

role in monitoring employer use of E-Verify and does not have access to 

program information that is maintained by USCIS unless it requests such

information from USCIS, ICE officials told us that program data could

indicate cases in which employers or employees may be fraudulently using 

the system and therefore should help the agency better target its worksite

enforcement resources toward those employers. ICE officials noted that, 

in a few cases, they have requested and received E-Verify data from USCIS 

on specific employers who participate in the program and are under ICE 

investigation. For example, USCIS told us that by monitoring use of the EVerify program to date, staff were able to identify instances of fraudulent 

Page 19 GAO-08-895T 
use of social security numbers and referred such egregious examples of 

fraud to ICE. However, USCIS and ICE officials told us that case referrals

or requests for information between the two agencies have been 

infrequent, and information on the resolution of these referrals is not 

formally maintained by ICE. USCIS expects to complete and implement a 

compliance tracking system to track referrals to and responses to requests

from ICE on compliance cases in fiscal year 2009. USCIS and ICE are also 

negotiating an MOU to define roles, responsibilities, and mechanisms for 

sharing and using E-Verify information. Outstanding issues that need to be 

resolved for the MOU include the type of information that USCIS will 

provide to ICE through the referral process and the purposes for which 

ICE will use this information. While the MOU between USCIS and ICE is 

incomplete, ICE officials anticipate that, if the E-Verify program is made 

mandatory, they would receive an increased number of referrals for 

investigation from USCIS. Therefore, ICE officials told us that they plan to 

require additional resources to follow-up on USCIS referrals. ICE also 

hopes to be able to use elements of the E-Verify program to detect and 

track large-scale instances of employer or employee fraud. 

For further information about this testimony, please contact Richard Stana 

at 202-512-8777. 

Other key contributors to this statement were Jonah Blumstein, Burns 

Chamberlain, Frances Cook, Josh A. Diosomito, Rebecca Gambler, 

Danielle Pakdaman, Evi Rezmovic, Julie E. Silvers, Rebekah Temple, and

Adam Vogt. 

Page 20 GAO-08-895T 

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