United States Government Accountability Office

GAO Testimony before the Subcommittees on 

Social Security and on Oversight, 

Committee on Ways and Means, 

House of Representatives 

SOCIAL SECURITY 

NUMBERS 

Coordinated Approach to 

SSN Data Could Help 

Reduce Unauthorized Work 

Statement of Barbara D. Bovbjerg, Director

Education, Workforce, and Income Security Issues 

For Release on Delivery

Expected at 10:00 a.m. EST 

Thursday, February 16, 2006

 

GAO-06-458T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 16, 2006

SOCIAL SECURITY NUMBERS 

Coordinated Approach to SSN Data Could 

Highlights of GAO-06-458T, a report to the Help Reduce Unauthorized Work 

Chairmen, Subcommittees on Social 

Security and on Oversight, Committee on 

Ways and Means, House of 

Representatives 

To lawfully work in the United 

States, individuals must have a 

valid Social Security number (SSN) 

and, if they are not citizens,

authorization to work from the 

Department of Homeland Security

(DHS). Noncitizens seeking work 

must provide both an SSN and 

evidence of work authorization to

their employer. Yet individuals 

without these required 

authorizations have gained

employment with false information. 

How these instances of 

unauthorized work can be

identified or prevented challenges

the federal agencies involved. 

The subcommittees asked GAO to

discuss how federal agencies can 

better share reported earnings data

to identify unauthorized work. 

Specifically, this testimony 

addresses two issues: (1) the Social

Security data that could help

identify unauthorized employment

and (2) coordination among certain 

federal agencies to improve the 

accuracy and usefulness of such

data. 

The Social Security Administration (SSA) has two types of data that could be 

useful to reducing unauthorized work—individual Social Security records 

and earnings reports. Individual Social Security records, which include 

name, date of birth, and SSN, are used by SSA to provide verification 

services to employers wishing to assure themselves that the names and SSNs 

of their workers match SSA’s records. SSA also uses Social Security records 

in a work authorization verification system developed by DHS called the 

Basic Pilot that offers electronic verification of worker status. These 

services are voluntary, and none are widely used by employers. SSA's 

earnings records provide additional information, which could be used as an 

enforcement tool to identify unauthorized work. Currently, SSA uses such 

records to produce two relevant files based on earnings records, which are 

the Nonwork Alien File and the Earnings Suspense File (ESF). The 

Nonwork Alien File contains earnings information posted to SSNs issued for 

nonwork purposes, suggesting that these individuals are working without 

authorization. The ESF contains earnings reports for which SSA is unable to 

match the name and SSN of the worker, suggesting employer error, SSN 

misuse, or unauthorized work activity. In addition, we have reported that 

the ESF, which contained roughly 250 million records as of December 2004, 

appears to include an increasing number of records associated with 

probable unauthorized work, but because of statutory constraints, the ESF is

not available to DHS as an enforcement tool. 

Improving the usefulness of SSA data could help identify unauthorized work 

and ensure that limited enforcement resources are targeted effectively.

Ensuring that the most useful data are available requires close coordination 

among the three federal agencies involved in collecting and using the data—

SSA, the Internal Revenue Service (IRS), and DHS. We have previously 

recommended that IRS work with DHS and SSA as it considers 

strengthening its employer wage reporting regulations, as such action could 

improve the accuracy of reported wage data, and that DHS, with SSA, 

determine how best to use such wage data to identify potential illegal work 

activity. Efforts to improve data will only make a difference, however, if 

agencies work together to improve employer reporting and ensure they can 

conduct effective worksite enforcement programs. 

www.gao.gov/cgi-bin/getrpt?-GAO-06-458T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Barbara 

Bovbjerg at (202) 512-7215 or 

bovbjergb@gao.gov. 
Messrs. Chairmen and Members of the Subcommittees: 

I am pleased to be here today to discuss Social Security numbers (SSNs) 

and their use in preventing and detecting unauthorized work. To lawfully 

work in the United States, individuals must have a valid SSN and, if they

are not citizens, authorization to work from the Department of Homeland 

Security (DHS). Noncitizens seeking work are required to provide both an

SSN and evidence of work authorization to their employers. Yet 

individuals without these required authorizations can gain employment 

with false information. How these instances of unauthorized work can be

identified or prevented challenges the federal agencies involved. 

