United States Government Accountability Office

GAO Report to the Chairman, Committee on 

the Judiciary, House of Representatives

SOCIAL SECURITY 

ADMINISTRATION 

Improved Agency 

Coordination Needed 

for Social Security 

Card Enhancement 

Efforts 

March 2006 

 

GAO-06-303 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 2006

SOCIAL SECURITY ADMINISTRATION

Improved Agency Coordination Needed 

for Social Security Card Enhancement 

Efforts 

Highlights of GAO-06-303, a report to the 

Chairman, Committee on the Judiciary, 

House of Representatives

The Social Security Administration

(SSA) has issued more than 

430 million Social Security 

numbers (SSN) and cards since the 

Social Security program began in

1935, of which an estimated 

300 million belong to living number 

holders. SSNs have a key role in 

verifying individuals’ authorization 

to work in the United States, but 

SSN cards are also vulnerable to

theft and counterfeiting. The 

Intelligence Reform and Terrorism 

Prevention Act of 2004 requires

that SSA consult with the 

Department of Homeland Security

(DHS), form a task force, establish 

standards for safeguarding the SSN

and card, and provide for

implementation by June 2006. 

Concerns about unauthorized 

workers and the use of counterfeit 

documents led the Chairman of the 

House Judiciary Committee to ask 

that GAO (1) review SSA’s progress

to safeguard the SSN and enhance 

the card as required under the 

Intelligence Act, (2) identify key

issues to be considered before 

enhancing the card, and (3) outline

the range of options available to

SSA for enhancing the card. 

What GAO Recommends

As the SSA-led task force works to

protect the Social Security card, 

GAO recommends that DHS and 

SSA work together to resolve the 

card’s weaknesses in proving

employment eligibility. DHS agreed

but SSA agreed in part, stating that 

aspects of the recommendation are

beyond the Intelligence Act scope. 

SSA has implemented several provisions of the Intelligence Act intended to 

help safeguard the SSN and card, but slow action to form the interagency 

task force may limit card enhancement efforts. SSA has implemented 

measures to limit the number of replacement cards, verify birth certificates

for applicants under age 1, and improve the Enumeration at Birth process. 

SSA has taken action to include death indicators and initiated work on fraud 

indicators for Social Security accounts in its database. SSA set specific tasks 

and timelines to address card enhancement options and made a preliminary 

decision to improve the current paper card and issue the improved cards

only to new card applicants. Although the card plays a significant role in 

verifying individuals’ authorization to work, SSA did not consult DHS about 

these initial tasks or the formation of the interagency task force until 

November 2005 and did not convene the task force until late January 2006. 

This allows less than 6 months for the task force to consider critical issues

that affect card enhancements before establishing new safeguards. 

The difficulty of counterfeit-proofing the card, the role the card has in 

determining employment eligibility, and ongoing enhancements to state 

drivers’ licenses and identification cards are critical issues to consider 

before enhancing the Social Security card. Counterfeit protections were first 

added in 1983 but older versions of the card remain valid. Millions of older 

cards never established employment eligibility because SSA did not require 

that everyone present evidence of age, identity, or citizenship status until 

1978. Prior GAO work shows that the employment verification process is 

jeopardized by document and identity fraud, the wide array of documents 

that can be used, weak worksite enforcement, and flaws in the voluntary 

electronic verification system. DHS is currently considering reducing the 

number of acceptable documents used to verify employment eligibility.

Changes to drivers’ licenses and identification cards under the Real ID Act 

will improve verification of identity in the employment process, since states 

must verify the SSN and legal presence upon application. However, states 

are not required to check or note employment eligibility. 

Once these critical issues are considered, a variety of options exist for 

enhancing the Social Security card, ranging from enhancing the paper card, 

to adding machine-readable or biometric features such as photographs and 

fingerprints, to eliminating the card entirely. Additionally, the costs of 

implementing each option will vary. Each option provides different 

alternatives for improving the ability to verify employment eligibility. The 

type of card and distribution method chosen will have a significant effect on 

costs and the agency’s workload. For example, if cards require a fingerprint 

or photograph, additional infrastructure will be required to obtain these 

features; reissuing new cards to the estimated 300 million living cardholders 

or staggering issuance to certain groups, such as those who change jobs, 

would require a different investment of resources. However, decisions about 

the card’s role will be crucial in determining costs.

www.gao.gov/cgi-bin/getrpt?GAO-06-303.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Barbara D. 

Bovbjerg at (202) 512-7215 or 

bovbjergb@gao.gov. 
Contents 

Letter 1

Results in Brief 3 

Background 6

SSA Has Made Progress on Intelligence Act Provisions, but Slow 

Action to Form the Interagency Task Force May Limit Card 

Enhancement Efforts 9 

The Difficulty of Counterfeit-proofing the Card, the Role the Card 

Has in the Employment Verification Process, and Improvements 

to Drivers’ Licenses Are Critical Issues to Consider 15 

A Range of Enhancement Options Exists, and Costs Would Vary 23 

Conclusions 32

Recommendation for Executive Action 32 

Agency Comments 33 

Appendix I Scope and Methodology 37 

Appendix II Department of Homeland Security Form I-9 39 

Appendix III Comments from the Department of Homeland Security 42 

Appendix IV Comments from the Social Security Administration 44 

Appendix V GAO Contact and Staff Acknowledgments 49 

Related GAO Products 50 

Tables 

Table 1: Original SSNs and Replacement Social Security Cards 

Issued in Fiscal Year 2005 7 

Table 2: Social Security Administration Timeline for Implementing 

Social Security Card Enhancements 13 

Page i GAO-06-303 Social Security Administration
Table 3: Examples of Fraudulent Social Security Card Activity 16 

Table 4: Acceptable Documents in the Employment Verification 

Process 18

Table 5: Requirements for State-Issued Drivers’ Licenses or ID 

Cards under the Real ID Act of 2005 22 

Table 6: Factors that Affect Costs of Enhanced Card Options 30 

Table 7: Card Issuance Options 31 

Figures 

Figure 1: Interagency Task Force Required by the Intelligence Act, 

November 2005 14 

Figure 2: Examples of Possible Social Security Card with Reverse 

Showing Magnetic Stripe and Secure Bar Code 25 

Figure 3: Examples of Biometrics—Fingerprint, Facial 

Recognition, and Photograph 27 

Abbreviations 

DHS Department of Homeland Security 

OIG Office of the Inspector General 

SSA Social Security Administration 

SSN Social Security number 

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Page ii GAO-06-303 Social Security Administration
United States Government Accountability Office

Washington, DC 20548 

March 29, 2006 

The Honorable F. James Sensenbrenner, Jr. 

Chairman 

Committee on the Judiciary 

House of Representatives 

The Honorable F. James Sensenbrenner, Jr. 

Chairman 

Committee on the Judiciary 

House of Representatives 

Dear Mr. Chairman: 

The Social Security Administration (SSA) has issued more than 430 million 

Social Security numbers (SSN) and cards since the Social Security 

program began in 1935. SSA uses the number to track workers’ earnings 

and eligibility for Social Security benefits, while the card serves as an 

individual’s record of the number. Over the years, the SSN is increasingly

used as a unique personal identifier by government agencies and 

businesses to maintain records and by individuals to file tax returns, open 

bank accounts, apply for credit, and conduct consumer transactions. Since 

passage of the Immigration Reform and Control Act of 1986, Social 

Security cards, drivers’ licenses, birth certificates, and other documents 

are also used to verify individuals’ eligibility to work in the United States 

as well as apply for government benefits. However, these documents can 

and have been altered, counterfeited, or stolen to gain access to legitimate 

documents, create false identities, obtain employment, or commit financial 

crimes. The National Commission on Terrorist Attacks upon the United

States (the 9/11 Commission) reported that all but one of the hijackers had 

acquired U.S. identification documents, some by fraud. The 9/11 

Commission recommended that the federal government strengthen the 

issuance standards for birth certificates and drivers’ licenses, and 

subsequent legislation also included Social Security cards. 

The Social Security Administration (SSA) has issued more than 430 million 

Social Security numbers (SSN) and cards since the Social Security 

program began in 1935. SSA uses the number to track workers’ earnings 

and eligibility for Social Security benefits, while the card serves as an 

individual’s record of the number. Over the years, the SSN is increasingly

used as a unique personal identifier by government agencies and 

businesses to maintain records and by individuals to file tax returns, open 

bank accounts, apply for credit, and conduct consumer transactions. Since 

passage of the Immigration Reform and Control Act of 1986, Social 

Security cards, drivers’ licenses, birth certificates, and other documents 

are also used to verify individuals’ eligibility to work in the United States 

as well as apply for government benefits. However, these documents can 

and have been altered, counterfeited, or stolen to gain access to legitimate 

documents, create false identities, obtain employment, or commit financial 

crimes. The National Commission on Terrorist Attacks upon the United

States (the 9/11 Commission) reported that all but one of the hijackers had 

acquired U.S. identification documents, some by fraud. The 9/11 

Commission recommended that the federal government strengthen the 

issuance standards for birth certificates and drivers’ licenses, and 

subsequent legislation also included Social Security cards. 

The Intelligence Reform and Terrorism Prevention Act of 2004 requires 

that SSA consult with the Department of Homeland Security (DHS) and 

form an interagency task force to establish standards to better protect the

SSN and card from counterfeiting, tampering, alteration, and theft, and 

provide for the implementation of security requirements including 

standards for safeguarding Social Security cards from counterfeiting and 

theft by June 2006. Although SSA is responsible for issuing the card, DHS 

monitors employers who are responsible for certifying the authenticity of

documents, such as the card, when presented as proof of eligibility to 

work. Congressional concerns about identification documents and 

questions about unauthorized workers prompted your request for us to 

The Intelligence Reform and Terrorism Prevention Act of 2004 requires 

that SSA consult with the Department of Homeland Security (DHS) and 

form an interagency task force to establish standards to better protect the

SSN and card from counterfeiting, tampering, alteration, and theft, and 

provide for the implementation of security requirements including 

standards for safeguarding Social Security cards from counterfeiting and 

theft by June 2006. Although SSA is responsible for issuing the card, DHS 

monitors employers who are responsible for certifying the authenticity of

documents, such as the card, when presented as proof of eligibility to 

work. Congressional concerns about identification documents and 

questions about unauthorized workers prompted your request for us to 

Page 1 GAO-06-303 Social Security Administration
review SSA’s efforts under the Intelligence Act.1

 In response to the request, 

we (1) reviewed the progress of SSA’s efforts to safeguard the SSN and 

enhance the card as required under the act, (2) identified key issues to be 

considered before enhancing the card, and (3) outlined the range of 

options available to SSA for enhancing the card. 

