Report to the Chairman, Committee on 

Finance, U.S. Senate 

United States Government Accountability Office

GAO 

April 2006 SOCIAL SECURITY 

ADMINISTRATION 

Additional Actions 

Needed to Prevent 

Improper Benefit 

Payments under 

Social Security 

Protection Act 

GAO-06-196 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-06-196.

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 

bovbjergbj@gao.gov. 

Highlights of GAO-06-196, a report to 

Chairman, Committee on Finance, U.S. 

Senate 

April 2006

SOCIAL SECURITY ADMINISTRATION

Additional Actions Needed to Prevent 

Improper Benefit Payments under Social 

Security Protection Act 

SSA has issued guidance and provided training to assist staff in processing 

benefit claims under Section 211, but the absence of certain internal controls 

has allowed some errors to go undetected. SSA issued detailed guidance in 

August 2004 and subsequently provided staff with training on the law, which 

some SSA field offices supplemented with additional training. Although 

SSA’s policies and procedures were fairly detailed, GAO found several 

incorrect claims determinations and a lack of internal review for preventing 

them. With regard to the provisions of Section 211, GAO found that SSA 

improperly approved 17 of the 19 claims that involved noncitizen workers 

who had been issued SSNs after 2003 and who lacked required work 

authorization. GAO also found that 1 of the 41 claims that SSA disapproved 

was improper. SSA officials stated that the improper determinations were 

likely due to staff’s unfamiliarity with the new requirements. In addition, 

GAO found that letters sent to claimants informing them of disapproval 

decisions did not always contain all required information. 

Because Section 211 does not apply to noncitizens who were assigned SSNs 

before 2004, few noncitizens have been affected by the law thus far. As 

shown below, only 41 (less than 1 percent) of the approximately 72,000 

noncitizen-related claims SSA disapproved during 2004 and 2005 were due to 

Section 211. It is likely that the number of disapprovals based on the law will 

grow as more unauthorized workers file for benefits in coming years. 

However, opportunities may exist for certain noncitizens who receive their 

SSNs after 2003 to collect benefits without current work authorization. For 

example, noncitizens who are issued SSNs under temporary work visas may 

be able to engage in work not authorized under their visas and subsequently 

claim benefits based on that work. Although SSA officials told GAO the 

likelihood of this occurring was low, the SSA Inspector General reported in 

2005 that a significant number of temporary visa holders overstayed their 

visas. 

Figure 1: Claims Decided by SSA for Claims Based on Noncitizen Workers 

Source: GAO analysis of claims processed by SSA that were potentially subject to Section 211.

59%

74%

26% 41% Total claims

disapproved

(72,352)

Insufficient work credits for 

retirement/survivors’ benefits

(18,531)

Insufficient work credits for

disability benefits (53,780)

Primary worker on claim

did not meet requirements

of Section 211 (41); <1% 

of the disapproved claims

All noncitizen-related claims Reasons for disapprovals

Total claims approved 

(105,056)

Note: Workers earn work credits based on the amount of their earnings while employed in jobs 

covered by Social Security. 

Continued high levels of 

unauthorized immigrant workers in 

the United States have fostered 

concerns about whether they 

should be eligible for Social 

Security benefits. Until recently, 

the Social Security Administration 

(SSA) allowed noncitizens to 

collect benefits, regardless of their 

work authorization status, provided 

that they met certain legal presence 

requirements. However, in March 

2004, Congress passed the Social 

Security Protection Act, which 

under Section 211, requires that 

noncitizens assigned a Social 

Security number (SSN) after 2003 

have work authorization from 

current or past qualifying work to 

collect benefits. This report 

describes (1) the steps SSA has 

taken to implement Section 211 

and how effective SSA’s policies 

and procedures are in preventing 

improper benefit decisions, and 

(2) how Section 211 has affected 

the payment of benefits to 

unauthorized workers. 

What GAO Recommends

To improve its processing of claims 

covered by Section 211, GAO 

recommends that SSA: (1) establish 

a control to identify claims that 

may have been erroneously 

decided, (2) provide staff with 

enhanced training to assist them in 

properly deciding such claims, and 

(3) provide staff with a 

standardized format for preparing 

disapproval letters. In commenting 

on a draft of this report, SSA 

agreed with GAO’s 

recommendations and has begun 

taking action to address them. 
Page i GAO-06-196 Social Security Protection Act 

Letter 1

Results in Brief 2 

Background 3 

SSA Provided Guidance and Training to Its Staff to Implement 

Section 211, but Lacked Internal Controls for Assuring Proper 

Determinations 8 

Section 211 Has Impacted a Small but Potentially Growing Number 

of Claims, but May Not Restrict Benefits to Certain Temporary 

Noncitizen Workers 12 

Conclusions 16 

Recommendations for Executive Action 17 

Agency Comments 17 

Appendix I Objectives, Scope, and Methodology 20 

Appendix II Examples of Temporary Visa Categories Issued SSNs 22 

Appendix III Comments from the Social Security Administration 24 

Appendix IV GAO Contact and Staff Acknowledgments 27 

Table 

Table 1: Number of Claims Based on Noncitizen Workers That SSA 

Decided during 2004 and 2005 by Claim Type 10 

Figures 

Figure 1: Claims Decided by SSA for Claims Based on Noncitizen 

Workers 13 

Figure 2: Number and Type of SSNs Assigned to Noncitizen 

Workers for Claims Approved during 2004 and 2005 14 

Figure 3: Total Number of Work Authorized SSNs Assigned to 

Noncitizens Issued Temporary Work Visas 15 

Contents 
Page ii GAO-06-196 Social Security Protection Act 

Abbreviations 

CRS Congressional Research Service 

DHS Department of Homeland Security 

ESF Earning Suspense File 

OIG SSA Office of Inspector General 

POMS Program Operations Manual System 

SSA Social Security Administration 

SSPA Social Security Protection Act 

SSN Social Security Number 

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Page 1 GAO-06-196 Social Security Protection Act 

April 28, 2006 

The Honorable Charles E. Grassley 

Chairman 

Committee on Finance 

United States Senate 

Dear Mr. Chairman: 

In fiscal 2005, the Social Security Administration (SSA) paid out 

approximately $514 billion in benefits through its two largest programs 

(Old Age Survivors and Disability Programs), with payments to some 

48 million beneficiaries monthly. These beneficiaries included both 

citizens and noncitizens. However, continued high levels of unauthorized 

immigrant workers have fostered concerns about whether they should be 

eligible for Social Security benefits, despite the fact that some pay Social 

Security taxes. Noncitizens cannot legally work in the United States unless 

they are specifically authorized. According to a June 2005 Pew Hispanic 

Center Report, more than 10 million of the approximately 24 million 

noncitizens living in the United States in 2004 were authorized to work. 