In prior GAO work on these issues, we have reported on the use of Social 

Security Administration (SSA) data for identity and employment eligibility 

verification. Although SSA’s verification systems have improved, use of 

SSA information in worksite enforcement continues to be challenging. 

Today I will discuss two issues: (1) the Social Security data that could help

identify some unauthorized employment and (2) coordination among SSA, 

DHS, and the Internal Revenue Service (IRS) to improve the accuracy and 

usefulness of such data.

My statement is based primarily on prior GAO work on these topics.1

 We 

are presently conducting additional work for these subcommittees 

examining the use of SSA data for detecting unauthorized work. To 

determine how SSA and DHS are coordinating to improve earnings data, 

we conducted interviews with officials from SSA, the SSA Office of the 

Inspector General, and DHS. In addition, we obtained and reviewed data 

from SSA on individuals who had reported earnings under a nonwork SSN, 

and we reviewed other documentation provided to us by these agencies. 

We began this review in October 2005 in accordance with generally 

accepted government auditing standards, and our work is ongoing. 

In summary, SSA has two types of data that could be useful for addressing 

unauthorized work— Social Security records for individuals and earnings 

 1

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

Unidentified Earnings Reports, GAO-05-154 (Washington, D.C.: February 2005); GAO,

Immigration Enforcement: Weaknesses Hinder Employment Verification and Worksite

Enforcement Efforts, GAO-05-813 (Washington, D.C.: August 2005); and GAO, Tax

Administration: IRS Needs to Consider Options for Revising Regulations to Increase the

Accuracy of Social Security Numbers on Wage Statements, GAO-04-712 (Washington, D.C:

August 2004) 

Page 1 GAO-06-458T 
reports. Individual Social Security records include name, date of birth, and 

SSN, among other things. SSA uses these data to provide SSN verification 

services free of charge to employers wishing to assure themselves that the 

names and SSNs that their workers provided match SSA’s records. SSA 

also uses Social Security records in a work authorization verification 

system called the Basic Pilot program developed by DHS, which offers 

electronic verification of worker status. These systems are voluntary and

not widely used by employers. SSA’s earnings records provide a different

sort of information that could be used for identifying unauthorized work. 

SSA uses such records to produce two relevant files. SSA’s Nonwork Alien 

File contains earnings reports that are posted to SSNs that were issued for 

nonwork purposes, which suggests individuals are working without DHS 

work authorization. By law, SSA provides nonwork alien information to 

DHS annually, and our ongoing work for you suggests that a number of 

these records are associated with people who became work authorized 

some time after receiving their nonwork SSNs. A second file of interest, 

the Earnings Suspense File (ESF), contains earnings reports in which the 

name and SSN do not match SSA’s records.2

 We have reported that this 

file, which contained 246 million records as of November 2004, appears to

include an increasing number of records associated with unauthorized 

work.3

Improving the usefulness of SSA data could help identify some 

unauthorized work and ensure that limited enforcement resources are 

targeted effectively. Ensuring that the most useful data are available 

requires close coordination among the three federal agencies involved in

collecting and using the data—SSA, IRS, and DHS. We have previously 

recommended that IRS work with DHS and SSA as it considers 

strengthening its employer wage reporting regulations, as such action

could improve the accuracy of reported wage data, and that DHS, with 

SSA, determine how best to use such wage data to identify potential illegal 

work activity. 

The Social Security Act of 1935 authorized the SSA to establish a recordkeeping system to help manage the Social Security program and resulted

in the creation of the SSN. SSA uses the SSN as a means to track workers’ 

earnings and eligibility for Social Security benefits. Through a process 

Background 

 2

 SSA receives tax records of employee earnings from employers via the IRS’s Form W-2 

(Wage and Tax Statement). 

3

GAO-05-154

Page 2 GAO-06-458T 
known as enumeration, each eligible person receives a unique number, 

which SSA uses for recording workers’ employment history and Social 

Security benefits. SSNs are routinely issued to U.S. citizens, and they are 

also available to noncitizens lawfully admitted to the United States with 

permission to work. Lawfully admitted noncitizens who lack DHS work 

authorization may qualify for an SSN for nonwork purposes when a 

federal, state, or local law requires that they have an SSN to obtain a 

particular welfare benefit or service. In this case, the Social Security card 

notes that the SSN is “Not Valid for Employment.”4

 As of 2003, SSA had 

assigned slightly more than 7 million nonwork SSNs. Over the years, SSA 

has tightened the requirements for assigning nonwork SSNs. 