In conducting our review, we met with officials from the Social Security 

Administration and the Department of Homeland Security. We also met 

with officials from the Government Printing Office who administer the 

contract for printing Social Security cards. We documented key issues SSA 

should consider as it proceeds with changing the Social Security card by

interviewing officials from SSA, DHS, the American Association of Motor 

Vehicle Administrators, and state motor vehicle administrators in Illinois, 

West Virginia, and Wyoming. We selected these three states because they 

used various security features in their drivers’ licensing or identification 

processes such as fingerprinting, advanced optical printing and inks, or 

holograms and other features, which already met stated or anticipated 

federal legislative requirements for improving drivers’ licenses and 

identification cards. We reviewed identification initiatives using 

biometrics at the United States Visitor and Immigrant Status Indicator 

Technology program and the Transportation Security Administration’s 

Registered Traveler program.2

 Finally, we met with employer association 

groups identified by the U.S. Chamber of Commerce. To examine the 

range of options available to SSA for enhancing the card, we researched 

and analyzed technical literature; identified card technologies; interviewed 

biometrics technology experts, vendors, and industry associations; and 

consulted the National Institute of Standards and Technology. We also met 

with Banknote Corporation of America, the contractor that prints Social 

Security cards, to discuss advances in security printing techniques. We 

performed our work between April 2005 and January 2006 in accordance 

with generally accepted government auditing standards. Appendix I 

discusses our scope and methodology in greater detail. 

 1

As used in this report, the Intelligence Act refers to the Intelligence Reform and Terrorism 

Prevention Act of 2004, Pub. L. No. 108-458 (2004). 

2

Biometrics is a technology that uses automated methods of recognizing a person based on 

analyzing physiological or behavioral characteristics such as fingerprints or facial features 

among others. 

Page 2 GAO-06-303 Social Security Administration
The Social Security Administration has implemented several Intelligence 

Act provisions intended to help safeguard the SSN and the card, and made 

a preliminary decision to add improved security features to the card 

before convening the interagency task force that was required to develop

safeguards for the card. SSA has implemented measures to limit the 

number of replacement cards, verify birth certificates for applicants under 

age 1, and improve the application process of the Enumeration at Birth 

Program.3

 SSA has also taken action to include death indicators and 

initiated action to include fraud indicators in its database. Additionally, 

SSA set eight specific tasks and timelines to develop safeguards for 

enhancing the card before reaching the statutory implementation date of 

June 17, 2006. Three tasks were expected to be completed before 

convening the interagency task force and thereby involving DHS—

researching the range of available security features, coming to an internal

agreement on new security features for the paper card, and developing a 

publicity campaign for the new card. SSA officials told us that a 

preliminary decision had been made to develop an improved version of the 

current paper card and issue the improved cards only to new card 

applicants. Although the card plays a significant role in verifying 

individuals’ authorization to work, SSA did not consult with DHS as it 

worked for nearly a year on these three tasks. Further, SSA did not 

convene the task force until late January 2006, allowing the task force less

than 6 months to consider critical issues that affect card enhancement 

options before new safeguards are to be established in June 2006. SSA is 

required to provide for the implementation of security requirements by the 

same date. These officials told us that the agency is unlikely to take action

beyond enhancing features of the paper card without specific legislative 

direction to do so. 

Results in Brief 

The difficulty of counterfeit-proofing the card, the role the card has in 

determining employment eligibility, and ongoing enhancements to state 

drivers’ licenses and identification cards are critical issues to consider 

before enhancing the Social Security card. Counterfeit protections were 

first put on the card in 1983, but older versions of the card remain in 

circulation, and all cards, including those issued before counterfeit 

protections were put in place, are still valid. Use of these older versions of 

the card would adversely affect the intended benefits of a newly enhanced 

 3

Since 1989, SSA has used the voluntary Enumeration at Birth Program to allow parents the 

option of requesting SSNs for their newly born children at the birth facilities rather than 

having to visit an SSA field office. 

Page 3 GAO-06-303 Social Security Administration
card. Additionally, when SSA began issuing Social Security cards in 1936, 

individuals applying for a card were not required to provide information 

useful for determining employment eligibility, such as evidence of age, 

identity, or citizenship status—not until 1978 were all persons required to

provide this information. Since older cards never established employment 

eligibility, employers cannot be certain if individuals with older Social 

Security cards are eligible to work. However, the Social Security card is a 

key document for verifying an individual’s authorization to work. Prior 

GAO work shows that the employment verification process is jeopardized 

by document and identity fraud, the wide array of documents that 

applicants can present, weak worksite enforcement, and flaws in the 

voluntary electronic verification system.4

 To improve the employment 

verification process, DHS is currently considering reducing the number of 

acceptable documents permitted to verify employment eligibility. Further,

recent legislation will require states to verify the Social Security numbers 

and legal presence of individuals applying for state drivers’ licenses and 

identification cards---linking the estimated 250 million licenses and 

identification cards to the Social Security number and immigration 

documents. These improved licenses and identification cards could 

improve the employment verification process. However, they are not 

meant to prove employment eligibility, since states are not required to 

determine and note worker status when verifying the Social Security 

number with SSA and immigration documents with DHS. 

Once these critical issues are considered, a variety of options exist for 

enhancing the card, ranging from enhancing the paper card to adding 

machine-readable or biometric features such as photographs and 

fingerprints, to eliminating the card entirely. Additionally, the costs of 

implementing each option will vary. First, the paper card could be made 

more counterfeit-resistant with features such as the use of paper with a 

fiber content that reacts to certain chemicals or security threads similar to 

those used in U.S. paper currency. Second, the card could be plastic and 

include some machine-readable features such as a magnetic strip or secure 

bar code; employers would use automated equipment to determine an 

individual’s employment eligibility status. Third, the card could include 

some form of biometrics that links the card to the cardholder, such as a 

fingerprint or a photograph. Finally, SSA could eliminate the card and 

 4

GAO, Immigration Enforcement: Weaknesses Hinder Employment Verification and

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

Social Security: Better Coordination among Federal Agencies Could Reduce Unidentified

Earnings Report, GAO-05-154 (Washington, D.C.: Feb. 4, 2005). 

Page 4 GAO-06-303 Social Security Administration
instead issue a letter with an individual’s Social Security number; in the 

absence of the card, employers could use a system such as Basic Pilot, or

some similar system, to verify employment eligibility through SSA and

DHS using the Social Security number or Alien number provided by the 

worker in combination with an identification document such as a driver’s 

license. Each option provides different alternatives for improving the 

ability to verify employment eligibility. Choosing the type of card and the 

method for issuing new cards will have a significant effect on costs and 

the agency’s workload. For example, if cards are machine-readable or 

require a fingerprint or photograph, additional infrastructure will be 

needed to obtain and read these features. Reissuing new cards to all 300 

million current cardholders could improve the cards’ counterfeit 

resistance and strengthen the card as a worker authorization document, 

but would be costly. Staggering issuance of an enhanced card to certain 

groups, such as those who change jobs, would require a lower initial 

investment of resources. Decisions about the card’s role for SSA as well as 

in employment eligibility authorization will be crucial to determining the 

most cost-effective strategy for enhancing the card. 

As the SSA-led task force develops ways to protect the Social Security

card, we are making a recommendation to the Secretary of Homeland 

Security and the Commissioner of Social Security to work together to 

resolve the weaknesses of the Social Security card in proving employment 

eligibility. 

In response to our draft report, DHS agreed that much could be done on

an interagency basis to improve the integrity of Social Security cards and 

numbers as required under the Intelligence Act. DHS stated that 

determining what to do to make the card more secure or eliminating the

card altogether appears to be appropriate, and DHS will continue to work 

with SSA through the interagency task force. SSA said that it agreed in

part with our recommendation; although SSA stated that some aspects of 

the recommendation were outside the scope of what Congress provided in

the Intelligence Act, SSA said it would continue to work with DHS on 

issues related to employment eligibility and verification. SSA also 

expressed concern that current law requires that the Social Security card 

be made of banknote paper, and thus limits the task force’s consideration 

of improvements. SSA also suggests that requirements under the Real ID

Act could be modified so that drivers’ licenses could be made to reflect 

work authorization. DHS and SSA’s comments are reproduced in 

appendixes III and IV. 

Page 5 GAO-06-303 Social Security Administration
The Social Security Act of 1935 authorized a record-keeping system to help 

manage the Social Security program and resulted in the creation of the 

SSN. SSNs are now issued to most U.S. citizens at birth. They are also 

available to noncitizens lawfully admitted to the United States with 

permission to work. Lawfully admitted noncitizens may also qualify for an 

SSN for nonwork purposes when a federal, state, or local law requires that 

they have an SSN to obtain a particular public benefit or service. SSA is 

responsible for paying retirement, survivors’, and disability benefits to 

eligible insured persons based on their lifetime earnings in covered 

employment. SSA maintains a historical record of each worker’s annual 

earnings, which are identified by the worker’s name and SSN. 

Since the Social Security program began, SSA has issued over 430 million

Social Security numbers and cards, of which an estimated 300 million 

represent living number holders.5

 As shown in table 1, in fiscal year 2005,

SSA issued a total of 17.5 million SSN cards to U.S. citizens and to 

noncitizens, of which about 12.1 million were replacement cards. SSA 

issues replacement cards when individuals’ cards are lost, stolen, or 

require corrections to the original card. In fiscal year 2005, SSA issued 

about 4.3 million original SSNs to U.S. citizens, of which 3.9 million SSNs 

were issued to newborns through the voluntary Enumeration at Birth 

Program. Under this program, parents can request SSNs and cards for 

newborns at hospitals and other facilities at birth. The Enumeration at 

Birth Program eases SSA’s work demands in its approximately 1,300 field 

offices because parents using the Enumeration at Birth Program generally

do not need to visit SSA field offices.