About 6.3 million workers, however, were estimated to lack such 

authorization. Until recently, the lack of such work authorization did not 

prevent noncitizens from receiving Social Security benefits. To prevent 

payment of Social Security benefits in the future to certain noncitizens not 

authorized to work, Congress passed the Social Security Protection Act of 

2004, which under Section 211 requires that noncitizen workers assigned a 

Social Security Number (SSN) after 2003 have work authorization to 

qualify for benefits. 

Because of your interest in SSA’s implementation of Section 211 and 

whether the law has prevented unauthorized workers from collecting 

benefits, you asked us to determine: (1) what steps SSA has taken to 

implement Section 211 and how effective are SSA’s policies and 

procedures in preventing improper benefit decisions and (2) how Section 

211 has affected the payment of Social Security benefits to noncitizens for 

unauthorized work. 

To complete our work, we reviewed and discussed with SSA headquarters 

officials the guidance that they issued to implement Section 211, the 

training provided to field office staff to assist them in properly processing 

claims, and the circumstances under which noncitizens could receive 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-06-196 Social Security Protection Act 

benefits based on periods of unauthorized work. To ascertain whether SSA 

made proper decisions for claims covered by Section 211, we reviewed all 

19 of the claims that SSA had approved for benefits between January 2004 

and December 2005 that involved a primary worker who was a noncitizen 

(hereafter referred to as “noncitizen workers” or “workers”), and had been 

assigned an SSN after 2003, but lacked work authorization. We also 

reviewed all 41 of the claims that SSA had disapproved as of December 

2005 as a result of Section 211. To assess the overall impact that Section 

211 had on the payment of benefits to noncitizens, we reviewed data on all 

approved and disapproved claims involving noncitizen workers that SSA 

had processed from January 2004 to December 2005. In addition, we 

discussed with SSA officials various circumstances under which 

noncitizens could receive benefits based on unauthorized work. We 

conducted our work at SSA headquarters in Baltimore, Maryland, and at 

four SSA field offices—the Williamsburg District Office in Brooklyn, New 

York, and three branch offices in California—Culver City, Redlands, and 

Porterville. We selected these SSA offices because of the geographic 

proximity of multiple offices in a single state and because they had 

processed, individually or collectively within their region, a large number 

of Social Security benefit applications that had been disapproved under 

Section 211 at that time. We also met with officials at the Internal Revenue 

Service and the Department of Homeland Security (DHS) to discuss their 

policies regarding noncitizens issued temporary work visas. We conducted 

our work between February 2005 and January 2006 in accordance with 

generally accepted government auditing standards. Appendix I discusses 

our scope and methodology in further detail. 

SSA has issued guidance and provided training to assist staff in processing 

benefit claims under Section 211, but we found that staff improperly 

processed some of these claims and that the agency lacked certain internal 

controls for detecting such errors. Section 211 requires that claims based 

on a noncitizen worker who was assigned an SSN after 2003 show that the 

worker was either authorized to work in the United States or had a record 

of prior entry into the United States for certain work purposes. In August 

2004, SSA issued detailed guidance to its staff to implement the new law. 

SSA also offered Section 211 training to its field office staff in September 

2004, and some of the field offices we visited had supplemented this 

training with more specific training and peer group discussions. Although 

the agency’s policies and procedures were fairly detailed, we found that 

they were not always employed correctly in deciding applicants’ benefits 

eligibility under Section 211 for the claims we reviewed. In particular, we 

found that SSA improperly approved 17 of the 19 claims involving 

Results in Brief 
Page 3 GAO-06-196 Social Security Protection Act 

noncitizen workers with SSNs assigned after 2003 but lacked work 

authorization. In addition, among the 41 claims that SSA had disapproved 

as a result of Section 211, we found one decision that was improper. SSA 

officials agreed with our determinations and said that they were due to 

staff’s lack of familiarity with Section 211 requirements. However, SSA 

lacked internal control mechanisms for detecting such errors. Further, we 

found that letters sent to claimants to inform them of disapproval 

decisions did not always provide required information, such as their right 

to appeal. According to staff we interviewed, such inconsistencies 

occurred because they lacked a standardized format for such letters. 

Because Section 211 does not apply to claims involving noncitizen 

workers whose SSNs were issued before 2004, it has not yet significantly 

reduced the number of noncitizens allowed benefits for unauthorized 

work. It is likely, however, that the number of disapproved claims will 

increase as more unauthorized workers file for benefits in the coming 

years. Of the approximately 72,000 claims disapproved by SSA as of 

December 2005, only 41 were due to Section 211. As more unauthorized 

workers file for retirement or disability benefits, the law’s impact will 

presumably grow over time. However, opportunities may still exist for 

certain noncitizens to collect benefits without current work authorization. 

These noncitizens include, among others, college students, camp 

counselors, and international dignitaries. With such an SSN, these 

noncitizens could engage in work that is not authorized under their visas 

and potentially accrue enough work credits to qualify for benefits by 

continuing to work in the United States after their visas have expired. 

Although SSA officials told us the likelihood of this occurring was low, in 

2005, the SSA Inspector General reported that a significant number of 

temporary visa holders overstayed their visas. 

We are recommending that SSA adopt additional measures to help ensure 

the proper application of Section 211 to benefit decisions. In response to a 

draft of this report, SSA agreed with our recommendations and discussed 

various actions it is taking to address them. 