In 1986, Congress passed the Immigration Reform and Control Act (IRCA), 

which made it illegal for individuals and entities to knowingly hire and 

continue to employ unauthorized workers. The act established a twopronged approach for helping to limit the employment of unauthorized 

workers: (1) an employment verification process through which employers 

are to verify newly hired workers’ employment eligibility and (2) a 

sanctions program for fining employers who do not comply with the act.

Under the employment verification process, workers and employers must 

complete the Employment Eligibility Verification Form (Form I-9) to 

certify that the workers are authorized to work in the United States. Those 

employers who do not follow the verification process can be sanctioned.

SSA has two types of data useful to identifying unauthorized work—

individual Social Security records and earnings reports. Its individual 

records, which include name, date of birth, and SSN, among other things, 

can be used to verify that a worker is providing the SSN that was assigned 

to a person of that name. These records are used in verification services 

that are available free of charge to employers on a voluntary basis. SSA’s 

earnings reports could also be used to identify some unauthorized work by

reporting noncitizens who may have worked without authorization and 

employers who have a history of providing SSN/name combinations that

do not match SSA records. 

SSA Individual 

Records and Earnings 

Reports Can Identify 

Some Unauthorized 

Work

 4

 Cards issued prior to 1982 do not contain this notation. 

Page 3 GAO-06-458T 
SSA uses individual Social Security records in its Employee Verification 

Service (EVS) and the Web-based SSN Verification Service (SSNVS), 

which employers can use to assure themselves that the names and SSNs of 

their workers match SSA’s records. The services, designed to ensure 

accurate employer wage reporting, are offered free of charge. Employer 

use is voluntary. Although these systems only confirm whether submitted 

names and SSNs match, they could help employers identify workers who 

provide an SSN with fictitious information. 

SSA Records Provide 

Verification Services to 

Improve Wage Data 

Over the years, SSA has developed several different verification methods 

under EVS. For example, employers may submit lists of workers’ names 

and SSNs by mail on a variety of media, such as magnetic tapes or 

diskettes. Alternatively, employers may call a toll-free number or present a 

hard-copy list via fax, mail, or hand delivery to a local SSA office. SSA 

verifies the information received from employers by comparing it with 

information in its own records. SSA then advises the employer whether 

worker names and SSNs match. EVS offers the benefit of verifying name 

and SSN combinations for a company’s entire payroll. However, the 

system would not be able to detect a worker’s misuse of another person’s 

name and SSN as long as the name and SSN matched. Employers do not 

widely use this service. 

In an attempt to make verification more attractive to employers, in 2005, 

SSA implemented the Web-based SSNVS. It is designed to respond to 

employer requests within 24 hours. Requests of up to 10 worker names 

and SSNs can be verified instantaneously. Larger requests of up to 250,000 

names can be submitted in a batch file, and SSA will provide results by the 

next business day. While this new system is attracting more employer 

interest, it is still not widely used. 

SSA also uses its records in a work eligibility verification system 

developed by DHS called the Basic Pilot, which offers electronic 

verification of work authorization for newly hired workers.5

 Use of this 

program by employers is also voluntary, and the service has been available 

 5

 The Basic Pilot program was authorized in 1996 through the Illegal Immigration Reform 

and Immigrant Responsibility Act (IIRIRA), which required that the Attorney General, (now 

DHS) develop and test three pilot programs to assist employers in verifying workers’

identity and work eligibility. The Basic Pilot program was developed and made available to

employers in six states starting in 1997. In 2003, Congress required DHS to expand the

verification service to all 50 states by December 2004, and DHS met that requirement. To 

improve its effectiveness and increase participation, DHS converted the program to a Webbased system in July 2004.

Page 4 GAO-06-458T 
nationwide only since December 2004. Employers who agree to participate 

must electronically verify the status of all newly hired workers within 3 

days of hire, using information that a new hire is required to provide. 