Background 

Social Security Cards and 

Noncitizen Employment 

Eligibility 

 5

SSNs are assigned for the life of the number holder and remain valid indefinitely even after 

a number holder’s death for the purposes of administering survivor benefits. 

Page 6 GAO-06-303 Social Security Administration
Table 1: Original SSNs and Replacement Social Security Cards Issued in Fiscal 

Year 2005 

Numbers in millions 

U.S. citizens Noncitizens Overall Total 

Original SSNs and 

cards issued 4.28 1.12 5.40 

Replacement Social 

Security cards 11.27 0.81 12.08 

Total 15.55a1.94a17.48a

Source: SSA. 

a

Totals by category may not equal overall total because of rounding.

The card has also become a document used in controlling unauthorized 

work. In 1986, Congress enacted the Immigration Reform and Control Act 

to help reduce the attraction of employment to illegal aliens coming to this 

country.6

 The act made it illegal for individuals and entities to knowingly 

hire, continue to employ, or recruit unauthorized workers. The act 

required employers to review documents that established newly hired 

workers’ identity and eligibility to work in the United States and to sign 

statements certifying that the documents they review, such as a Social 

Security card, appear genuine and refer to the prospective worker. DHS 

has responsibility for implementing and enforcing the act and has 

authorized a combination of 27 documents that employees can choose 

from and provide to prove identity and eligibility to work. See appendix II

for DHS’s Form I-9, which contains a list of the documents used to verify 

employment eligibility. 

Efforts to Enhance the 

Card and Drivers’ Licenses 

As uses for the SSN have grown, misuses of the number and counterfeiting 

of the card have increased. Since the SSN’s creation, SSA has used the 

same basic wallet-sized card but included additional information on the 

card to meet the evolving role of the SSN. At present, there are 50 valid 

versions of the card—many of which have little or no counterfeit 

protection. On several occasions, Congress considered directing SSA to 

issue cards that were more resistant to tampering and counterfeiting. In 

1983, the Social Security Act was amended to require that the card be 

made of banknote paper and to the maximum extent practicable be a card 

that cannot be counterfeited. Later that year, SSA introduced a card with

security features including tinted patterns that show when information is 

 6

Pub. L. No. 99-603, (1986), 8 U.S.C.§ 1324a et seq. 

Page 7 GAO-06-303 Social Security Administration
erased, small multicolored discs randomly placed on the paper, and 

special raised ink. Some members of Congress subsequently expressed 

disappointment that these security features did not make the card 

significantly more difficult to counterfeit and that employers could not 

easily determine the card’s authenticity for employment authorization 

purposes. In 1996, Congress asked SSA to study and report on different 

methods for improving the Social Security card and develop a prototype of

a counterfeit-resistant Social Security card. In the report, SSA provided 

several options for enhancing the card, along with estimated costs, but did 

not recommend options for implementation. In 1998, we reviewed SSA’s 

estimates and agreed that a mass issuance of a more secure card would 

cost billions of dollars but concluded that alternative approaches to 

issuing new cards may provide a more cost-effective approach to verifying

individuals’ authorization to work. 

Since the terrorist attacks of September 11, 2001, Congress has focused 

attention on verifying identity and protecting American forms of 

identification. In December 2004, Congress enacted the Intelligence Act, 

which required improvements to birth certificates, drivers’ licenses, and 

Social Security cards. Under the act, minimum standards for birth 

certificates are to be established, such as certifications by state or local 

governments that they issued the document, the use of safety paper or an 

alternative, the use of a seal representing the issuing government entity 

and other features designed to prevent fraud. For the Social Security card, 

the act required improvements to the process for issuing the card and 

required that the Social Security Commissioner consult with the Secretary 

of Homeland Security to form a task force for the purpose of safeguarding

Social Security cards and numbers. Within an 18-month time frame 

following the December 2004 enactment of the act, the task force is to 

establish 

• standards for safeguarding Social Security cards from counterfeiting, 

tampering, alteration, and theft; 

• requirements for verifying documents submitted for the issuance of 

replacement cards; and 

• actions to increase enforcement against the fraudulent use or issuance 

of Social Security numbers and cards. 

The SSA Commissioner is to provide for the implementation of such 

security requirements by June 2006.

Page 8 GAO-06-303 Social Security Administration
In 2005, Congress enacted the Real ID Act, which, among other things 

amended the security requirements of the Intelligence Act for state drivers’ 

licenses.7

 Under the Real ID Act, the Secretary of Homeland Security must 

determine whether states meet certain minimum security requirements for 

drivers’ licenses and personal identification cards. The law provides that,

in order to be federally recognized, the state-issued card must have certain

physical security features designed to prevent tampering, counterfeiting,

or duplication, including a digital picture and machine-readable 

technology. The Real ID Act also requires individuals to provide evidence 

of their legal status to obtain a driver’s license and provide proof of their 

Social Security numbers so that states can verify the information with SSA. 

Additionally, the law requires that states verify individuals’ immigration 

status with DHS. Ultimately, Real ID prohibits federal agencies from 

accepting state-issued drivers’ licenses or identification cards as identity 

documents unless they are determined to meet certain minimum security 

requirements. 

SSA has made progress implementing the Intelligence Act requirements 

enacted in December 2004. The agency implemented provisions for 

obtaining replacement cards, verifying birth certificates of applicants 

under age 1, and improving the application process of the Enumeration at 

Birth Program. In addition, SSA has taken actions to include death 

indicators and initiated action to include fraud indicators on Social 

Security records. In the effort to safeguard the Social Security card and 

number, SSA did not contact DHS until November 2005 to form an 

interagency task force, and the task force did not meet until late January 

2006. This allows the task force less than 6 months to consider critical 

issues that affect card enhancement options before the establishment of 

security standards in June 2006. In addition, SSA is required to provide for 

the implementation of standards for safeguarding the card and number 

from counterfeiting, tampering, alteration, and theft by the same date. 

Before convening the task force, SSA made a preliminary decision to 

improve the current paper card. 

The Intelligence Act requires that, generally, SSA limit the number of 

replacement cards it issues to individuals to 3 annually and 10 over a 

SSA Has Made 

Progress on 

Intelligence Act 

Provisions, but Slow 

Action to Form the 

Interagency Task 

Force May Limit Card 

Enhancement Efforts

Replacement Cards 

Limited 

 7

Pub. L. No. 109-13, Emergency Supplemental Appropriations Act for Defense, the Global 

War on Terror, and Tsunami Relief, 2005, Title II, (2005). 

Page 9 GAO-06-303 Social Security Administration
lifetime, and the act increased requirements for verifying the authenticity

of documents presented before issuing replacement cards. SSA’s policy 

prior to the Intelligence Act allowed individuals to obtain as many as 52 

replacement cards annually, generally, requiring only proof of identity for 

U.S. citizens to receive the cards. GAO previously reported on the 

potential for fraud with SSA’s replacement card policy. Our investigators 

were able to obtain 8 replacement cards in less than 6 weeks before SSA 

placed a fraud alert on the SSN accounts.8

 In response to the act, SSA 

reported that the agency had 

• modified its computer system to enable monitoring the number of 

cards issued to individuals; 

• published interim final regulations on replacement cards in the Federal 

Register on December 16, 2005; 

• issued operating instructions for SSA employees to use in processing 

claims and conducting the daily business of the agency; and 

• provided training to staff on SSA’s new policy on replacement cards. 

Minimum Standards for 

Verifying Documents 

Established 

The Intelligence Act requires that SSA establish minimum standards for 

verifying documents or records that individuals present when applying for 

original and replacement Social Security cards other than through the 

Enumeration at Birth process. SSA reported that it had 

• published operating instructions that describe the minimum standards 

for verifying all documents submitted for enumeration; 

• created a new fact sheet for applicants explaining the Intelligence Act 

provisions and revised public information, such as brochures and 

pamphlets; and 

• provided training to SSA personnel on the minimum standards for 

verifying all documents. 

 8

GAO, Social Security Administration: Actions Needed to Strengthen Processes for

Issuing Social Security Numbers to Children, GAO-05-115 (Washington, D.C.: Jan. 31,

2005). 

Page 10 GAO-06-303 Social Security Administration
The act required that SSA independently verify birth certificates that 

individuals submit to establish eligibility for a Social Security number. 

Prior to the act, SSA required verification of birth certificates for 

individuals over age 1, but required only a visual inspection of birth 

certificates for children under age 1 who were assigned SSNs outside the 

Enumeration at Birth process. Both GAO and SSA’s Office of the Inspector 

General (OIG) identified the potential for fraud with the verification of 

birth certificates because SSA personnel could not detect counterfeit birth 

certificates by visual inspection, and because no verification of documents 

with the issuers was required for replacement Social Security cards. GAO 

investigators posing as parents of children under age 1 used counterfeit 

birth certificates to get two SSNs for fictitious children. In one instance,

the investigators supplied the counterfeit documents in person; in the 

other, they mailed the counterfeit documents. In both cases SSA staff 

verified the counterfeit documents as valid and SSA issued the SSNs and

cards. SSA reported that upon enactment of the Intelligence Act, the 

agency changed its policy for verifying birth certificates for individuals 

under age 1. Specifically, SSA 

• issued Program Operations Manual System requirements for 

independently verifying birth certificates, and 

• provided training to SSA personnel on specific requirements for 

verifying birth certificates. 

The Intelligence Act requires that SSA undertake to improve the 

application process for assigning Social Security numbers to newborns. 

The act requires that SSA improve the 

Birth Certificates for Card 

Applicants under Age 1 

Independently Verified 

Progress Made on 

Enumeration at 

Birth Process 

• assignment of Social Security numbers to unnamed children, 

• issuance of SSNs to prevent assigning more than one Social Security 

account to the same child, and 

• system to prevent other opportunities for fraudulently obtaining a 

Social Security account number. 

Prior GAO work showed that SSA did not have sufficient internal controls 

in place to minimize fraudulent activities that could affect the 

Enumeration at Birth data that SSA uses to issue SSNs and cards. 