SSA pays retirement and disability benefits to both citizen and noncitizen 

workers who pay Social Security taxes and meet certain entitlement 

requirements. SSA also pays benefits to dependents of living workers and 

survivors of deceased workers who are entitled to benefits. Retirement, 

Background 
Page 4 GAO-06-196 Social Security Protection Act 

disability, and survivor benefits are known as Title II Social Security 

benefits. 1 Historically, SSA paid benefits to noncitizens regardless of their 

work authorization status and/or lawful presence. SSA records earnings 

information for workers, regardless of their citizenship status, from 

earnings reports (IRS Form W-2, Wage and Tax Statement) submitted by 

employers and self-employed individuals. Workers in Social Security 

covered employment (“covered employment”) contribute to Social 

Security either through payroll taxes or self-employment taxes.2

 The 

earnings from these jobs are reported under a worker’s SSN, if the 

individual has been assigned one. In cases where SSA is unable to match a 

worker’s earnings report with a valid SSN, SSA records the worker’s 

earnings in its Earning Suspense File (ESF), which electronically tracks 

such earnings. If workers later receive work authorization and SSNs, SSA 

will credit previous unmatched earnings to them, if they can show that 

such earnings in the ESF belong to them. SSA later determines whether a 

worker accrues enough work credits to receive benefits (also referred to 

as “quarters of coverage”). In addition to this, workers must meet certain 

age requirements and, in the case of disability benefits, have medical 

certification of their disability. An individual typically needs to work at 

least 10 years (which is equivalent to 40 work credits) and be at least 

62 years old to qualify for retirement benefits. Fewer work credits are 

needed for disability benefits. In general, these applicants must also show 

recent employment history and that they have worked for a certain 

number of years prior to their disability, both of which vary with the 

worker’s age. Dependents and survivors of workers may also qualify for 

benefits based on the workers’ entitlement. However, noncitizen workers 

and their dependents or survivors applying for benefits after 1996 must 

also prove that they meet certain lawful presence requirements to receive 

benefit payments. 

 1

Section 211 covers all Social Security benefits under Title II of the Social Security Act. 

Section 211 does not, however, cover Supplemental Security Income, which is a benefit 

under Title XVI of the Social Security Act. 

2

These taxes are withheld under the Federal Insurance Contributions Act (often referred to 

as FICA) and the Self-Employed Contributions Act (SECA). The 2006 FICA tax rate for 

employees is 7.65 percent (limited in part to established taxable earnings thresholds), 

which is matched by employers. The 2006 SECA tax rate for self-employed persons is 

15.3 percent. 
Page 5 GAO-06-196 Social Security Protection Act 

While SSA previously paid benefits to all individuals who met Social 

Security entitlement requirements, without regard to their work 

authorization status, the Social Security Protection Act (SSPA)3

 now 

prevents payment of benefits to noncitizens who lack authorization. 

According to a June 2005 Pew Hispanic Center report, about 6.3 million 

workers of the approximately 24 million noncitizens living in the United 

States in 2004 lacked such authorization.4

 To qualify for benefits, Section 

211 of the SSPA requires that claims based on a noncitizen worker 

assigned an SSN after 2003 prove that the worker meets one of the 

following requirements: 

• has authorization to work in the United States or 

• was temporarily admitted into the United States at any time as a 

business visitor or as a crewman under specified provisions of the 

Immigration and Nationality Act. 

Congress passed the SSPA in March 2004, but made its provisions 

retroactive to benefit applications based on SSNs issued on or after 

January 1, 2004. Although the provisions of Section 211 apply directly to 

noncitizen workers, they can also affect the entitlement of any person 

applying for a benefit on the worker’s record. For example, if a noncitizen 

worker is ineligible for benefits under Section 211, a child claiming 

benefits on the worker’s record would also be disallowed, regardless of 

the child’s citizenship or immigration status. Noncitizens assigned SSNs 

before January 1, 2004, are not affected by Section 211 restrictions. For 

noncitizens who meet the conditions of Section 211 or are exempt from its 

requirements, SSA counts all earnings from covered employment—

including those from periods of unauthorized employment—toward their 

Social Security benefit. However, unauthorized workers no longer qualify 

for benefits if they were assigned an SSN on or after January 1, 2004, and 

do not meet the additional eligibility requirements under Section 211. In 

addition, since 1996, noncitizens and their noncitizen dependents or 

survivors must be lawfully present in the United States to receive benefits.5

If such noncitizens are entitled to benefits, but do not meet the lawful 

 3

Pub. L. No. 108-203 (2004).

4

Unauthorized Migrants: Numbers and Characteristics, Pew Hispanic Center Report, 

June 14, 2005. The estimates are based on the Urban Institute’s data from the March 2004 

U.S. Census Bureau’s Current Population Survey.

5

The lawful presence requirement was established under the Personal Responsibility and 

Work Opportunity Reconciliation Act, Pub.L. No. 104-193 (1996).

New Restrictions Now 

Prevent Payment of 

Benefits to Noncitizens 

Unauthorized to Work in 

the United States 
Page 6 GAO-06-196 Social Security Protection Act 

presence requirement, SSA approves their benefit application, but places 

their benefits in a suspended status, until they establish lawful presence. 

However, a noncitizen living outside of the United States may receive 

benefits under certain conditions. For example, a noncitizen may receive 

benefits outside of the United States if he/she is a citizen of certain 

countries that have agreements with the United States permitting such 

payments. 

In addition to Section 211, there are other initiatives to reduce 

unauthorized work activity by noncitizens. Employers are required under 

the Immigration Reform and Control Act of 1986 to review certain 

documents and certify whether their workers are authorized to work in 

the United States, making it illegal for employers to knowingly hire 

unauthorized workers.6

 To assist employers with this effort, SSA and DHS 

are offering services to help them verify whether a noncitizen is authorized 

to work in the United States. For example, SSA and DHS jointly operate an 

employee verification service called the Basic Pilot Program, which assists 

employers in verifying employment eligibility of newly hired workers, 

based on DHS and SSA records.7

In addition, Congress has recently passed the REAL ID Act of 2005, which 

could make it more difficult for noncitizens to engage in unauthorized 

employment by placing restrictions on state issuance of driver’s licenses 

and personal identification cards.8

 Under the law, beginning in May 2008, 

federal agencies may not accept for any official purpose driver’s licenses 

or identification cards issued by a state unless the state meets certain 

minimum standards. These standards must include requirements that the 

state (1) receives proof and verifies, among other things, the person’s SSN, 

or verifies that the person is not eligible for one, and (2) receives valid 

documentary evidence that the person is in the United States legally. Also, 

the law requires that driver’s licenses and identification cards issued to 

certain noncitizens must expire when the individual’s authorized stay in 

the United States ends or, if there is no definite authorized period of stay, 

after 1 year. 

 6

Pub. L. No. 99-603 (1986).

7

 The Basic Pilot was established under the Illegal Immigration Reform and Immigrant 

Responsibility Act, Pub. L. No. 104-208 (1996). 

8

Pub. L. No. 109-13 (2004). 