Under this program, an employer electronically sends worker data through 

DHS to SSA to check the validity of the SSN, name, date of birth, and 

citizenship provided by the worker. SSA records are used to confirm 

information on citizens. For noncitizens, SSA confirms SSN, name, and 

date of birth, then refers the request to DHS to verify work authorization 

status against DHS’s automated records.6

 If DHS cannot verify work 

authorization status for the submitted name and SSN electronically, the 

query is referred to a DHS field office for additional research by 

immigration status verifiers. If SSA is unable to verify the SSN, name, and 

date of birth or DHS record searches cannot verify work authorization, a 

tentative nonconfirmation response is transmitted to the employer. After 

checking the accuracy of the information and resubmitting the 

information, if necessary, the employer must advise the worker of the 

finding and refer him or her to either DHS or SSA to correct the problem. 

During this time, employers are not to take any adverse actions against 

those workers related to verification, such as limiting their work 

assignments or pay. When workers do not contest their tentative 

nonconfirmations within the allotted time, the Basic Pilot program issues a 

final nonconfirmation. Employers are required to either immediately 

terminate employment or notify DHS of their continued employment. 

Like SSA’s verification services, the Basic Pilot is voluntary and is not 

widely utilized. As of January 2006, about 5,500 businesses nationwide had 

registered to participate, although a significantly smaller number of these 

are active users.7

 Active participants have made about 4.7 million initial 

verification requests over a 5-year period (981,000 requests were made in 

fiscal year 2005). DHS reported on actions taken to address weaknesses in

the program that had been identified during the early years of the program. 

They included delays in updating immigration records, erroneous 

nonconfirmations, and program software that was not user friendly. We 

subsequently reported on additional challenges, specifically, the capacity 

constraints of the system, its inability to detect identity fraud, and the fact 

 6

 The DHS data are maintained by the U.S. Citizenship and Immigration Service, (USCIS). 

7

 This indicates the number of businesses that have signed memorandums of understanding 

with DHS and is not indicative of the number of active participants. 

Page 5 GAO-06-458T 
that the program is limited to verifying work authorization of newly hired 

workers.8

SSA Earnings Data May Be 

Used to Identify Some 

Unauthorized Work 

SSA’s earnings records can also provide information on unauthorized 

work. There are two sets of data that are relevant to unauthorized work. 

The first set, the Nonwork Alien File, contains earnings reports for SSNs 

that were issued for nonwork purposes. The second set, the Earnings 

Suspense File, contains earnings reports in which the name and SSN do 

not match. Both could help identify some unauthorized work. 

SSA is required by law to provide its Nonwork Alien File to DHS since it 

suggests a group of people who are in the United States legally but may be 

working without authorization.9

 Since 1998, SSA has provided DHS annual 

data on over half a million persons with earnings listed under nonwork 

SSNs. The file includes annual earnings amounts, worker names and 

addresses, and employer names and addresses as well. 

SSA’s Nonwork Alien File 

DHS has found this file to be of little use to enforcement activities, 

however. According to DHS officials, the file is currently not an effective 

tool for worksite enforcement due in part to inaccuracies in the data and

the absence of some information that would help the department 

efficiently target its enforcement.10 

In fact, because SSA only updates work authorization status at the request 

of the SSN holder, individuals in the file may now be U.S. citizens or 

otherwise legal workers who simply have not updated their status with 

SSA. Our ongoing work in this area suggests that a number of these 

records are indeed associated with people who later obtained permission 

to work from DHS. SSA policy is to update work authorization status when 

the SSN holder informs the agency of the status change and provides 

supporting documentation.

11 Unless the individual informs SSA directly of 

 8 GAO-05-813. 

9

 IIRIRA, Section 414. 

10 In prior years, DHS officials cited an inability to access the file, because SSA sent the

data to them via a computer mainframe cartridge that was incompatible with DHS’s 

systems. SSA now supplies the file in a format that is accessible to DHS agents. 

11 Individuals are not required to update such changes with SSA, although since 2002 the

agency has encouraged them to do so. SSA will remove the nonwork notation from the SSN

and reissue a card to individuals who were originally assigned a nonwork SSN if the 

individual provides SSA documentation of a change in the individual’s work status by DHS. 