Additionally, the SSA OIG reported various vulnerabilities in the 

Enumeration at Birth Program and suggested that SSA provide more 

Page 11 GAO-06-303 Social Security Administration
systematic oversight and management. As of our review, SSA reported that

the agency has made systems changes to improve the Enumeration at 

Birth Program. For example, a more detailed check of the child’s name 

will be made to prevent assigning SSNs to “Baby Boy” or “Baby Girl,” or to 

issue two different SSNs to the same child by honoring the parents’ 

request at the hospital but then honoring a second request a short time 

later through a field office with a claim of nonreceipt of the SSN through 

the hospital or an urgent need for the SSN. SSA submitted a report to 

Congress detailing these improvements in December 2005. 

The act also required that SSA conduct a study to determine the options 

for ensuring the integrity of the Enumeration at Birth Program. 

Specifically, the report must include an examination of available methods 

to reconcile hospital birth records with birth registrations submitted to 

state agencies that submit data to SSA as part of the Enumeration at Birth 

process. 

SSA reported that it asked the Inspector General to conduct the required 

study, and the Inspector General plans to deliver the study to Congress by 

June 2006. 

The Intelligence Act requires that SSA add death and fraud indicators to 

the systems for verifying Social Security numbers so employers and state

agencies issuing drivers’ licenses and identification cards can receive

accurate information when verifying the SSN. Death and fraud indicators 

are “flags,” or “alerts,” that SSA would place on SSN accounts to warn 

inquirers that certain SSN accounts belong to a deceased person or were

used for fraudulent purposes. SSA is required to add death indicators by 

June 17, 2006, and fraud indicators by December 17, 2007. SSA reported 

that the agency currently maintains death information in its records and

has added state death information to its verifications as of March 6, 2006.

SSA reported that it has begun to discuss what steps are needed but has 

not yet drafted guidance for handling fraud indicators. 

The Intelligence Act requires that SSA consult with DHS and form an 

interagency task force to safeguard Social Security cards and numbers. 

Under the act, the task force has 18 months to establish standards for 

preventing counterfeiting, tampering, alteration, and theft. During the first 

12 months since enactment, SSA has conducted research on enhancement

options, come to a preliminary internal agreement on the features a newly 

enhanced card might have, and discussed what type of publicity campaign 

Work on Death Indicators 

Taken and Fraud 

Indicators Initiated 

SSA Has Moved Slowly to 

Convene the Interagency 

Task Force for 

Safeguarding the Card 

Page 12 GAO-06-303 Social Security Administration
is needed to promote an enhanced paper Social Security card. However, 

SSA did not consult with DHS about the formulation of an interagency 

task force until November 2005, and the task force did not meet until late

January 2006, allowing the task force less than 6 months before security 

standards are to be established in June 2006. SSA is required to provide for 

implementation of the new safeguards by the same date. Prior to 

consulting with DHS on forming the interagency task force, SSA made a 

preliminary decision to enhance security features for the paper card. 

According to SSA, the agency wanted to have an approach to present to 

the task force once it convened. Table 2 shows the timeline SSA has set for 

implementing tasks related to card enhancement.

Table 2: Social Security Administration Timeline for Implementing Social Security 

Card Enhancements

Intelligence Reform and Terrorism Prevention Act passed 12/17/04

Task name Start Finish

Research and benchmarkinga1/3/05 8/16/05

SSA internal agreement on new security features for SSN cards 8/18/05 12/16/05

Develop publicity campaignb8/18/05 12/16/05

Interagency task force agreement on new security features 12/19/05 3/17/06

Prepare new contract for SSN card 3/20/06 6/16/06

Provide SSA systems support for changes 3/20/06 6/16/06

Finalize SSA publicity campaign 3/20/06 6/16/06

Report to Congress 6/17/06 6/17/06

Source: SSA. 

a

Research and benchmarking were not completed as of February 3, 2006 to allow for coordination 

with the Document Security Alliance regarding card enhancement options. 

b

The publicity campaign has been discussed but is not yet complete. SSA noted that these timelines

are internal guidelines with room built in to allow for slippage, but the agency fully expects to meet the

legislated completion date of June 17, 2006. 

Page 13 GAO-06-303 Social Security Administration
SSA officials told us that they expect the interagency task force to include 

representation from DHS and several other agencies. According to SSA, 

the task force’s first meeting in January 2006 addressed the Intelligence 

Act requirement to establish standards for verifying documents submitted 

to obtain replacement cards. SSA reported that the task force will address 

other requirements of the Intelligence Act, such as enhancements to the 

Social Security card in future meetings. While the task force has broad 

latitude to address issues relative to the Social Security card, information 

SSA and DHS provided at the time of our review does not indicate that the 

task force will address the role of the card in verifying employment 

eligibility. According to SSA, final agreements on the new features to add 

to the card will be made based partly on results from work being 

performed by the Document Security Alliance, a group of experts on 

document security with representatives from industry and government 

agencies. Figure 1 shows the task force membership and structure as 

proposed by SSA. 

Figure 1: Interagency Task Force Required by the Intelligence Act, November 2005 

Source: GAO.

Government

Printing Office

Federal Bureau

of Investigation

Department of 

Justice

Chair

Assistant Deputy Commissioner 

Disability and Income Security Programs

Social Security Administration

Department of 

State

Immigration and

Customs Enforcement

Department of 

Homeland Security

Bureau of Engraving

and Printing

Department of 

the Treasury

Page 14 GAO-06-303 Social Security Administration
The Social Security card is a critical federal government document that is 

used in daily American life, and understanding what is needed to protect 

the card is essential to enhancement efforts. Critical issues to consider 

include the difficulty of developing and maintaining a counterfeit-proof 

card, the role the card has in the employment verification process, and 

new requirements of state drivers’ licenses and identification cards that 

provide links to the card and immigration documents and could help 

improve the employment verification process. 

In the past 30 years the Social Security number and card have become 

critical to daily functions in the United States, such as filing tax returns, 

opening bank accounts, applying for credit, conducting consumer 

transactions, and obtaining employment. As uses for the number and card 

have grown, demand for counterfeit cards has risen. In testimony before 

Congress, SSA’s Assistant Deputy Commissioner for Disability and Income 

Security Programs (Program Policy) stated that when the Social Security

program began, no special efforts were needed to prevent the Social 

Security card from being counterfeited, but as the card’s use expanded

and technology improved, counterfeiting became a concern. According to 

the Assistant Deputy Commissioner, SSA has incorporated a number of 

security features to make the card counterfeit-resistant since 1983, but the 

expertise of counterfeiters and the wide availability of state-of-the-art 

technology make it increasingly difficult to develop and maintain a 

document that cannot be counterfeited.9

 Table 3 describes four examples 

of fraudulent Social Security card activity. 

The Difficulty of 

Counterfeit-proofing 

the Card, the Role the 

Card Has in the 

Employment 

Verification Process, 

and Improvements to 

Drivers’ Licenses Are 

Critical Issues to 

Consider 

A Counterfeit-proof Social 

Security Card Is Difficult 

to Develop and Maintain 

 9

Testimony of the 109th Congress, Social Security Testimony before Congress, November 1, 

2005, Statement of Frederick G. Streckewald, Assistant Deputy Commissioner, Office of 

Disability and Income Security Programs (Program Policy), before the House Committee 

on Ways and Means, Subcommittee on Social Security. 

Page 15 GAO-06-303 Social Security Administration
Table 3: Examples of Fraudulent Social Security Card Activity 

Document fraud: Law enforcement officials investigating an alleged case of document 

fraud in the state of Maryland in December 2005 expressed concern that technology has 

improved so much that it is difficult to identify counterfeit documents. These officials 

arrested an individual for allegedly selling a fake Social Security card and an immigration

document (resident alien card) for about $250 to a law enforcement official posing as an 

undocumented immigrant. According to the law enforcement report, two passport-sized 

photographs were provided so that a resident alien card could be made, along with a 

Social Security card, both of which were ready in 3 days. 

Document fraud: In testimony before the House Committee on Ways and Means in 

November 2005, the Deputy Inspector General for SSA stated that investigators had 

apprehended an individual who used counterfeit immigration documents to obtain over 

600 valid Social Security numbers to sell to undocumented immigrants at a price of 

$1,000 to $2,000. In addition, this person had multiple Social Security cards and 

photocopies of cards. Counterfeit Social Security cards and activities have also involved

U.S. citizens. 

Identity and mail fraud: The SSA Inspector General reported in August 2005 that a 

university professor was indicted on 33 counts of mail fraud for posing as a parent and 

using students’ personal information to obtain Social Security cards, credit cards, and 

birth certificates.

a

 

Identity and document fraud: The Deputy Inspector General testified that in August 

2005, one individual was sentenced to 18 months’ incarceration for submitting more than

200 applications for Social Security numbers for fictitious children using fraudulent birth 

certificates and other falsified documents. The individual used two identities, one of 

which belonged to a person who had been dead for a year. 

Source:Montgomery County, Maryland Police Department and SSA Inspector General. 

a

Office of the Inspector General, Social Security Administration, Universities’ Use of Social Security

Numbers as Student Identifiers in Region VI, A-06-05-15100 (August 2005). 

Although the card is now used as documentation for government and 

nongovernment functions, the card was never intended as a personal 

identification document and does not establish the person presenting the 

card as the person whose name and SSN appear on the card. According to

SSA, while the card has some counterfeit-resistant features, it does not 

contain information that would allow the card to be used as proof of 

identity. In its 1997 Report to Congress on Options for Enhancing the 

Social Security Card, SSA reported that 

Page 16 GAO-06-303 Social Security Administration
“The only way the Social Security card can, with certainty, assure that the bearer of the

card is the assigned number holder is if the number holder’s identifying information,

picture, fingerprint, or biometric identifier is on the card itself. Then, someone needing

assurance the card bearer is the assigned number holder could perform a visual 

comparison with the number holder’s picture or identifying information, or an electronic 

comparison to a biometric identifier stored on the Social Security card.” 

SSA reported that linking the number holder to the card would entail 

collecting and maintaining biometric data, a step the agency reported 

would be costly for the agency and complicated for the public. Although 

the technology has advanced since the 1997 SSA report, the agency 

maintains that the same principles of cost and complexity apply. The 

ability to tie the card to the cardholder could assist SSA in reducing the 

number of instances in which wages are not credited to the correct Social 

Security account and assist DHS in its efforts to confirm the immigration 

status of nonimmigrants. 