Other Initiatives Are 

Intended to Reduce 

Unauthorized Work 
Page 7 GAO-06-196 Social Security Protection Act 

Despite these initiatives, however, there is evidence that many noncitzens 

are able to engage in unauthorized employment. For example, in an August 

2005 study, the SSA Office of Inspector General found 85 cases involving 

noncitizens who were not authorized to work in the United States from its 

review of 100 randomly selected cases of 1,382 records involving 

individuals who had earnings posted to their Social Security earnings 

records from work done prior to receiving their SSN in 2000.9

SSNs were originally created to record workers’ earnings; however, SSA 

has assigned them to individuals over the years for various nonwork 

purposes (called “nonwork SSNs”), such as general identification. In 

recent years, SSA has tightened the criteria for assigning such SSNs. SSA 

also assigns SSNs to noncitizens who are authorized to work in the United 

States, which are known as work-authorized SSNs. In fiscal year 2005, SSA 

issued 1.1 million original SSNs to noncitizens, fewer than 15,000 of which 

were nonwork SSNs. As of 2003, SSA had assigned some 7 million 

nonwork SSNs. SSA started tightening the requirements for assigning 

nonwork SSNs in 1996 when the Internal Revenue Service began assigning 

taxpayer identification numbers to assist individuals who did not qualify 

for a SSN in filing their taxes. SSA further tightened the requirements for 

assigning nonwork SSNs, primarily due to the terrorist attacks of 

September 11, 2001, limiting them only to noncitizens when (1) a federal 

statute or regulation requires that they be assigned an SSN to receive a 

particular benefit or service to which they are entitled or (2) a state or 

local law requires that they be assigned an SSN to receive entitled public 

assistance benefits. 

 9

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

to the Issuance of a Social Security Number, A-03-04-14037 (August 2005). 

SSA Has Tightened the 

Criteria for Issuing 

Nonwork SSNs 
Page 8 GAO-06-196 Social Security Protection Act 

SSA has issued guidance and provided training to assist staff in processing 

benefit claims covered by Section 211; however, we found some improper 

determinations by staff and a lack of internal controls for detecting such 

errors. The claims with improper determinations consisted of 17 claims 

involving workers who were assigned nonwork SSNs after 2003, which 

should not have been approved, and 1 claim that was improperly 

disapproved. SSA agreed with our assessment and attributed the errors to 

staff’s lack of familiarity with the new Section 211 requirements. 

Additionally, we found that letters sent to claimants to inform them of 

disapproval decisions did not always provide them with information on 

their right to appeal the decision and other required information. 

SSA has provided guidance and training to assist staff in reaching proper 

determinations for claims covered by Section 211. With the SSPA’s 

passage in March 2004 and retroactive effective date of January 1, 2004, 

SSA acted quickly to provide guidance to its field offices by issuing an 

emergency message on Section 211 in April 2004. This message explained 

the various provisions of the new law and instructed staff to hold all 

noncitizen claims that could have a potential Section 211 issue until 

detailed guidance could be developed. In August 2004, SSA issued detailed 

guidance through its Program Operations Manual System (POMS).10 The 

guidance explained the new requirements for approving claims under 

Section 211 and provided several hypothetical scenarios to illustrate how 

the guidance should be applied. Some SSA regional offices provided 

additional written guidance on Section 211. For example, one regional 

office provided staff with guidance that compared claims processing 

procedures in effect before the passage of the SSPA with those required 

under Section 211. 

Although SSA’s benefit application process is the same for citizens and 

noncitizens, Section 211 imposes additional requirements for claims based 

on a noncitizen worker assigned an SSN after 2003. For such claims, SSA’s 

guidance on Section 211 directs field office staff to determine if the worker 

has work authorization or a record of prior entry into the United States for 

certain work purposes. This determination is in addition to the existing 

requirement that noncitizens residing in the United States who file for 

benefits are lawfully present to receive benefit payments or meet other 

 10The guidance for Section 211 is found at POMS RS 00301.102, “Additional Requirements 

for Alien Workers – Social Security Protection Act of 2004,” issued August 18, 2004.

SSA Provided 

Guidance and 

Training to Its Staff to 

Implement Section 

211, but Lacked 

Internal Controls for 

Assuring Proper 

Determinations 

SSA Provided Guidance 

and Training to Assist Staff 

in Properly Applying 

Section 211 
Page 9 GAO-06-196 Social Security Protection Act 

conditions to receive benefit payments outside of the United States. To 

process applications for benefits, SSA field office staff meet with 

applicants to explain the benefits for which they might qualify and review 

the evidence supporting the claim. After a claims representative makes the 

initial determination, a field office supervisor or an experienced colleague 

reviews the claim for the appropriateness of the decision.11 Once a claims 

determination is made, SSA requires that field office staff send applicants 

a letter notifying them of the decision. For those claims disallowed as a 

result of Section 211 in which the primary worker lacked an SSN, SSA 

guidance requires field office staff to send a copy of the disallowance 

letter to agency headquarters. SSA headquarters uses this information to 

monitor the number of such cases, because there is currently no way to 

track this information in SSA’s system without an SSN. 

SSA also provided training to field office staff to assist them in properly 

applying Section 211. In September 2004, SSA headquarters provided 

interactive video training on the SSPA, as part of its monthly training for 

newly issued transmittals, which included a general discussion of the 

requirements of Section 211, among other topics. SSA later circulated a 

written summary of the broadcast to field offices for training purposes. In 

November 2004, SSA headquarters issued a transmittal to its 800-number 

call centers to assist staff in addressing inquiries about Section 211. 

Additionally, managers at three of the four field offices we visited told us 

they used peer group discussions and more specific training to supplement 

the headquarters training. One field office manager developed and 

administered a test to assess staff’s understanding of the Section 211 

requirements. 

As part of our review, SSA provided us with records on all of the 

approximately 177,000 approved and disapproved claims that involved 

noncitizen workers—and therefore possibly covered by Section 211—that 

had been decided from January 2004 to December 2005. (See table 1.) 

These records included information on the type of claim, when the SSN 

was assigned, and whether the claimants were lawfully present. The 

majority of these claims were for retirement or disability benefits, which 

made up roughly 94 percent of all claims. 

 11Although field office managers conduct monthly reviews of a random sample of all 

claims, SSA headquarters and field officials told us that due to the low number of Section 

211-impacted claims, few if any have been included in these reviews.

SSA Lacked Internal 

Controls to Detect 

Erroneously Decided 

Claims and Several 

Disapproval Letters 

Lacked Required 

Information 
Page 10 GAO-06-196 Social Security Protection Act 

Table 1: Number of Claims Based on Noncitizen Workers That SSA Decided during 2004 and 2005 by Claim Type 

Type of claim Approved Percent Disapproved Percent Total

Retirement 69,883 80 17,511 20 87,394

Disabilitya 26,499 33 53,012 67 79,511

Survivor 8,232 90 944 10 9,176

End stage renal disease 442 33 885 67 1,327

Total 105,056 59 72,352 41 177,408

Source: GAO analysis of SSA data. 