Page 6 GAO-06-458T 
the status change, SSA’s enumeration records will continue to show the 

person as unauthorized to work and will record his or her earnings to the 

Nonwork Alien File. Currently, the extent to which such noncitizens are 

included in the file is unknown, but SSA and DHS officials have both

acknowledged that the file may include a number of people who are 

currently authorized to work. 

DHS officials said that the file would be of greater value if it contained 

DHS’s identifying numbers—referred to as alien registration numbers. 

According to DHS officials, because persons in the file do not have an 

identifier in common use by both agencies, they cannot automatically be 

matched with DHS records. As a result, DHS officials told us that they use

names and birth dates to match the records, which can result in 

mismatches because names can change and numbers in birth dates may be 

transposed. SSA officials have said that generally they do not collect alien 

registration numbers from noncitizens. Collecting the alien registration 

number and providing it in the Nonwork Alien File is possible, they stated,

but would require modifications to SSA’s information systems and 

procedures. They also noted that SSA would only be able to collect the 

alien registration number when noncitizens are assigned an SSN or when 

such an individual updates his or her record. As part of its procedures, 

SSA is required to verify the immigration status of noncitizens before 

assigning them an SSN, which requires using alien registration numbers.12

However, some noncitizens, such as those who have temporary visas, (e.g. 

students) may not have an alien registration number. In these cases, SSA 

would not be able to include the number in the Nonwork Alien File. 

The time it takes SSA to validate earnings reports and convey the 

Nonwork Alien File to DHS also makes the file less effective for worksite 

enforcement. When SSA finishes its various processes to ensure that the 

file includes the appropriate data, the reported earnings can be up to 2 

years old. By that time, many of the noncitizens included in the file may 

have changed employers, relocated, or changed their immigration status, 

 12 To do this, SSA field office staff use the alien registration number, in part, to query DHS’s 

records, through DHS’s Systematic Alien Verification for Entitlements (SAVE) program,

which provides certain DHS data online regarding aliens with such numbers. In addition, 

SSA field office staff is instructed to ask noncitizens to present their immigration and 

identity documents, which contain their alien registration numbers for verification. 

Page 7 GAO-06-458T 
resulting in out-of-date data on individuals or ineffective leads for DHS 

agents.13

A DHS official told us that if the Nonwork Alien File were to contain 

industry codes for the reporting employers, DHS could target those in 

industries considered critical for homeland security purposes, which 

would be consistent with DHS’s mission and enforcement priorities. 

Having information about the industries the employers are in would help 

them better link the data to areas of high enforcement priority, such as 

airports, power plants, and military bases. 

Another SSA earnings file, referred to as the Earnings Suspense File, 

contains earnings reports in which the name and SSN do not match SSA’s 

records, suggesting employer or worker error or, potentially, identity theft 

and unauthorized work. We have reported that this file, which contained 

246 million records as of November 2004, appears to include an increasing 

number of records associated with unauthorized work. SSA’s Office of the 

Inspector General has used the ESF to identify employers who have a 

history of providing names and SSNs that do not match. 

Earnings Suspense File 

When SSA encounters earnings reports with names and SSNs that do not 

match, it makes various attempts to correct them using over twenty 

automated processes. However, about 4 percent of all earnings reports still 

remain unmatched and are electronically placed in the ESF, where SSA 

uses additional automated and manual processes to continue to identify

valid records. Forty-three percent of employers associated with earnings 

reports in the ESF are from only 5 of the 83 broad industry categories, 

with eating and drinking establishments and construction being the top 

categories. A small portion of employers also account for a 

disproportionate number of ESF reports. For example, only about 8,900 

employers—0.2 percent of all employers with reports recorded in the ESF 

for tax years 1985-2000—submitted over 30 percent of the reports we 

analyzed.14

 13 Under the current process, SSA receives wage information from employers annually. 

Once the earnings reports are received, SSA will ensure the validity of the reported 

information before sending it to DHS. As a result, DHS receives the data 1 to 2 years after 

the earnings occur. For example, SSA officials told us that they SSA received earnings from 

employers based on tax year 2004 in early 2005. After receipt, SSA electronically validated 

such information throughout the summer and fall of that year, and sent all reported

earnings associated with a nonwork SSN to DHS in January 2006. 

14 GAO-05-154. 

Page 8 GAO-06-458T 
Our past work has documented that individuals who worked prior to 

obtaining work authorization are a growing source of the unmatched 

earnings reports in the ESF that are later reinstated to a worker’s account.