The Card Is a Weak Link in 

the Employment 

Verification Process 

The Social Security card is commonly presented as a document to prove 

authorization to work. As part of the employment verification process, job 

applicants can choose from a list of 27 documents that employers then use 

to verify identity and employment eligibility. Employers are required to 

certify on DHS’s Form I-9 that they have examined the documents 

presented, and that the documents appear genuine and relate to the 

person presenting them. As shown in table 4, documents from three 

categories may be used to establish identity and employment eligibility. 

See appendix II for Form I-9. 

Page 17 GAO-06-303 Social Security Administration
Table 4: Acceptable Documents in the Employment Verification Process 

List A 

Documents that establish both identity and

employment eligibility 

(only one document from this category 

needed) 

List B 

Documents that establish identity 

(a document from this category

must be used with one from List

C) 

List C 

Documents that establish employment 

eligibility 

(a document from this category must be

used with one from List B) 

(1) U.S. passport (1) Driver’s license or ID card issued 

by a state or U.S. possession

(1) U.S. Social Security card issued by 

SSA 

(2) Unexpired foreign passport (2) ID card issued by federal, state, 

or local governments 

(2) Certification of birth abroad issued by 

the State Department 

(3) Permanent Resident card or Alien Registration 

Receipt card with photograph

(3) School ID card with a photograph (3) Original or certified copy of a birth 

certificate issued by a state, county, etc. 

bearing an official seal

(4) Unexpired Temporary Resident card (4) Voter’s registration card (4)Native American tribal document 

(5) Unexpired Employment Authorization card (5) U.S. military card or draft record (5) U.S. citizen ID card 

(6) Unexpired reentry permit (6) Military dependent’s ID card (6) ID card for use of resident citizen in the 

United States 

(7) Unexpired refugee travel document (7) U.S. Coast Guard Merchant 

Mariner’s card

(7) Unexpired employment authorization 

document issued by DHS 

(8) Unexpired employment authorization 

document issued by DHS with a picture 

(8) Native American tribal document 

(9) Driver’s license issued by a 

Canadian government authority

(10) School record or report card 

(11) Clinic, doctor or hospital record 

(12) Day-care or nursery school 

record 

Source: Department of Homeland Security. 

While the employment verification process relies on a variety of 

documents to establish identity, the role of the Social Security card in 

proving authority to work has limitations. Millions of existing cardholders 

have not proven their employment eligibility status to SSA, because SSA 

did not begin requiring identification documents from all persons until 

1978. According to SSA, at the inception of the Social Security program, all 

SSNs were assigned and cards issued based solely on information 

provided by the applicant. In 1971, SSA began requiring evidence of 

identity from individuals age 55 and over who were applying for an 

original number and Social Security card. From the first issuance of the 

Social Security number and card until evidence of identity was first 

required, SSA issued over 194 million SSNs and cards. SSA first required 

that noncitizens show evidence of age, identity, and status in 1974, by 

which time SSA had issued another 26 million original SSNs and cards. In

Page 18 GAO-06-303 Social Security Administration
his testimony, the SSA Deputy Commissioner stated that in 1974, the 

agency began to annotate its records to show the issuance of SSNs to 

noncitizens for nonwork purposes because the agency was concerned that

individuals might use SSNs assigned for purposes other than work to 

obtain unauthorized employment. Beginning in 1978, SSA required all SSN 

applicants to provide evidence of age, identity, and United States 

citizenship or noncitizen status, by which time SSA had issued about 253 

million original SSNs and cards. In 1982 SSA began printing the legend, 

“NOT VALID For Employment,” on the cards of noncitizens not authorized 

to work. 

To reduce the instances of fraudulent activity associated with documents 

used in the employment verification process, both SSA and Homeland 

Security offer employers voluntary electronic verification of information 

on the Social Security card and immigration documents. However, in 

August 2005, GAO reported several weaknesses in the current employment 

verification process.10 The wide array of documents permitted leaves the

employment verification process vulnerable to fraud. Various studies show 

that document fraud (use of counterfeit documents) and identity fraud 

(fraudulent use of valid documents or information belonging to others) 

have made it difficult for employers to accurately verify individuals’ 

eligibility to work. In its 1997 report to Congress, the U.S. Commission on

Immigration Reform noted that the widespread availability of false 

documents made it easy for unauthorized workers to obtain jobs in the 

United States. Prior GAO work shows that the problems with document 

and identity fraud undermine the employment verification process. For 

example, in 1999 we reported that large numbers of unauthorized workers 

either fraudulently used valid documents that belong to others or 

presented counterfeit documents as evidence of employment eligibility.11

In 2004, we reported that unauthorized workers were able to use false 

documents to illegally gain entry to secure areas of critical infrastructure 

sites, such as airports, nuclear power plants, and military bases. To 

improve the employment verification process, DHS reported it is 

considering reducing the number of acceptable documents permitted to 

verify employment eligibility. 

 10GAO-05-813. 

11GAO, Illegal Aliens: Significant Obstacles to Reducing Unauthorized Alien Employment 

Exist, GAO/GGD-99-33 (Washington, D.C.: Apr. 2, 1999). 

Page 19 GAO-06-303 Social Security Administration
DHS has made worksite enforcement a relatively low priority, given the 

other immigration enforcement programs that compete for DHS resources. 

Since the terrorist attacks of September 11, 2001, DHS has focused its 

investigative resources on national security, and worksite enforcement has 

focused on identifying and removing unauthorized workers from critical 

infrastructure sites such as airports and nuclear power plants. However, 

fraudulent use of SSNs among immigrants remains a problem. In 

September 2005, the SSA Inspector General reported that some 

nonimmigrants may remain in the United States and continue working 

without DHS authorization,12 while others leave the country, and in their 

absence, someone else may use these individuals’ SSNs to obtain 

employment. Using a universe of about 800,000 nonimmigrants that SSA 

enumerated in fiscal year 2000, the Inspector General estimated that about 

32,000 nonimmigrants continued working after their immigration status 

expired or someone else may have used their SSNs to work after they left

the country. 13

DHS has a voluntary “Basic Pilot” program where employers can choose to

verify employment eligibility electronically, but few employers participate, 

and technological flaws hinder the program’s effectiveness. Most of the 

nation’s approximately 5.6 million employer firms rely on visual 

examination of documents individuals present, while about 5,500 

employer firms signed up to participate in Basic Pilot as of March 2006.14

Basic Pilot enables employers to verify Social Security numbers with SSA 

and work authorization and immigration status with DHS. Basic Pilot 

shows promise for detecting document fraud, but if an unauthorized 

worker presents valid documentation that belongs to another person who 

is authorized to work, Basic Pilot may verify the individual as workauthorized. If the use of Basic Pilot expands, some unresolved problems, 

such as delays in data entry and timely verification, will need to be 

resolved. 

 12A nonimmigrant is a foreign-born individual who is granted temporary admission to the 

United States for a specific purpose, such as students and temporary workers. 

13Office of Inspector General, Social Security Administration, Impact of Nonimmigrants 

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

(September 2005). 

14This indicates the number of businesses that have signed memorandums of understanding 

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

Page 20 GAO-06-303 Social Security Administration
Improvements to state drivers’ licenses and identification cards, as a result 

of the Real ID Act, may help the government’s ability to identify 

individuals and establish better links to the Social Security card and 

employment eligibility determinations. The Real ID Act will require that 

the estimated 250 million state drivers’ licenses and identification cards 

have a biometric such as a digital photo; physical security features, such as

a special hologram, to prevent tampering, counterfeiting, or duplication; 

and a common machine-readable technology. Before issuing drivers’ 

licenses and identification cards, states will be required to verify the Social 

Security numbers and legal presence of applicants. While licenses and 

identification cards are meant to prove identification, under the new law 

states are not required to establish employment eligibility and will not be 

checking worker status as they verify the Social Security number with SSA 

and immigration documents with DHS. Beginning 3 years after the date of 

enactment, a federal agency may not accept a state’s driver’s license or 

identification card for any official purpose, unless the state meets certain 

requirements. Table 5 shows the key requirements of the Real ID Act. 

Real ID Act May Improve 

Links to the Card and 

Employment Eligibility 

Determinations, but 

Limitations Exist 

Page 21 GAO-06-303 Social Security Administration
Table 5: Requirements for State-Issued Drivers’ Licenses or ID Cards under the Real ID Act of 2005 

Minimum issuance standards Applicant must present evidence and have verified

• Photo identification or nonphoto identification with full legal name and date of birth on 

the document 

• Date of birth 

• Proof of valid SSN or verification that the person is not eligible for one 

• Address of principal residence

Minimum document information 

standards 

The driver’s license must contain

• Full legal name

• Date of birth 

• Gender 

• Driver’s license or identification number 

• Digital photo of the person 

• Address of principal residence

• Security features meant to prevent counterfeiting, tampering, or duplication 

• Common machine-readable technology with defined data elements 

Evidence of lawful status A state shall require that a person provide valid documentary evidence that the 

person 

• Is a citizen or national of the United States 

• Is an alien lawfully admitted for permanent or temporary residence in the United States 

• Has conditional permanent resident status in the United States 

• Has an approved application for asylum in the United States or has entered into the 

United States in refugee status

• Has a pending application for asylum in the United States 

• Has a pending or approved application for temporary protected status in the United

States 

• Has approved deferred action status 

• Has a pending application for adjustment of status to that of an alien lawfully admitted 

for permanent residence in the United States 

• Has a valid, unexpired nonimmigrant visa or nonimmigrant visa status for entry into the 

United States 

Temporary drivers’ licenses and

identification cards 

Temporary drivers’ licenses and identification cards will only be accepted by

federal agencies if they 

• Are valid only during the time in which the individual is authorized to reside in the 

United States or, if there is no definite end to the period of authorized stay, a period of 

1 year 

• Clearly display that the license has been temporarily issued and plainly display the 

expiration date

• With respect to a temporary driver’s license or temporary identification card, may only 

be renewed upon presentation of valid documentary evidence that the status has been 

extended by the Department of Homeland Security 

Source: Real ID Act. 