Note: SSA decided an additional 49 claims that do not appear in this table because the claim type 

was not specified. 

a

These claims only include disability claims that SSA disapproved due to lack of work credits. 

In assessing SSA’s claims determinations we found that 18 were 

erroneous. These 18 were; 

• 17 approved claims based on noncitizen workers who had been 

assigned a nonwork SSN after 2003; and 

• 1 disapproved claim in which SSA erroneously applied Section 211 to a 

survivor’s parent who was not the primary worker.12

In 17 of the 19 approved cases we reviewed in which the primary workers 

had been assigned a nonwork SSN after 2003, we found that the 

determinations were erroneous because the workers lacked the work 

authorization or past qualifying work experience required under Section 

211. Our review of SSA’s records for the 17 erroneously decided claims 

showed that SSA paid benefits for 13 of the claims. In total, over the 

period of 2004 and 2005, SSA paid out approximately $110,000 for these 

claims, almost all of which was in the form of recurring monthly payments. 

For the remaining four claims, SSA never began benefit payments due to 

beneficiaries’ lack of lawful presence or other reasons. In discussing the 

erroneously approved cases with SSA officials, they agreed that the cases 

had been improperly decided and said that the errors possibly resulted 

from some claims representatives’ lack of familiarity with the new 

requirements of Section 211. Also, in an earlier discussion with SSA 

officials, we asked whether they had considered installing an automated 

systems control to identify potentially erroneous claims. The officials told 

us that although the agency indeed considered such a control, SSA 

 12The 72,000 disapproved claims did not include any claims that were disapproved due to 

lack of evidence of a medical disability. 
Page 11 GAO-06-196 Social Security Protection Act 

management decided that it was not needed due to the low number of 

claims involving Section 211 that had been processed overall. 

For the 41 claims disapproved as a result of Section 211, we found that 

proper determinations had been made in all but one case. In assessing 

these cases, we reviewed all of the case file documentation. The 

documentation in some cases included only the letter notifying the 

claimant(s) of the disapproval decision, and in other cases this letter and a 

combination of other documents such as wage and earnings statements 

and immigration documentation. SSA disapproved 38 of the 41 claims 

because the primary worker lacked work authorization and had never 

been issued an SSN. Although the workers for the remaining three claims 

had been assigned SSNs after 2003, their claims were disapproved because 

they lacked work authorization. In several of the cases, it appeared that 

that the primary workers had been employed in the United States and had 

paid Social Security taxes as documented by wage and earnings 

statements and other tax information included in the files. In some 

instances, the claimants said that the SSN that the worker had used had 

been made up or belonged to someone else. For the one claim that was 

incorrectly decided, SSA based its decision on a survivor’s claim for a 

child on the widow’s lack of an SSN, instead of the primary worker who 

had been assigned an SSN prior to 2004. After further review of this claim, 

SSA officials agreed that the claim had been improperly disapproved 

based on Section 211, but stated that the claim would remain in a 

disapproved status pending additional evidence supporting the child’s 

relationship to the deceased worker. 

In reviewing the 41 letters sent to claimants to inform them of disapproval 

decisions based on Section 211, we found that SSA staff did not always 

provide the claimants with information on their appeals rights and other 

required information. For example, in most cases, the letters did not 

inform claimants of their right to representation for appeals or refer them 

to a pamphlet explaining their right to question the decision as required by 

SSA’s guidance. Also, in several cases, the letters did not apprise claimants 

of their right to appeal the decision or provide instructions on how to file 

an appeal. SSA field managers and staff told us that these inconsistencies 

occur because they lack a standardized format for preparing such 

disapproval letters. They suggested that automating the letters would help 

ensure that they provide all required information to claimants. When 

claimants do not receive such information, they could fail to file an appeal 

or secure representation on their behalf. As a result, claimants who might 

be found eligible for benefits upon appeal would not receive benefits to 

which they may be entitled. 
Page 12 GAO-06-196 Social Security Protection Act 

Though its impact may grow over time, Section 211 has not yet 

significantly reduced benefits to noncitizens; the law’s restrictions, 

however, may not prevent benefits for certain temporary noncitizen 

workers who could engage in work not authorized by their visas. As of 

December 2005, SSA had disapproved only 41 claims of some 72,000 

disapproved noncitizen-related claims due to Section 211 because SSA 

determined that the workers involved in the claims lacked necessary work 

authorization. While the number of disapproved claims could increase as 

more noncitizens file for retirement or disability claims in the coming 

years, there are still certain temporary workers who, upon receiving an 

SSN, could engage in employment not authorized by their visas. If these 

noncitizens remain in the country long enough after their visas expire, 

they could potentially earn enough work credits in such employment to 

eventually qualify for benefits. 

Because Section 211 does not apply to claims based on noncitizen workers 

assigned SSNs prior to 2004, the law has not significantly reduced the 

number of noncitizens receiving benefits. However, the number of 

disapproved claims will likely increase as unauthorized workers file for 

benefits in the coming years. During 2004 and 2005, SSA disallowed 

roughly 72,000 of some 177,000 claims involving noncitizen workers, of 

which only 41 were disallowed because they lacked the necessary work 

authorization required under Section 211. In addition to the Section 211 

exemptions, according to SSA officials, the minimal impact of the law to 

date may also be a result of unauthorized workers not applying for 

benefits after concluding that they would not be eligible. 

As of December 2005, SSA approved roughly 60 percent of the 

approximately 177,000 claims, almost all of which involved noncitizens 

who were assigned a work-authorized SSN prior to 2004. Our review also 

showed that SSA disallowed roughly 72,000 benefit claims involving a 

noncitizen worker, almost always due to reasons other than Section 211. 

Almost 54,000 (74 percent) were disapproved because the primary worker 

upon whom the claim was based did not have sufficient work credits to 

qualify for disability benefits, which requires fewer than the 40 work 

credits generally required for retirement benefits. In addition, 

approximately 19,000 (26 percent) claims were disapproved because the 

Section 211 Has 

Impacted a Small but 

Potentially Growing 

Number of Claims, 

but May Not Restrict 

Benefits to Certain 

Temporary Noncitizen 

Workers 

Section 211 Has Not Yet 

Significantly Reduced the 

Number of Noncitizens 

Receiving Benefits 
Page 13 GAO-06-196 Social Security Protection Act 

primary worker did not have sufficient work credits to qualify the 

claimant(s) for retirement or survivor benefits (fig. 1). 

Figure 1: Claims Decided by SSA for Claims Based on Noncitizen Workers 

Although SSA has disallowed only 41 claims as a result of Section 211 

requirements, the number will increase in future years as more 

unauthorized workers reach retirement age or become disabled. While the 

41 disallowed claims affected workers who had applied for retirement or 

disability benefits, they predominantly affected claimants applying for 

survivor benefits. In fact, 31 of the 41 claims were for survivor benefits. 

These claims in several cases involved survivors who were U.S. citizens. In 

some of these cases, survivors of deceased workers were denied benefits 

because the worker did not meet the requirements of Section 211, even 

though the worker had enough work credits to qualify the claimants for 

survivor benefits. 

While SSA data for the approximately 105,000 claims approved during 2004 

and 2005 shows that 97 percent of the workers assigned SSNs before 2004 

had work authorized SSNs, there are millions of noncitizens assigned 

nonwork SSNs before 2004 who may qualify for benefits in the coming 

Source: GAO analysis of claims processed by SSA that were potentially subject to Section 211.

59%

74%

26% 41% Total claims

disapproved

(72,352)

Insufficient work credits for 

retirement/survivors’ benefits

(18,531)

Insufficient work credits

for disability benefits

(53,780)

Primary worker on claim

did not meet requirements

of Section 211 (41); <1% of 

the disapproved claims

All noncitizen-related claims Reasons for disapprovals

Total claims approved 

(105,056)
Page 14 GAO-06-196 Social Security Protection Act 

years because Section 211 does not affect them. As figure 2 shows, 

3,130 claims were made based on noncitizen workers issued nonwork 

SSNs before 2004. 

Figure 2: Number and Type of SSNs Assigned to Noncitizen Workers for Claims 

Approved during 2004 and 2005 

Even with Section 211 restrictions, opportunities may still exist for certain 

noncitizens assigned SSNs after 2003 to collect benefits without current 

work authorization. For example, some temporary workers—often 

referred to as nonimmigrants—legally admitted into the United States may 

receive benefits based on work not authorized by their visas.13 Currently, 

the Social Security Act directs SSA to take steps to issue SSNs to certain 

noncitizen visa holders granted permission to work in the United States by 

DHS under certain temporary visas. Such noncitizens include, among 

others, college students, camp counselors, and international dignitaries. 

(We selected certain visa categories under which noncitizens temporarily 

in the United States were most likely to receive a work authorized SSN 

based on information received from SSA. See app. II for a detailed 

description of the nonimmigrant classifications we used.) Between 2000 

 13 In addition to earning work credits by staying beyond their period of authorized 

admittance under their visas, a nonimmigrant could accrue work credits in subsequent 

periods of authorized re-admittance. 

Section 211 May Not 

Restrict Benefits to Certain 

Noncitizen Temporary 

Workers Who Engage in 

Unauthorized Work 

Type of SSN

Number of claimants

Source: SSA.

0 1,000 2,000 3,000

Work authorized

SSNs assigned

pre Section 211

Non work

SSNs assigned

pre Section 211

Work authorized

SSNs assigned 

post Section 211

Non work 

SSNs assigned

post Section 211

19

117

3,130

101,789

60,000 80,000 100,000 120,000
Page 15 GAO-06-196 Social Security Protection Act 

and 2004, SSA issued approximately 1 million SSNs to these noncitizens, 

and as shown in figure 3, the number of these SSNs substantially increased 

after 2001. By using their work authorized SSN, these workers could 

engage in employment covered by Social Security, but not authorized by 

their visa (which is considered illegal employment). If these workers 

accumulate enough work credits by overstaying their visas and meet age 

and other entitlement requirements, they would qualify for benefits based 

on the work authorized designation of their SSN. SSA’s Office of the 

Inspector General estimated that out of the approximately 795,000 

temporary visa holders that had received an SSN regardless of their visa 

type during fiscal year 2000 alone, some 32,000 had either continued 

working after their immigration status expired or may have allowed 

someone else to use their SSN to work after they left the United States.14 

Figure 3: Total Number of Work Authorized SSNs Assigned to Noncitizens Issued 

Temporary Work Visas 

SSA officials acknowledged that it was possible for these temporary 

workers to obtain benefits by using their SSN to engage in employment 

 14Social Security Administration, Office of the Inspector General, Impact of 

Nonimmigrants Who Continue Working after their Immigration Status Expires, A-08-05-

15073 (September 2005). 

0

50,000

100,000

150,000

200,000

250,000

Total number of SSNs

Source: SSA.

Year of issuance

2000 2001 2002 2003 2004
Page 16 GAO-06-196 Social Security Protection Act 

not authorized under their visa. However, they said that the likelihood of 

this occurring was low, because such individuals would probably not stay 

in the country long enough to accrue sufficient work credits or meet 

lawful presence requirements. As demonstrated by the Office of the 

Inspector General report, however, temporary visa holders do, in many 

instances, continue working after their visas expire. Also, if temporary visa 

holders accrue sufficient work credits and meet other eligibility 

requirements, they may be able receive benefits without meeting the 

lawful presence requirement under certain conditions. For example, such 

temporary visa holders could receive benefits if they apply for benefits 

outside of the United States if they are citizens of certain countries that 

have agreements with the United States permitting such payments. Should 

such instances occur, SSA would be limited in its ability to detect them 

because it does not have the mechanisms to distinguish between 

individuals’ authorized and unauthorized employment. 

Section 211 has imposed new restrictions on the payment of Social 

Security benefits to noncitizens who work without authorization, but, not 

surprisingly, few have been denied benefits thus far. Under the law, 

noncitizens may continue to have earnings from unauthorized employment 

credited toward their benefits entitlement if they received their SSN in 

2003 or earlier, or if their nonwork SSN was assigned after 2003 and they 

later obtain work authorization. Over time, however, this provision of the 

law will likely exert a greater impact on benefits paid based on 

unauthorized work. Although Section 211 will not prevent all such benefit 

payments, as in the instance regarding certain temporary visa holders, the 

new law is making a small but potentially growing difference. It will be 

important for SSA to continue to monitor the law’s impact and, to the 

extent practicable, identify the remaining situations permitting benefit 

payments based on unauthorized work if they prove significant and 

measurable. 

Meanwhile, SSA needs to take actions to ensure that Section 211 is 

properly administered. Our findings show that, in implementing Section 

211, SSA has taken steps to prevent the payment of benefits for claims 

involving workers who lack work authorization, but additional actions are 

needed to ensure that claims are properly decided and that all claimants 

receive necessary information concerning the decision. Because we 

identified 17 claims that had been approved in error, developing an 

internal control to identify potentially erroneous claims decisions could 

reduce future errors. Additionally, it is important that SSA staff receive 

additional training on the proper application of Section 211 for claims 

Conclusions 
Page 17 GAO-06-196 Social Security Protection Act 

approved after 2004 in which workers lack work authorization. Without 

such measures, benefits may be paid to those who are not entitled to them 

and denied to those who are. Given the fact that over time the number of 

unauthorized workers reaching retirement age or becoming disabled will 

likely increase and therefore be subject to Section 211, these measures 

could help SSA ensure the integrity of the Social Security program and 

avoid erroneous payments. Also, with regard to disapproved claims, SSA 

has not developed a way to ensure that all unsuccessful applicants receive 

information on both their right to appeal the decision and information 

regarding whom to contact for questions about the decision—as required 

by its own policy. As a result, applicants who do not receive such 

information may not understand that they can appeal the decision, the 

process for filing an appeal, and the time frame within which such action 

must be taken. 

To assure proper benefit eligibility determinations and appeals processes, 

we recommend that the Commissioner of Social Security: 

• establish a control to identify potentially erroneous claims decisions 

for unauthorized workers assigned SSNs after 2003, such as an 

electronic edit check to identify such claims; 

• provide enhanced training to staff to assist them in properly processing 

claims covered by Section 211; and 

• develop a standardized format for disapproval letters to ensure that 

staff provide applicants with all required information regarding the 

disapproval decision. 

We obtained written comments on a draft of this report from the 

Commissioner of SSA. SSA’s comments are reproduced in appendix III. 

SSA also provided additional technical comments, which have been 

included in the report as appropriate. 

SSA agreed with our recommendations and discussed various actions it is 

taking to address them. In response to our first recommendation, SSA 

stated that it had implemented a new edit check into its Disability Insured 

Status Calculator Online program to screen for whether individuals meet 

the disability insured status rules. To assist staff in making proper claims 

determinations, SSA stated that the edit check generates an alert when an 

individual’s SSN issue date is January 1, 2004, or later, and provides staff 

with a copy of the claims processing procedures relating to Section 211. 

While we commend SSA for its swift implementation of this action, we 

Recommendations for 

Executive Action 

Agency Comments 
Page 18 GAO-06-196 Social Security Protection Act 

believe that this improvement still leaves room for erroneous claims 

determinations to go undetected. One reason for this is that SSA’s action 

only provides such alerts for disability claims, potentially leaving 

thousands of retirement, dependent, and survivor claims susceptible to 

error. Also, this action still relies only on SSA staff to make proper 

determinations. However, as our review demonstrated, this step alone is 

not sufficient to detect claims that were improperly decided. Therefore, 

we believe that SSA should install an automated systems edit to identify 

potentially erroneous claims decisions as we recommended. 

In response to our second recommendation, SSA stated that it was 

updating its claims processing procedures relating to Section 211 of the 

SSPA and would provide staff with training on the new update when it is 

completed. 

Regarding our third recommendation, SSA stated that it would require 

staff to use a notice that provides standardized appeals language and 

information on the disapproval decision, as part of its update to the 

Section 211 guidance. This notice is located in SSA’s Distributed Online 

Correspondence System, which is separate from the Program Operations 

Manual System that contains Section 211 guidance. While existing 

guidance on Section 211 instructs staff to include appeals language and 

other required information in letters explaining disapproval decisions, it 

does not provide the exact language that staff are to include in the letters. 

Consequently, staff must use their discretion in determining what language 

should be included. As our review found, this resulted in several letters 

that did not provide unsuccessful claimants with information on their right 

to appeal the disapproval decision and other required information. While 

providing staff with such standardized language is a step forward, it will 

require SSA staff to combine language from the Section 211 guidance 

explaining why the worker did not meet the requirements of Section 211 

with the standardized language from the notice. We believe that having 

staff prepare the letters using information from two different places could 

increase the likelihood that all required information may not be included. 

Thus, we still believe that a standardized letter containing all of the 

required information regarding the disapproval decision is needed. 

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after its 

issue date. At that time, we will send copies of this report to the 

Commissioner of SSA, the Secretary of DHS, and the Commissioner of IRS, 

and other interested parties. Copies will also be made available at no 

charge on GAO’s Web site at http://www.gao.gov. 
Page 19 GAO-06-196 Social Security Protection Act 

If you have questions concerning this report, please call me on 

(202) 512-7215. Contact points for our Offices of Congressional Relations 

and Public Affairs, respectively, are Gloria Jarmon, who may be reached 

on (202) 512-4470, and Paul Anderson, who may be reached on 

(202) 512-4800. 

Sincerely yours, 

Barbara D. Bovbjerg 

Director, Education, Workforce, 

 and Income Security 
Appendix I: Objectives, Scope, and 

Methodology 

Page 20 GAO-06-196 Social Security Protection Act 

In assessing the Social Security Administration’s (SSA) implementation of 

Section 211 and the adequacy of its policies and procedures, we reviewed 

the law and discussed its legal interpretation with GAO and SSA attorneys. 

We also reviewed prior GAO, SSA Office of Inspector General (OIG), 

Congressional Research Service (CRS), and other reports on the new law 

and related issues. We also reviewed various documents detailing SSA’s 

guidance on Section 211. In particular, we examined relevant sections of 

SSA’s Program Operations Manual System (POMS) that explained the 

procedures for processing claims covered by Section 211. We obtained 

information from officials in SSA headquarters in Baltimore, Maryland, 

and the four field offices we visited (Williamsburg Field Office in 

Brooklyn, New York, and the Culver City, Redlands, and Porterville Field 

Offices in California) on the training provided to staff. We selected the 

four field offices because of the geographic proximity of multiple offices in 

a single state and because the information that we had at the time of our 

visits showed that the offices had individually or collectively—within their 

region—processed a large number of claims that had been disapproved as 

a result of Section 211 requirements. 

To ascertain whether SSA made proper decisions for claims involving 

primary workers who were noncitizens, we reviewed: 

(1) all 19 approved claims in which SSA had assigned a nonwork 

SSN to the noncitizen workers after 2003, and 

(2) all 41 disapproved claims in which SSA had reached its decision 

as a result of the Section 211 requirements. 

To identify claims possibly covered by Section 211, we obtained data on 

claims that SSA had approved for benefit payments involving noncitzen 

workers between January 2004 and December 2005. SSA provided 

information on these claims from its electronic Master Beneficiary Record 

file, which maintains data on all benefit claims. From these files, we 

obtained data such as the filing date for the claim, the type of SSN 

assigned to the primary worker, the date the SSN was assigned to the 

worker, the type of claim, among other pieces of information. We 

reviewed these data from the Master Beneficiary Record for the 

19 approved claims and discussed each of the claims with SSA officials. 

For the 41 claims that had been disapproved due to Section 211 

requirements, we reviewed all of the available documentation associated 

with each claim and discussed the claims with SSA officials. The file 

documentation in some cases included only the letter notifying the 

claimant(s) of the disapproval decision, and in other cases, a combination 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology 

Page 21 GAO-06-196 Social Security Protection Act 

of other documents such as earnings statements and immigration 

documents. Additionally, we discussed with managers and staff in the four 

SSA field offices we visited the claims that they had disapproved based on 

Section 211. We did not review any approved cases in the four field offices, 

because information on the approved cases for the offices was not 

available at the time. To more generally assess the extent to which Section 

211 had impacted the payment of benefits for claims that involved primary 

workers who were noncitizens—and therefore possibly covered by 

Section 211—we obtained data on all such claims that SSA had decided 

between January 2004 and December 2005. This data showed that SSA had 

decided a total of approximately 177,000 claims, of which some 105,000 

had been approved and 72,000 had been disapproved. 1

To determine if there are circumstances under which certain noncitizens 

could still receive benefits based on unauthorized employment, we 

interviewed SSA headquarters officials and managers and staff in the four 

field offices we visited. We also obtained data from SSA on certain 

noncitizens issued temporary work visas that make them eligible to 

receive work-authorized SSNs. SSA officials identified 23 temporary visa 

categories that qualify individuals for such SSNs (app. II lists the 23 visa 

categories). We obtained data from SSA on the number of SSNs it had 

assigned to individuals for each of the visa types between 2000 and 2004. 

SSA’s data showed that it had assigned almost 1 million SSNs to these 

temporary workers. We compared SSA’s data to the number of temporary 

work visas that the Department of State had issued for the 23 visa types 

between 2000 and 2004 and found that SSA’s overall numbers were 

reasonable. We also discussed with officials at the Internal Revenue 

Service and the Department of Homeland Security their policies regarding 

noncitizens issued temporary work visas. 

We conducted our work between February 2005 and January 2006 in 

accordance with generally accepted government auditing standards. 

 1

SSA data showed that it had disapproved approximately 72,000 claims between January 

2004 and December 2005 for failure to meet either work credit or Section 211 requirements; 

this total does not include any claims that were disapproved due to lack of evidence of a 

medical disability. 
Appendix II: Examples of Temporary Visa 

Categories Issued SSNs 

Page 22 GAO-06-196 Social Security Protection Act 

Visas Authorized Activity Under Temporary Visa 

 Foreign Government Officials 

A-1 Ambassador, public minister, career, diplomatic or consular officer, 

and members of immediate family 

A-2 Other foreign government official or employee, and members of 

immediate family 

A-3 Attendant, servant, or personal employee of A-1 and A-2, and 

members of immediate family 

Visitors 

C-2 Alien in transit to UN headquarters district under Section 11.(3), (4), 

or (5) of the Headquarters Agreement 

C-3 Foreign government official, members of immediate family, 

attendant, servant, or personal employee, in transit 

Academic Students 

F-1 Academic Student 

Foreign Government Officials to International Organizations 

G-1 Principal resident representative of recognized foreign member 

government to international organization, and members of 

immediate family 

G-2 Other representative of recognized foreign member government to 

international organization, and members of immediate family 

G-3 Representative of non-recognized or nonmember government to 

international organization, and members of immediate family 

G-4 International organization officer or employee, and members of 

immediate family 

G-5 Attendant, servant, or personal employee of G-1, G-2, G-3, G-4, or 

members of immediate family 

Temporary Workers 

H-1B Specialty Occupations, fashion models 

H-2A Temporary Agricultural Worker 

Exchange Visitors 

J-1 Exchange Visitors; visitor categories can include camp counselors, 

students, government visitors, physicians, professors, short-term 

scholars, and trainees 

Vocational and Language Students 

M-1 Vocational student or other nonacademic student 

North Atlantic Treaty Organization 

NATO-1 Principal Permanent Representative of Member State to NATO and 

resident members of official staff or immediate family 

NATO-2 Other representatives of member State; Dependents of Member of a 

Force entering in accordance with the provisions of NATO Status-ofForces agreement; Members of such a Force if issued visas 

Appendix II: Examples of Temporary Visa 

Categories Issued SSNs 
Appendix II: Examples of Temporary Visa 

Categories Issued SSNs 

Page 23 GAO-06-196 Social Security Protection Act 

Visas Authorized Activity Under Temporary Visa 

NATO-3 Official clerical staff accompanying Representative of Member State 

to NATO or immediate family 

NATO-4 Official of NATO other than those qualified as NATO-1 and 

immediate family 

NATO-5 Expert other than NATO officials qualified under NATO-4, employed 

on behalf of NATO and immediate family 

NATO-6 Member of civilian component who is either accompanying a Force 

entering in accordance with the provisions of the NATO Status-ofForces agreement; attached to an Allied headquarters under the 

protocol on the Status of International Military headquarters set up 

pursuant to the North Atlantic Treaty; and their dependents 

NATO-7 Servant or personal employee of NATO-1, NATO-2, NATO-3, 

NATO-4, NATO-5, NATO-6, or immediate family 

International Cultural Exchange Visitors 

Q-1 International cultural exchange visitors; the “Q-1” visa is for certain 

international cultural exchange programs designed to provide 

practical training and employment, and sharing of the history, 

culture, and traditions of participants home country in the United 

States 

Source: DHS. 
Appendix III: Comments from the Social 

Security Administration 

Page 24 GAO-06-196 Social Security Protection Act 

Appendix III: Comments from the Social 

Security Administration 
Appendix III: Comments from the Social 

Security Administration 

Page 25 GAO-06-196 Social Security Protection Act 
Appendix III: Comments from the Social 

Security Administration 

Page 26 GAO-06-196 Social Security Protection Act 
Appendix IV: GAO Contact and Staff 

Acknowledgments 

Page 27 GAO-06-196 Social Security Protection Act 

Barbara D. Bovbjerg (202) 512-7215 or bovbjergb@gao.gov 

The following team members made key contributions to this report: 

Blake Ainsworth, Assistant Director, Susan Bernstein, Mary Crenshaw, 

Jason Holsclaw, Kevin Jackson, Mimi Nguyen, Daniel Schwimer, 

Vanessa Taylor, and Paul Wright. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Acknowledgments 

(130453) 
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