Once workers obtain a valid SSN, they can provide SSA evidence of prior 

earnings reports representing unauthorized employment prior to receiving

their SSN. Such earnings reports can then be used to determine a worker’s 

eligibility for benefits.15

DHS officials believe that the ESF could be useful for targeting its limited 

worksite enforcement resources. For example, they could use the ESF to 

identify employers who provide large numbers of invalid SSNs or names 

and SSNs that do not match. They told us that these employers may 

knowingly hire unauthorized workers with no SSN or fraudulent SSNs and 

that employers who are knowingly reporting incorrect information about 

their workers might also be involved in illegal activities involving 

unauthorized workers. 

However, it is not clear that the ESF, which is much larger than the 

Nonwork Alien File, would be manageable or allow for targeted 

enforcement. The ESF contains hundreds of millions of records, many 

unrelated to unauthorized work, making it difficult to use for targeting 

limited resources. While the ESF may help identify some of the most 

egregious employers of unauthorized workers, in terms of poor earnings 

reporting, its focus is not on unauthorized workers. Our work has shown 

that most of the reinstatements from the file belong to U.S.-born citizens, 

not to unauthorized workers.16 In addition, because the ESF contains 

privileged taxpayer data, SSA cannot share this information with DHS 

without specific legislative authorization.17 SSA’s Office of the Inspector 

General has recommended that SSA seek legislative authority to share this

data with DHS, but SSA responded that it is beyond the agency’s purview 

to advance legislation to amend the Internal Revenue Code in order to 

 15 GAO-05-154. 

16 GAO-05-154. 

17 Internal Revenue Code Section 6103 provides that tax returns and return information are

confidential and may not be disclosed by IRS and others having access to the information,

with certain specific exceptions. Because the confidentiality of tax data is considered

crucial to voluntary compliance, if agencies want to establish new efforts to use taxpayer 

information, executive branch policy calls for a business case to support sharing tax data. 

Page 9 GAO-06-458T 
allow DHS access to tax return information.18 IRS officials have also 

expressed concern that sharing this data could decrease tax collections 

and compliance.19 We are examining the usefulness of SSA data to DHS for 

these subcommittees, and will consider ESF issues as part of this work. 

Improving the usefulness of the data could help ensure that limited 

enforcement resources are targeted effectively. SSA data could help 

identify areas of unauthorized work, but closer collaboration among SSA, 

IRS, and DHS can help to ensure that the most useful data are available in

a form that can be used efficiently for enforcement. 

Under the current data-sharing arrangement, DHS officials believe the 

agency would have to invest significant resources to determine whether 

employers it targets are really hiring persons who are not work authorized. 

DHS has stated that determining which nonwork SSN holders are now 

authorized to work may not be cost-effective and would pull resources 

from other national security-related initiatives.20 Neither SSA nor DHS is 

able to easily and quickly update work status because they lack a common 

identifier for their records. Updating status without a common identifier 

may not be practical because different spellings or name variations 

confound large-scale matching efforts. For example, an August 2005 report 

from the SSA’s Office of the Inspector General highlights a substantial 

proportion of cases in which names were inconsistent between SSA and 

DHS.21 In at least six reports in recent years, SSA’s Office of the Inspector 

General has recommended or mentioned prior recommendations that SSA 

Closer Coordination 

by SSA, IRS, and DHS 

Could Improve 

Usefulness of SSA 

Earnings Data 

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

Misuse in the Service, Restaurant, and Agriculture Industries, A-O8-05-25023 (Baltimore, 

Maryland: April 2005); and Obstacles to Reducing Social Security Number Misuse in the 

Agriculture Industry, A-08-99-41004 (Baltimore, Maryland: January 2001). 

19 GAO-05-154. 

20GAO-05-154. 

21Social Security Administration, Office of the Inspector General, Reported Earnings Prior

to the Issuance of a Social Security Number, A-03-04-14037 (Baltimore, Maryland: August 

2005). 