Page 22 GAO-06-303 Social Security Administration
A Range of 

Enhancement Options

Exists, and Costs 

Would Vary 

A range of options exists for enhancing the Social Security card, and these 

options provide different levels of counterfeit protection and capacity to 

verify employment eligibility. Options range from adding counterfeitresistant features to the paper card, adding machine-readable features 

such as a magnetic stripe or bar code, and adding biometric features such 

as photographs and fingerprints, to eliminating the card entirely. 

Currently, the cost of providing a card to a cardholder is approximately 

$25, and the cost of some of these options will be higher.15 The total cost of 

enhancing the card will be significantly affected by how many people are 

issued new cards and the time frame for distribution. Options for 

distribution include providing enhanced cards only to new cardholders, 

reissuing cards to all of the 300 million estimated cardholders, or 

staggering issuance by providing cards to new cardholders and to 

individuals who change jobs. The options that we describe below are not

intended to be an all-inclusive listing of options available to enhance the 

security of the card, but provide a framework of approaches for doing so.

Options for Enhancing 

Cards 

There are a wide range of features that could be added to the current 

paper card to make it more counterfeit-resistant. According to

Government Printing Office officials and other industry experts, these 

features could include such improvements as printing a hidden image that

appears when the card is tilted to the light, changing the paper content of 

the card to include fiber that reacts to certain chemicals, and

incorporating various security features currently used on currency, such

as a security thread in the paper. Government Printing Office officials and

industry experts report that these are relatively inexpensive changes that

would help protect the card by rendering obsolete many of the counterfeit

techniques currently used. Adopting these types of changes to the current

card would be the least disruptive to SSA operations and to cardholders. 

Adding secure features to the 

paper card 

Adding machine--readable features such as a magnetic stripe or secure bar 

code feature could offer some measure of security of the card, though 

some experts question the value of this option. Machine--readable 

technology varies in the amount and type of information that can be 

Adding machine--readable 

features 

 15Based on fiscal year 2004 data. 

Page 23 GAO-06-303 Social Security Administration
included on the card. For example, a card with a magnetic stripe similar to 

those on credit and debit cards may contain the information currently 

displayed on the Social Security card plus the individual’s work status. A 

secure bar code can also store identifying information such as a 

photograph or fingerprint. Much like the process to verify credit cards, 

machine-readable technology combines the security of counterfeitresistant features on the card with features that can be read and verified 

by an external device. Employers and SSA would rely on machines to read 

the cards, thus adding another step to assess the cards’ validity and 

protect the cards from counterfeiting. See figure 2 for a possible SSN card 

showing a magnetic stripe and a secure bar code.

Page 24 GAO-06-303 Social Security Administration
Figure 2: Examples of Possible Social Security Card with Reverse Showing Magnetic Stripe and Secure Bar Code 

Possible SSN card

Magnetic stripe Secure bar code

Source: SSA.

The main change to the card would be the introduction of machinereadable technology. The primary advantage of machine--readable 

technology is that it combines the security of counterfeit-resistant features

with those that can be read by an external device. The use of machinereadable features could be useful as part of DHS’s employment eligibility 

authorization process. Current DHS guidelines state that an employer has 

to review documents provided by new employees to prove their eligibility 

to work and make a reasonable determination as to the validity of 

Page 25 GAO-06-303 Social Security Administration
documents presented. Use of machine-readable features would take the 

burden off employers to make a determination that the card that is 

presented is valid. Due to the large number of documents that can be 

presented, including the many versions of the Social Security card, 

employers are often ill equipped to determine if documents are valid. A 

secure card with machine-readable features could also be used by SSA or

other programs in determining the validity of the card and eligibility for 

benefits. 

Card technology experts have noted that certain machine-readable 

technology offers little protection against counterfeiting. For example, 

magnetic stripe technology is relatively easy to counterfeit with 

inexpensive equipment that is widely available. Other industry experts 

stated that even though the data included in a secure bar code may be 

encrypted, or coded so that the data cannot be read by unauthorized 

persons, the data may still be copied in its encrypted form and included on

a counterfeit card. 

A highly secure card could incorporate biometric security features to 

effectively establish an individual’s identity and backup systems to 

authenticate an individual’s eligibility for benefits or work status. 

Biometric features cover a wide range of technologies that can be used to 

verify a person’s identity by measuring or analyzing his or her 

characteristics. Some widely used and well-known biometric features 

include fingerprints, which uses distinct ridges of the fingertips to 

establish an individual’s identity, and digital pictures, which are commonly 

used in drivers’ licenses. These digital pictures support facial recognition, 

which electronically compares facial features in the digital pictures with 

those of the individual. Biometric cards would be made of plastic or other 

durable material and could incorporate smart card technologies.16 See 

figure 3 for examples of biometrics that might be used on a Social Security 

card’s front or reverse sides depending on the card’s design. 

Adding biometric features 

 16Smart cards are plastic devices about the size of a credit card that use integrated circuit 

chips to store and process data. 

Page 26 GAO-06-303 Social Security Administration
Figure 3: Examples of Biometrics—Fingerprint, Facial Recognition, and Photograph 

Possible SSN card Photograph

Fingerprint

Facial recognition

Source: GAO and SSA.

Page 27 GAO-06-303 Social Security Administration
Biometrics-enhanced cards could be supported by a central SSA database 

to store the biometric information to verify the identity of an individual. 

Storing identifying information on a central system would provide 

additional protection if some of the physical security features used on the 

card are able to be counterfeited. For example, many motor vehicle

administrations maintain central databases to compare stored photos with 

those of individual renewing a driver’s license. The ability to make similar 

verifications to a centralized database could also establish if individuals 

are eligible to work in the United States. The biometric feature could also

be stored only on the card, but some industry experts indicate that data 

stored only on the card are far more vulnerable to fraud than data in a 

centrally located database of identifying information.17 However, experts 

also caution that a centralized database has its own set of security 

concerns, which will require a risk assessment to determine the most costeffective solution for storing biometric data. For example, techniques 

would need to be developed to ensure that biometric information provided

to the centralized database actually represents the individual, and a 

method would need to be implemented to handle the inevitable situations 

where the information in the central database did not agree with 

information provided. Prior GAO work on biometrics outlines the 

strengths and concerns raised with the use of biometric technology.18

An additional consideration in using biometrics on the Social Security card 

is determining when a biometric can first be captured from a cardholder, 

as in the case of fingerprints or a picture or the need to update the 

biometric in the case of a photograph. This may require SSA to issue a 

temporary card through the Enumeration at Birth process and then issue a 

card with a biometric at some other time, such as when the individual 

reaches adulthood or enters the workforce. Depending on the biometric 

selected, such as a digital picture, SSA would also need to reissue the card 

at intervals to update these data. 

A biometric Social Security card could raise general privacy concerns 

about the card becoming a national identification card. A new Social 

Security card with a biometric identifier issued to all number holders 

 17American Association of Motor Vehicle Administrators officials have pointed out that the

combination of a number of security features raises the overall level of security of a card or 

document. 

18GAO, Information Security: Challenges in Using Biometrics, GAO-03-1137T 

(Washington, D.C.: Sept. 9, 2003). 

Page 28 GAO-06-303 Social Security Administration
could create a central database capable of identifying 300 million 

individuals. A system that stores biometrics related to individuals’ identity

may raise concerns about how the government would use and protect the 

data. The Privacy Act of 1974 limits federal agencies’ collection, use, and 

disclosure of personal information, such as fingerprints and photographs. 

While the act includes exemptions for law enforcement and national 

security purposes, representatives of civil liberties groups and privacy 

experts have expressed concerns regarding the adequacy of protections 

for security, data sharing, identity theft, and other identified uses of 

biometric data and the potential intrusiveness of such an approach. 

Additional concerns focus on the ease of using biometrics and their effect

on the ability of the agency to complete its mission. 

Finally, another approach would be to eliminate Social Security cards 

entirely and use other, more secure documents to prove employment 

eligibility. Under a no Social Security card option, each person who is 

assigned an SSN would receive a letter, not a card, with an SSN on it. Like

the current card, the letter would record the number assigned and provide

individuals with a written record of their number. Eliminating the Social 

Security card would mean that the card itself would not be used as 

documentation for obtaining government benefits, and the burden of 

finding a means to secure the card would be removed. Changing from a 

card to a letter would not require that SSA deviate from its current 

issuance process,19 which would save SSA the time, inconvenience, and 

many of the costs associated with issuing an enhanced card. 

Documentation of an individual’s identity could be tied to other 

documents such as a driver’s license and require some link between the 

SSN and drivers’ licenses, which are currently undergoing improvements, 

or other identity documents. 

Eliminating the card 

Factors Affecting the Cost 

of Card Options 

The current cost of issuing an original or replacement Social Security card 

is approximately $25. This includes approximately 4 cents for the 

banknote paper card, and as table 6 shows, to enumerate an applicant,

SSA needs to interview applicants, verify documents such as birth 

 19SSA currently has numerous means of establishing an individual’s identity. These include

verifying the individual’s identity by asking open-ended questions and confirming this

information with information previously provided in SSA’s records. If there are questions

about the individual’s identity, SSA staff may request identification documents, check 

telephone directories, or contact persons or organizations who may know the individual. 

They are not constrained by any single document or question. 

Page 29 GAO-06-303 Social Security Administration
certificates with the agencies that issued them, and determine work 

eligibility status. Including additional features on the card would increase 

the cost of the card. For example, in 1997, SSA reported that the cost of 

the current Social Security card document was 5 cents; a plastic card with 

security features was 12 cents; a plastic card with a picture was 14 cents; 

and a plastic card with a magnetic stripe was 22 cents. According to SSA, 

these costs have likely decreased somewhat since its 1997 estimate. But 

this estimate also showed that processing costs accounted for the bulk of

issuance costs for most options it considered. SSA’s processing costs 

would increase if additional features were included on the card. In 2004,

SSA estimated that the cost of obtaining a number holder’s picture and 

biometric identifier would add 5 minutes, or $3.50, to the cost of issuing a

card. Adding machine-readable or biometric features to the card would 

also require additional equipment in SSA’s approximately 1,300 field 

offices, and employers and other users would also need equipment if they 

were expected to read features on the card. Further, biometric features 

would likely require cardholders to have their biometric information 

updated at periodic intervals—greatly affecting the number of cards 

cardholders would receive in their lifetime and long-term card issuance 

costs. 

Table 6: Factors that Affect Costs of Enhanced Card Options

Card options

Determine 

employment 

eligibilitya

New equipment at

SSA field offices 

New equipment at

job sites 

Periodic updates 

needed from

cardholder at SSA 

field offices 

Unchanged paper card X 

Machine-Readable 

(paper or plastic) 

X X X

Biometric X X X X

No card—letter to notify assigned SSN X 

Source: GAO.

a

This includes interviewing applicants and verifying documents 

Issuance Options Affect 

Cost 

Specific costs for each card option are not yet available. However, issuing

300 million enhanced cards at the current cost of approximately $25 each 

is costly, but maintaining the current method of issuing cards and 

permitting older versions of cards to remain valid would do little to stem 

counterfeiting or help employers determine whether applicants are eligible 

to work. Permitting older versions is cost-effective for SSA, since new 

cards have to be issued only to new applicants and people needing 

Page 30 GAO-06-303 Social Security Administration
replacement cards. About 17 million new and replacement cards are 

issued annually. Table 7 shows three card issuance options, including the 

number of cardholders requiring new cards. 

Table 7: Card Issuance Options

Document used to prove 

employment eligibility 

Issuance options

Cards issued in the 

initial 12 months

Old cards 

valid 

Only new cards 

valid 

Current issuance process 18 millionaX

Mass issuance 300 million X 

Staggered issuance 45 millionbX

Source: GAO analysis of SSA data. 

a

Total rounded to next million. 

b

This figure represents the approximately 34 million people who SSA estimates change jobs annually, 

5.4 million original Social Security cards issued annually, and SSA’s estimate of 6 million individuals

who would request replacement cards under this option. 

While mass reissuance of Social Security cards to all 300 million Social 

Security number holders would ensure a more effective tool for 

establishing employment eligibility, mass issuance could cost billions of 

dollars. Number holders would need to be notified through costly mass 

mailings that they would need to come to an SSA field office with 

appropriate documentation to obtain their new card, and field offices 

would need to be staffed and equipped to verify the identity of the number 

holders and issue the cards. To help ease the strain on SSA field offices 

and resources, costs for a mass issuance could be phased in over several 

years. 

Mass issuance 

Staggering issuance of an enhanced Social Security card to new hires or 

individuals who change jobs could help increase the likelihood that the 

card is a valid document in the worker verification process and help 

reduce the cost of a mass issuance. Under this issuance option, only an 

enhanced card would be permitted for determining employment eligibility. 

As a result, the 34 million workers who change jobs each year would need

to obtain an enhanced card. In addition, SSA issues approximately 

5 million cards to new cardholders annually. Further, SSA has estimated 

that this option would include about half, or 6 million, of the replacement 

cards issued annually. Therefore, staggering issuance to job changers and 

new cardholders would result in a total of about 45 million enhanced cards 

issued during the first year of an enhanced card issuance. 

Staggered issuance 

Page 31 GAO-06-303 Social Security Administration
Congress has long recognized that the Social Security card is vulnerable to

misuse and has considered various approaches to minimizing this 

vulnerability and securing the card against counterfeiting. However, with 

50 valid versions, many of which lack any counterfeit protections, the card 

is difficult to counterfeit-proof completely, making it an element in identity 

theft and benefit program fraud, as well as an ineffective tool in verifying

employment authorization. We recognize that the Intelligence Reform and 

Terrorism Prevention Act does not, specifically, require SSA to establish 

safeguards for the card for the purposes of employment eligibility, but the 

act intends for SSA to establish standards for safeguarding the card from 

fraudulent use. In doing so, SSA is thus far considering card protection 

solely within the context of the Social Security program; the agency is not 

currently planning to address card protection as part of the broader 

question of the card’s role in employment verification or the potential 

impact of other identification advances such as the new state driver’s 

license requirements on the use of the card. 

While DHS is represented on the SSA-led task force to address card 

protection, the task force has been convened late in SSA’s card 

enhancement process, only a few months before SSA must provide for 

implementing new card safeguards. This approach allows little time to 

involve DHS in addressing the scope of critical issues affecting the role of

the card. Yet DHS’s ongoing reevaluation of which documentation 

represents acceptable proof of employment authorization is clearly 

relevant to the card’s role and the types of security elements that might be 

warranted. It is important that the card’s role in the employment eligibility 

documentation process not be overlooked in SSA’s work on 

enhancements. Although consideration of this issue may not be specified 

in law, broader thinking about the card’s use and security could mitigate 

the need to revisit card enhancement issues in the future. 

As the SSA-led task force develops ways to protect the Social Security

card, it is important that the card meets the needs of DHS in the 

employment verification process; therefore, we recommend that 

Conclusions 

Recommendation for 

Executive Action 

• the Secretary of Homeland Security and the Commissioner of Social 

Security work together to resolve the weaknesses of the Social Security

card in proving employment eligibility. Specifically, they should 

consider the millions of cards that do not prove employment eligibility, 

the inability to tie the card to the cardholder, flaws in the voluntary 

employment verification system, improvements to identification cards 

by the Real ID Act, and the current ease of counterfeiting the card. 

Page 32 GAO-06-303 Social Security Administration
The Department of Homeland Security and the Social Security 

Administration provided comments on a draft of this report. Agency Comments 

In its response, DHS agreed that much could be done on an interagency 

basis to improve the integrity of Social Security cards and numbers, as 

required by the Intelligence Reform and Terrorism Prevention Act of 2004. 

In addition, DHS agreed with SSA’s decision to link the role of the card 

with verifying employment eligibility later in the task force’s deliberative 

process. DHS stated that determining what to do to make the card more 

secure, or eliminating the card altogether, appears to be the appropriate 

task at this stage and DHS will continue to work with SSA through the 

interagency task force. DHS’s comments are reprinted in appendix III. 

We also received technical comments, which we incorporated where 

appropriate. 

In SSA’s response to our recommendation, SSA agreed in part, although it

stated that some aspects of the recommendation are outside the scope of

what Congress provided in the Intelligence Act. But otherwise SSA is 

continuing to work with DHS on issues related to employment eligibility 

and verification through the Basic Pilot program. While we assessed SSA’s 

implementation of the Intelligence Act provisions, we also studied the role

of the Social Security card and number in the context of employment 

verification. We recognize that the Intelligence Act does not specifically

state that the task force is to establish safeguards for the card for the 

purposes of employment eligibility. However, the act was broadly written 

and provides sufficient authority to address such issues, given the act’s 

requirement to consult with DHS to form an interagency task force. Our 

work showed major flaws with the Social Security card’s role in the 

employment verification process, which raises concern when SSA did not 

involve DHS early enough in the process to fully consider its input to card

enhancement decisions. That is why we recommended that SSA and DHS 

work together more closely to resolve the weaknesses of the Social 

Security card in proving employment eligibility. 

SSA states that the Intelligence Act requires SSA to have a plan for 

implementation by June 2006 and that the agency is on target to develop a 

plan for implementation by June 2006. While developing a plan for 

implementation is certainly consistent with the Intelligence Act's mandate, 

we do not view the Commissioner's responsibilities under the law to be 

limited solely to developing a plan. Specifically, the Intelligence Act 

requires that “Not later than 18 months after the date of enactment of this 

Act, the task force shall establish, and the Commissioner shall provide for

the implementation of, security requirements, including—standards for 

Page 33 GAO-06-303 Social Security Administration
safeguarding social security cards from counterfeiting, tampering, 

alteration, and theft.” 

SSA further notes that our report has various references to SSA moving 

slowly and is not convening the task force until a time so late in the 

process that successful implementation would be nearly impossible. 

We believe our report accurately characterizes SSA’s actions to date. 

The Intelligence Act requires that SSA consult with DHS and form an 

interagency task force to establish standards to better protect the SSN and 

card. Instead of having the task force direct efforts to establish safeguards

for the SSN and card, SSA studied card enhancement options for nearly 

1 year and made a preliminary decision without task force input. By the 

time SSA convened the task force, the group had less than 6 months to 

study and establish standards for safeguarding the card. 

SSA stated that current law requires that the card be made of banknote 

paper, and as a result, the task force was technically limited to

improvements to the paper card. We believe that SSA and the task force, 

as stewards of the Social Security card, have a responsibility to ensure that 

the most appropriate enhancements to the card are considered. Although 

the law requires that the card be made of banknote paper, the Intelligence 

Act does not prohibit SSA or the task force from recommending legislative 

changes to better prevent tampering, alteration, and counterfeiting. 

SSA characterized the report as having an overarching theme that suggests

the use of an enhanced card would address weaknesses in employment 

eligibility and enforcement, which SSA cites as beyond the scope of its 

mission and more in line with DHS’s primary missions. SSA states that 

attempting to make the card meet a purpose for which it was not crafted 

would deflect valuable resources from the Social Security program. 

According to SSA, the report should make the point that a new, more 

secure card tailored to proving employment eligibility would do little good 

if not accompanied by other significant changes in the workplace 

enforcement arena. SSA stated that to expend considerable resources to 

develop a card to confirm employment eligibility that is used by a few 

employers would seem an injudicious use of government resources. We

agree that these are critical issues to consider. 

SSA also noted that because the Real ID Act requires states to use a DHS 

verification system for noncitizens, it would be an easy next step to reflect 

work authorization on drivers’ licenses if Congress wanted to do so. We 

believe that SSA’s suggestion for modifications to the Real ID Act 

requirements for drivers’ licenses and identification cards is important to 

the broader discussion on safeguards and represents yet another example 

Page 34 GAO-06-303 Social Security Administration
of a critical issue that DHS and SSA should consider in the deliberation on

card enhancements. SSA states that our claim that SSA is not planning to 

address card protection as part of employment verification or the potential 

impact of changes required by the Real ID Act to drivers’ licenses is not 

true. SSA stated that it is working with DHS and the American Association 

of Motor Vehicle Administrators on matters of joint interest. We are 

encouraged by SSA’s comments that the agency is working with DHS and 

the American Association of Motor Vehicle Administrators. However, we 

have asked SSA and DHS to provide information on the task force 

initiative but they have not provided the information we requested. 

SSA indicated that it found our report title misleading, stating that the 

majority of the report focuses on one purpose of enhancement—

employment eligibility verification. We disagree; our report title 

accurately reflects the need for SSA to coordinate with DHS in its card 

enhancement efforts and our recommendation that the agencies do so. 

Besides employment eligibility, our report describes SSA’s efforts to 

implement the Intelligence Act and outlines options for enhancing the 

Social Security card. 

Finally, because our report is concerned with counterfeiting, SSA stated 

that it would be prudent to protect its content by limiting distribution. We 

disagree. While our report describes examples involving counterfeit cards, 

the information in our report is readily available publicly in prior reports 

published by SSA and, most recently, in a November 2005 testimony by an 

SSA official before the House Committee on Ways and Means, 

Subcommittee on Social Security. However, we have made changes to 

some language in the report to address SSA’s concerns. SSA’s comments 

are reprinted in appendix IV. SSA also provided technical comments, 

which we incorporated where appropriate. 

 

We are sending copies of this report to the Secretary of Homeland Security 

and the Commissioner of the Social Security Administration and other 

interested parties. Copies will also be made available to others upon 

request. In addition, the report will be available at no charge on GAO’s 

Web site at http://www.gao.gov

Page 35 GAO-06-303 Social Security Administration
Please contact me at (202) 512-7215 or bovbjergb@gao.gov if you or your 

staff have any questions about this report. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff that made major contributions to this report 

are listed in appendix V.

Sincerely yours, 

Barbara D. Bovbjerg 

Director, Education, Workforce, 

 and Income Security Issues 

Page 36 GAO-06-303 Social Security Administration
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

The Chairman of the of the House Committee on the Judiciary asked us to 

review the Social Security Administration’s (SSA) efforts to implement 

provisions of the Intelligence Reform and Terrorism Prevention Act of 

2004 for safeguarding the Social Security number (SSN) and enhancing the 

Social Security card. The Chairman also asked that we identify key issues 

to be considered before enhancing the Social Security card and that we 

outline the range of options available to SSA for enhancing Social Security 

cards. 

To address the Chairman’s request, we met with officials from SSA 

headquarters in Baltimore, Maryland, to review the agency’s progress in 

implementing provisions of the Intelligence Act. We reviewed key 

initiatives planned and undertaken to strengthen SSA’s enumeration 

processes and SSA’s plans for enhancing the Social Security card. We also 

reviewed SSA’s schedule for implementing the card enhancement 

provision of the act and documented SSA’s progress in meeting other 

provisions contained in the legislation. In order to gain an understanding 

of the policies, procedures, and issues related to the current employment 

verification process, we met with officials from the Department of 

Homeland Security (DHS) in Washington, D.C. We discussed the current 

Form I-9 procedures and the role of employers in reviewing employment 

eligibility documents, as well as DHS’s Basic Pilot system used to 

determine the employment eligibility of certain prospective employees. 

To identify key issues to be considered before enhancing the Social 

Security card, we consulted the GAO body of work on the integrity of the 

SSN, our work on immigration enforcement and problems reported in the 

employment verification process, and work the SSA Office of the 

Inspector General and selected law enforcement agencies had performed 

in these areas. We contacted law enforcement officials involved in an 

alleged document fraud case in Montgomery County, Maryland. We 

examined concerns raised regarding the integrity of the SSN and card with

respect to counterfeiting, and reported document and identity fraud with 

the requirements of the employment verification process. We also 

reviewed SSA documents including agency testimonies before Congress 

and the 1997 SSA report entitled Social Security Administration: Report

To Congress On Options for Enhancing the Social Security Card to 

document flaws in the card and its ability to serve as proof of employment 

eligibility. We studied the new federal legislative requirements for states’ 

drivers’ licenses and identification cards included in the Real ID Act. We 

contacted DHS, the American Association of Motor Vehicle Administrators 

in Arlington, Virginia, and state motor vehicle administrations in Chicago, 

Illinois; Charleston, West Virginia; and Cheyenne, Wyoming, to discuss 

Page 37 GAO-06-303 Social Security Administration
Appendix I: Scope and Methodology 

security features used in drivers’ licenses and the implication of changes 

to drivers’ licenses as a result of the Real ID Act. We selected these three 

states because they used various security features in their driver’s 

licensing or identification processes such as fingerprinting, advanced 

optical printing and inks, or holograms and other features, which already 

meet stated or anticipated requirements of the Real ID Act. 

To identify the range of options available to SSA for enhancing the card, 

we researched and analyzed technical literature and identified various 

technology experts and industry associations. We held discussions with 

technology experts in the metropolitan Washington, D.C., area at the 

National Institute of Standards and Technology, International Biometrics 

Industry Association, AC Technology, Mitretek Systems, and the Smart 

Card Alliance to discuss the range of card options and available security 

features, their feasibility for use on the Social Security card, and privacy 

and other concerns. Through these discussions we developed a framework 

of options available to enhance the security of the card. 

Because the current legislation governing the Social Security card requires

that the card be made of banknote paper, we also obtained information on 

card improvements suitable to a paper format. We met with officials from 

the Government Printing Office, in Washington, D.C., who administer the 

contract for printing Social Security cards and Banknote Corporation of 

America in Browns Summit, North Carolina, the contractor that prints 

Social Security cards, to discuss advances in security printing techniques. 

We reviewed identification initiatives using biometrics at the United States

Visitor and Immigrant Status Indicator Technology program and the 

Transportation Security Administration Registered Traveler program in 

DHS in Washington, D.C. Finally, we met with employer association 

groups identified by the U.S. Chamber of Commerce in Washington, D.C., 

to discuss the impact of potential changes to the Social Security card on 

the business community. 

We performed our work between April 2005 and January 2006 in 

accordance with generally accepted government auditing standards. 

Page 38 GAO-06-303 Social Security Administration
Appendix II: Department of Homeland Appendix II: Department of Homeland Security Form I-9

Security Form I-9 

Page 39 GAO-06-303 Social Security Administration
Appendix II: Department of Homeland 

Security Form I-9

Page 40 GAO-06-303 Social Security Administration
Appendix II: Department of Homeland 

Security Form I-9

Note: While DHS has removed the Certificate of United States Citizenship and Certification of Naturalization as acceptable List A 

documents that establish both identity and employment eligibility, it has not updated the Form I-9.

Page 41 GAO-06-303 Social Security Administration
Appendix III: Comments from the Department Appendix III: Comments from the of Homeland Security

Department of Homeland Security 

Page 42 GAO-06-303 Social Security Administration
Appendix III: Comments from the Department 

of Homeland Security

Page 43 GAO-06-303 Social Security Administration
Appendix IV: Comments from the Social Appendix IV Security Administration : Comments from the Social 

Security Administration 

Page 44 GAO-06-303 Social Security Administration
Appendix IV: Comments from the Social 

Security Administration 

Page 45 GAO-06-303 Social Security Administration
Appendix IV: Comments from the Social 

Security Administration 

Page 46 GAO-06-303 Social Security Administration
Appendix IV: Comments from the Social 

Security Administration 

Page 47 GAO-06-303 Social Security Administration
Appendix IV: Comments from the Social 

Security Administration 

Page 48 GAO-06-303 Social Security Administration
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 49 GAO-06-303

Appendix V: GAO Contact and Staff 

Acknowledgments 

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

In addition to the contact named above, Blake Ainsworth, Assistant 

Director; Daniel Bertoni, Assistant Director; Jacqueline Harpp; 

Jeff Bernstein; Jeremie Greer; Roger Thomas; and Tovah Rom made key 

contributions to this report. 

Staff 

Acknowledgments 

Social Security Administration
Related GAO Products Related GAO Products 

Immigration Enforcement: Weaknesses Hinder Employment 

Verification and Worksite Enforcement Efforts. GAO-05-813. Washington, 

D.C.: August 31, 2005. 

Aviation Security: Transportation Security Administration Did Not 

Fully Disclose Uses of Personal Information during Secure Flight 

Program Testing in Initial Privacy Notices, but Has Recently Taken 

Steps to More Fully Inform the Public. GAO-05-864R. Washington, D.C.: 

July 22, 2005.

Immigration Enforcement: Preliminary Observations on Employment 

Verification and Worksite Enforcement Efforts. GAO-05-822T. 

Washington, D.C.: June 21, 2005. 

Social Security: Better Coordination among Federal Agencies Could 

Reduce Unidentified Earnings Reports. GAO-05-154. Washington, D.C.: 

February 4, 2005. 

Social Security Administration: Actions Needed to Strengthen Processes 

for Issuing Social Security Numbers to Children. GAO-05-115. 

Washington, D.C.: January 31, 2005. 

Electronic Government: Federal Agencies Continue to Invest in Smart 

Card Technology. GAO-04-948. Washington, D.C. September 8, 2004. 

Social Security Administration: Actions Taken to Strengthen Procedures

for Issuing Social Security Numbers to Noncitizens, but Some 

Weaknesses Remain. GAO-04-12. Washington, D.C.: October 15, 2003. 

Social Security Numbers: Improved SSN Verification and Exchange of 

States’ Driver Records Would Enhance Identity Verification. GAO-03-920. 

Washington, D.C.: September 15, 2003. 

Electronic Government: Progress in Promoting Adoption of Smart Card 

Technology. GAO-03-144. Washington, D.C.: January 3, 2003. 

Technology Assessment: Using Biometrics for Border Security. 

GAO-03-174. Washington, D.C.: November 15, 2002. 

Social Security Numbers: Government Benefits from SSN Use but Could 

Provide Better Safeguards. GAO-02-352. Washington, D.C.: May 31, 2002. 

Page 50 GAO-06-303 Social Security Administration
Related GAO Products 

Social Security: Government and Commercial Use of the Social Security 

Number Is Widespread. GAO/HEHS-99-28. Washington, D.C.: February 16, 

999. 

Social Security: Mass Issuance of Counterfeit-Resistant Cards 

Expensive, but Alternatives Exist. GAO/HEHS-98-170. Washington, D.C.: 

August 20, 1998. 

Immigration Control: A New Role for the Social Security Card. 

GAO/HRD-88-4. Washington, D.C.: March 16, 1988. 

(130458) Page 51 GAO-06-303 Social Security Administration
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