Page 10 GAO-06-458T 
work with DHS to update information about work authorization.22 SSA 

officials maintain that it is their policy to make changes to the Social

Security record only if the SSN holder initiates the changes and provides

evidentiary documents from DHS. SSA further states that a “resolution of 

the discrepant information between DHS and SSA would require more 

than a simple verification.”23

Despite the many problems with the data, there are steps that could be

taken to improve them. For example, the employers who submit the most 

earnings reports for nonwork SSNs might be good candidates for outreach 

and education about verifying work eligibility. SSA’s Office of the 

Inspector General officials suggested that DHS send letters to employers 

of persons with nonwork SSNs. These letters could encourage persons 

listed as having nonwork SSNs, who are now authorized to work, to 

update their records. The ESF also has the potential to provide useful 

information to DHS, but this information has protected tax status. 

Although some of the same difficulties that pertain to the Nonwork Alien 

File could also affect the usefulness of the ESF to DHS enforcement 

efforts, if these challenges could be overcome, authorizing transmittal of at 

least some of the ESF information to DHS might be warranted.

Producing accurate, useful data will require substantial continued effort 

on the part of SSA, DHS, and the IRS: these efforts will be of little value, 

however, if the data are not used for enforcement and to stimulate 

changes in employer and employee behavior. We have reported previously

that the IRS program of employer penalties is weak, because of limited 

requirements on employers to verify and report accurate worker names 

and SSNs; we have recommended that IRS consider strengthening 

employer requirements, a course that could over time improve the 

accuracy of wage data reported to SSA.24 We have also reported that, 

 22Social Security Administration, Office of the Inspector General, Social Security

Administration Benefits Related to Unauthorized Work, A-03-03-23053 (Baltimore, 

Maryland: March 2003); Profile of the Social Security Administration’s Non-Work Alien 

File, A-14-03-23071 (Baltimore, Maryland: September 2003); Reported Earnings Prior to 

the Issuance of a Social Security Number, A-03-04-14037 (Baltimore, Maryland: August 

2005); Unauthorized Work Social Security Numbers at the Department of Defense, A-03-

05-25127 (Baltimore, Maryland: September 2005); Impact of Nonimmigrants Who 

Continue Working after Their Immigration Status Expires, A-08-05-15073 (Baltimore, 

Maryland: September 2005); and Work Activity for Social Security Numbers Assigned for

Nonwork Purposes in the State of Utah, A-14-01-11048 (Baltimore, Maryland: March 2002). 

23SSA, OIG, A-03-04-14037; A-03-05-25127. 

24GAO-04-712. 

Page 11 GAO-06-458T 
consistent with DHS’s primary mission in the post-September 11 

environment, DHS enforcement resources have focused mainly on critical

infrastructure industries in preference to general worksite enforcement. 25

In such circumstances, coordination to leverage usable and useful SSA 

data is essential to ensure that limited DHS worksite enforcement 

resources are targeted effectively.

The federal government likely can make use of information it already has 

to better support enforcement of immigration, work authorization and tax 

laws. The Earnings Suspense and the Nonwork Alien files have potential, 

but even the best information will not make a difference if the relevant 

federal agencies do not have credible enforcement programs. In fact, 

sharing earnings data to identify potential unauthorized workers could 

unnecessarily disclose sensitive taxpayer information if the data are not

utilized by enforcement programs. To address unauthorized work more 

meaningfully, IRS, DHS and SSA need to work together to improve 

employer reporting, develop more usable and useful data sets for 

suspicious earnings reports, and better target limited enforcement 

resources. We look forward to contributing to this endeavor as we 

continue to conduct our work on using SSA data to help reduce 

unauthorized work. 

This concludes my prepared statement. I will be happy to answer any 

questions you may have.

For questions regarding this testimony, please call Barbara Bovbjerg at 

(202) 512-7215. Other key contributors to this statement were Blake 

Ainsworth, Assistant Director; Lara Laufer, Analyst-in-Charge; Beverly

Crawford; Susan Bernstein; Michael Brostek; Rebecca Gambler; Jason 

Holsclaw; Daniel Schwimer; Richard Stana; Vanessa Taylor; Walter Vance; 

and Paul Wright. 

Concluding 

Observations 

Contacts and 

Acknowledgments 

 25 GAO-05-813 and GAO, Immigration Enforcement: Challenges to Implementing the INS 

Interior Enforcement Strategy, GAO-02-861T. (Washington, D.C.: June 19, 2002) 

Page 12 GAO-06-458T (130559) 
This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER