Report to Congressional Requesters

United States General Accounting Office 

GAO 

September 2003 SOCIAL SECURITY 

NUMBERS 

Improved SSN 

Verification and 

Exchange of States’ 

Driver Records Would 

Enhance Identity 

Verification 

GAO-03-920 
GAO found that 25 states have used either one or both of the methods SSA 

offers for requesting SSN verification. Over the last several years, states 

used the batch and on-line method to submit over 84 million and 13 million 

requests, respectively. Although on-line use has been increasing, usage 

varied significantly among states, with 5 out of 18 states submitting over 70 

percent of all requests. States decide to use SSA’s service based on various 

factors, such as costs and state priorities. 

Weaknesses in SSA’s design and management of its SSN verification service 

have contributed to capacity and performance problems and limited its 

usefulness. While SSA recently increased systems capacity and reduced 

outages, problems remain. For example: 

• The level of service cannot be assessed because SSA has not established 

key performance measures. 

• States are concerned that the high verification failure rate adds to their 

workloads. Several states noted that some of the failures could be 

prevented if SSA disclosed more information to states. 

• States using the batch method are vulnerable to licensing individuals 

using SSNs of deceased persons because SSA does not match requests 

against its death files. In fact, GAO obtained licenses using fraudulent 

documents and deceased persons’ SSNs in 2 states. 

Driver licensing agencies rely primarily on visual inspection of documents 

such as birth certificates, driver licenses, and U.S. immigration documents to 

verify applicants’ identity. While states may use safeguards beyond visual 

inspection to verify documents, they lack the ability to systematically 

exchange identity information on all drivers with other states. Without a 

means to readily share all driver records, states face a greater risk for 

identity theft and fraud in the driver licensing process. A recent Department 

of Transportation report to Congress identified options that would provide 

states a system for exchanging records on all drivers and could help mitigate 

identity fraud. 

Example of Identity Information That Driver License May Contain 

DRIVER'S LICENSE CLASS

BIRTH DATE

NAME

ADDRESS

ADDRESS

RESTR.HEIGHTWEIGHTSEX TYPEDONOR

SP0000 ISSUE DATE

EXPIRES

ENDORS. IDENTIFICATION NO. ?

Source: GAO.

Since September 11, 2001, more 

attention has been focused on the 

importance of identifying people 

who use false identity information 

or documents to obtain a driver 

license. The Social Security 

Administration (SSA) offers states 

a service to verify social security 

numbers (SSNs) collected during 

the driver licensing process. This 

report examines states’ use of 

SSA’s verification service, factors 

that may affect the usefulness of 

the service, and other tools states 

use or need to verify identity. 

GAO recommends that SSA 

develop performance measures to 

assess the quality of its service, 

develop a strategy to decrease the 

verification failure rate, and modify 

its batch method to match requests 

against death records. SSA 

disagreed on developing 

performance measures for this 

purpose but agreed it should 

develop a strategy for improving 

the verification rate and begin 

matching batch requests against 

death records. However, SSA 

stated that limits in law and 

systems priorities could restrict the 

actions it could take. 

Given the homeland security 

implications associated with states’ 

inability to exchange information 

on all drivers, GAO recommends 

that the Congress, in partnership 

with the states, consider 

authorizing the development of a 

national data sharing system. 

www.gao.gov/cgi-bin/getrpt?GAO-03-920. 

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Barbara 

Bovbjerg at (202) 512-7215 or 

bovbjergb@gao.gov. 

Highlights of GAO-03-920, a report to the 

Committee on the Judiciary and the 

Subcommittee on Social Security, 

Committee on Ways and Means, House of 

Representatives 

September 2003

SOCIAL SECURITY NUMBERS 

Improved SSN Verification and Exchange 

of States' Driver Records Would Enhance 

Identity Verification 
Page i GAO-03-920 SSNs and Driver Licensing 

Letter 1

Results in Brief 2

Background 4

Twenty-five States Have Used SSA’s Verification Service 7

Weaknesses in SSA’s Design and Management of the SSN 

Verification Service Has Limited Its Usefulness 11

States May Use Safeguards Beyond Visual Inspection of Identity 

Documents, but Lack a Systematic Means to Share All Driver 

Records 16

Conclusion 22

Matter for Congressional Consideration 23

Recommendations 23

Agency Comments and Our Evaluation 24

Appendix I Scope and Methodology 27 

Appendix II Comments from the Social Security Administration 29 

Appendix III GAO Contacts and Staff Acknowledgments 33 

GAO Contacts 33

Staff Acknowledgments 33

Related GAO Products 34 

Figures 

Figure 1: States Using SSA’s Verification Services through March 

2003 8

Figure 2: SSA’s On-line Transactions, Fiscal Years 1998-2002 9

Figure 3: Distribution of On-line Verification Requests, Fiscal Years 

1998-2002 10

Contents 
Page ii GAO-03-920 SSNs and Driver Licensing 

Abbreviations 

AAMVA American Association of Motor Vehicle Administrators 

CDLIS Commercial Drivers Licensing Information System 

DHS Department of Homeland Security 

DOT Department of Transportation 

NDR National Driver Register 

NHTSA National Highway Traffic Safety Administration 

SSA Social Security Administration 

SSN social security number 

This is a work of the U.S. government and is not subject to copyright protection in the 

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

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

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

reproduce this material separately. 
Page 1 GAO-03-920 SSNs and Driver Licensing 

September 15, 2003 

The Honorable F. James Sensenbrenner, Jr. 

Chairman 

Committee on the Judiciary 

House of Representatives 

The Honorable E. Clay Shaw, Jr. 

Chairman 

Subcommittee on Social Security 

Committee on Ways and Means 

House of Representatives 

The events of September 11, 2001, focused attention on the importance of 

identifying people who use false identity information or documents, 

particularly in the driver licensing process. Driver licenses are a widely 

accepted form of identification that individuals frequently use to obtain 

services or benefits from federal and state agencies, open a bank account, 

request credit, board an airplane, and carry on other important activities of 

daily living. For this reason, driver licensing agencies are points at which 

individuals may attempt to fraudulently obtain a license using a false 

name, social security number (SSN), or other documents such as birth 

certificates to secure this key credential. Accordingly, states face 

increasing pressure to verify the identity information of individuals to 

whom they issue licenses. 

As the agency responsible for issuing SSNs, the Social Security 

Administration (SSA) is uniquely positioned to help states verify the 

identity information provided by applicants. To this end, SSA has a 

verification service in place that allows state driver licensing agencies to 

verify the SSN, name, and date of birth of customers with SSA’s master file 

of SSN owners. States can transmit requests for SSN verification in two 

ways. One is by sending multiple requests together, called the “batch” 

method, to which SSA generally responds within 24 to 48 hours. The other 

way is to send an individual request on-line, to which SSA responds 

immediately. 

To shed light on states’ practices for verifying the identity information of 

driver license applicants, you asked us to examine: (1) the extent to which 

states use SSA’s services to verify the SSNs of driver license applicants, 

(2) factors that may affect the usefulness of SSA’s verification service, and 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-03-920 SSNs and Driver Licensing 

(3) other tools states use or need to verify the identity of driver license 

applicants. To conduct our work, we reviewed federal requirements 

governing SSN use in the driver licensing process, SSA’s policies for 

disclosing information to licensing agencies, information on the operation 

of SSA’s verification service, and national data on states’ use of the 

service. We interviewed key SSA headquarters managers and staff 

responsible for the design and oversight of the verification service, as well 

as American Association of Motor Vehicle Administrators (AAMVA) 

officials responsible for co-managing the on-line verification method with 

SSA.1

 To develop in-depth information on specific states’ identity 

verification practices, we obtained data and interviewed officials from 

California, Florida, Georgia, Maine, Maryland, Massachusetts, Ohio, 

Pennsylvania, and Tennessee. These states represent a range of identity 

verification policies and practices. We also telephoned or visited the states 

that did not use SSA’s service to obtain general information about their 

identity verification policies and practices. Finally, we analyzed SSA and 

state driver licensing agency data to identify instances of potential identity 

fraud involving (1) individuals who used the name and SSN of deceased 

persons and (2) individuals who used fraudulent out-of-state licenses. We 

conducted our work from July 2002 through May 2003 in accordance with 

generally accepted government auditing standards. For additional details 

on our audit approach, see appendix I. 

Twenty-five states have used the batch or on-line method to verify SSNs 

with SSA, and the extent to which they regularly use the service varies. 

About three-fourths of the states that rely on SSA’s verification service 

used the on-line method or a combination of the on-line and batch method, 

while the remaining states used the batch method exclusively. Over the 

last several years, states estimated submitting over 84 million SSN 

verification requests to SSA using the batch method compared with 

13 million requests submitted using the on-line method. States generally 

use the batch method for a short-term period to verify SSNs in their 

existing records, while states are more likely to use the on-line service on 

a continuous basis. States’ use of SSA’s on-line service has increased 

steadily over the last several years. However, the extent of use has varied 

significantly, with 5 states submitting over 70 percent of all on-line 

verification requests and one state submitting about one-third of the total. 

 1

AAMVA is an association that represents motor vehicle administrators in North America 

and is a recognized leader in driver credentialing issues. 

Results in Brief 
Page 3 GAO-03-920 SSNs and Driver Licensing 

States consider various factors in deciding whether to use SSA’s 

verification service. For example, some states that did not use SSA’s 

service told us they were reluctant to do so based on performance 

problems they had heard were encountered by other states, such as 

frequent outages and slowness of the on-line system. States’ use of SSA’s 

service is also driven by internal policies, priorities, and other concerns. 

For example, some states may limit their use to certain targeted 

populations, such as where fraud is suspected or for initial licenses, but 

not for renewals of in-state licenses. 

Weaknesses in SSA’s design and management of its SSN on-line 

verification service have contributed to capacity and performance 

problems. SSA recently took steps to increase system capacity and to give 

more management attention to the service; however, problems remain. In 

designing the service, SSA used an available infrastructure to set up the 

system and encountered capacity problems, which worsened after the 

pilot phase. AAMVA’s data show that, in 1999, the on-line system 

experienced an average of three major outages per month, increasing to an 

average of five per month in 2000. The capacity problems inherent in the 

design of the on-line system have affected states’ use of SSA’s verification 

service. For example, officials in one state told us that they have been 

forced to scale back their use of the system because they were told by SSA 

that their volume of transactions was overloading the system. SSA officials 

acknowledged problems stemming from the design and management of 

the on-line service and have made some necessary improvements. For 

example, in April 2003, SSA completed an upgrade to increase capacity 

and improve response times. SSA has also designated a project manager to 

oversee the day-to-day management of the service. However, at the time of 

our review, SSA still had not established key goals for the level of service 

it will provide to driver licensing agencies. SSA has also not addressed 

problems regarding the high nonmatch rate and some states’ continued 

vulnerability to fraud associated with the use of SSNs of deceased 

individuals by driver license applicants. These issues may affect states’ 

willingness to use the service and may also expose them to a higher risk of 

fraud. Our own investigators were able to obtain licenses in two states 

using a counterfeit out-of-state license and other fraudulent documents 

and the SSNs of deceased persons. 

While states may use safeguards beyond visual inspection to verify 

documents, states lack the ability to systematically exchange identity 

information on all drivers with other states. Driver licensing agencies rely 

primarily on visual inspection of documents such as birth certificates, 

driver licenses, and immigration documents to verify applicants’ identity. 
Page 4 GAO-03-920 SSNs and Driver Licensing 

For example, driver licensing employees look for security features or 

other characteristics that indicate authenticity. States may employ more 

extensive measures to verify identity information. For example, states may 

use independent data sources to corroborate applicants’ identity 

information and computer systems to identify potential instances of 

identity fraud within their respective driver records and to prevent 

licensing when key identity information is questionable. Despite these 

extra measures, however, states remain vulnerable to identity fraud 

because they lack a systematic means to exchange information on all 

drivers. States’ current means to exchange driver information is limited to 

records for commercial drivers and individuals who have lost their driving 

privileges. Our analysis in one state showed that licensing agencies might 

unknowingly accept false out-of-state licenses as valid identity documents. 

However, a joint federal and AAMVA study recently identified options that 

if implemented would provide states an exchange system for all driver 

records and could help mitigate the vulnerabilities that exist across states. 

This report includes recommendations for SSA to improve the 

management of its SSN verification service to make it more useful to 

driver licensing agencies. SSA generally agreed with our findings regarding 

its SSN verification service and commented that recent improvements 

have increased states’ use of the service. SSA also noted that its service 

only confirms individuals’ SSN information and is not a means for 

verifying their identity. In response to our specific recommendations, SSA 

did not agree that it should develop measures for assessing the quality of 

its SSN on-line verification service because the agency did not believe that 

it would result in improved identity authentication. SSA agreed with our 

recommendations that it develop a strategy for improving the nonmatch 

rate and that it modify the batch process to include a match against its 

death records. However, the agency said that factors such as legal 

restrictions and limited systems resources could restrict the actions it can 

take. We are also presenting a matter for congressional consideration that 

the Congress, in partnership with the states, authorize the development of 

a national data sharing system for all driver records. 

Driver licenses have become widely accepted identity documents because 

they generally include features that make them difficult to counterfeit or 

alter and may contain identifying information such as the licensees’ legal 

name, photograph, physical description, and signature. Currently, about 

188 million drivers are licensed in the United States, and states issue an 

Background 
Page 5 GAO-03-920 SSNs and Driver Licensing 

additional 73 million licenses and identification cards each year.2

Individuals can apply to obtain licenses at about 3,800 locations across the 

United States.3

Authority for designing and administering driver licensing programs, as 

well as for verifying the identity information of licensees, lies with 

individual states. Accordingly, driver licensing agencies face the challenge 

of determining whether the identity documents individuals provide (1) are 

authentic and contain information that agrees with the issuing agency’s 

records and (2) actually belong to the person presenting them. To promote 

uniformity among driver licensing programs, AAMVA provides states with 

guidance on documents it recommends as acceptable proof of identity, as 

well as best practices for verifying the documents. Not surprisingly, the 

SSN is key to any verification process because each SSN is unique to its 

owner.4

 In February 2002, we reported that 45 states collect SSN 

information from driver license applicants. 5

 Individuals obtain SSNs by 

applying to SSA and providing evidence of their age, identity, and U.S. 

citizenship or lawful alien status.6

As the agency responsible for assigning SSNs and issuing social security 

cards, SSA provides a service to the states to verify those numbers. SSA 

provides two methods for driver licensing agencies to verify SSNs: batch 

and on-line. States use the batch method to submit an aggregate group of 

SSN requests directly to SSA, and SSA generally responds within 24 to 

48 hours. Those states using the on-line method submit individual SSN 

 2

Identification cards are issued for the sole purpose of identifying the owner and generally 

contain the same information as driver licenses but lack information authorizing the owner 

to drive. Estimates of the number of licenses and identification cards issued annually were 

taken from a 2002 survey conducted by the California Department of Motor Vehicles. 

3

Estimates of the number of licensing sites nationwide were provided by AAMVA. 

4

SSN verification primarily serves to corroborate the identity information submitted by 

driver license applicants. If the identity document contains a photograph or biometric 

information, licensing employees may visually inspect or electronically read these data as 

well as use interviewing techniques to determine if the documents actually belong to the 

individual presenting them. 

5

See U.S. General Accounting Office, Child Support Enforcement: Most States Collect 

Drivers’ SSNs and Use Them to Enforce Child Support, GAO-02-239 (Washington, D.C.: 

Feb. 15, 2002). 

6

All U.S. citizens can be assigned SSNs. SSA will also assign SSNs to noncitizens authorized 

by the Department of Homeland Security to work in the United States and to noncitizens 

legally in the country who have a valid nonwork reason. 
Page 6 GAO-03-920 SSNs and Driver Licensing 

requests and receive immediate “real time” responses from SSA. On-line 

users transmit and receive information to and from SSA through a network 

maintained by AAMVA. SSA charges states a fee to cover its costs 

(basically system processing and personnel) for providing this service. 

Batch users pay $0.0015 per transaction while on-line users are charged 

$0.03 per transaction. For fiscal year 2002, the total billings for batch and 

on-line users were about $39,000 and $193,000, respectively. SSA collects 

payments directly from the batch users, while it bills and collects 

payments from the on-line users through AAMVA. 

SSA followed Privacy Act7

 requirements in deciding what information it 

would disclose to driver licensing agencies. Under its current disclosure 

policy, if the SSN, name, and date of birth submitted to SSA by a driver 

licensing agency match SSA’s records, SSA will verify the match to the 

state driver licensing agency. If one or more elements do not match, SSA 

will inform the agency of the nonmatch but will not disclose further 

information. match only establishes that the information agrees with SSA’s 

records and is not proof that the individual using the SSN is the person to 

whom SSA assigned the number. 

Beyond SSA’s verification service, the federal government plays a role in 

several other key areas of states’ driver licensing programs. For example, 

within the Department of Transportation (DOT), the National Highway 

Traffic Safety Administration (NHTSA) operates the National Driver 

Register (NDR), a national database containing identity information on 

39 million problem drivers that states are required to use when making 

licensing decisions.8

 Also, to remove unsafe commercial drivers from the 

highways, the federal government established the Commercial Drivers 

License Information System (CDLIS), a nationwide database of 11 million 

records that states must use to exchange information on applicants who 

may hold commercial licenses in other states or have driving infractions 

 7

The Privacy Act regulates federal agencies’ collection, use, and disclosure of individuals’ 

personal information and generally prohibits disclosure of such information without the 

individuals’ consent. The act authorizes 12 exceptions under which an agency may disclose 

information. One exception, “routine use,” allows an agency to disclose the information if 

the agency deems the disclosure to be compatible with the purpose for which it collected 

the information, and the agency gives public notice describing the information it plans to 

disclose. SSA offers as many as 14 different verification services, each of which is designed 

for various requesters (e.g., social service agencies, employers, etc.) and may make 

different disclosures as a result of the verification. 

8

Problem drivers are individuals whose driving privileges have been suspended, revoked, or 

canceled for cause or who have been convicted of certain traffic offenses. 
Page 7 GAO-03-920 SSNs and Driver Licensing 

that make them ineligible for licensing.9 DOT, the federal agency charged 

with establishing the CDLIS database, contracts with AAMVA to operate it. 

The federal government also provides grants to help states improve their 

highway safety programs. Furthermore, states’ receipt of federal funds for 

their state child support enforcement programs are contingent on the 

collection of individuals’ SSNs during the driver licensing process. This 

provision enables licensing agencies to assist states in locating and 

obtaining child support payments from noncustodial parents. 

Twenty-five states have used either the batch or on-line verification 

method and the extent to which they regularly use the on-line service 

varies.10 States that used the batch method generally use it for a short 

period then switch to the on-line process exclusively. Although states’ use 

of SSA’s on-line service has increased steadily over the last several years, 

5 states submitted over 70 percent of all on-line verification requests. 

Factors such as cost, system performance, and individual state priorities 

play a role in determining whether states opt to use SSA’s verification 

service and the frequency in which it is used. 

As of March 2003, driver licensing agencies in 25 states have used the 

batch or on-line method to verify SSNs with SSA. States generally use the 

batch method for a short-term period, but states are more likely to use the 

on-line service on a continuous basis. About three-fourths of the states 

that rely on SSA’s verification service used the on-line method or a 

combination of the on-line and batch method, while the remaining states 

used the batch method exclusively. (See fig. 1.) Over the last several years, 

states estimated submitting over 84 million requests to SSA using the 

batch method.11 Similarly, states submitted a total of 13 million requests 

using the on-line method. Two-thirds of these on-line requests were 

submitted in the last 2 fiscal years.12

 9

States issue commercial driver licenses to individuals involved in interstate, intrastate, or 

foreign commerce to operate certain types of vehicles such as large trucks and buses. 

10This report uses the word “states” to refer to the 50 states and the District of Columbia. 

11SSA did not provide the actual number of batch transactions. Batch estimates represent 

data for 1999–2003. 

12On-line verification requests represent data for fiscal years 1998-2002. 

Twenty-five States 

Have Used SSA’s 

Verification Service 

Twenty-five States Have 

Used the Batch or On-line 

Methods 
Page 8 GAO-03-920 SSNs and Driver Licensing 

Figure 1: States Using SSA’s Verification Services through March 2003 

SSA officials told us that the batch method offers advantages in 

circumstances where a real-time verification response is unnecessary. For 

example, some states have used the batch method to “clean-up” SSNs in 

their existing records and address any discrepancies prior to the license 

coming due for renewal at a later date. A number of states that have used 

the batch method in this manner subsequently used the on-line method 

States using SSA's Online Verification Service only (14)

States using SSA's Batch Verification Service only (7)

States using both SSA's Online and Batch Verification Service (4) 

States not using SSA's Verification Service (26) 

Alaska

Source: Social Security Administration.

Arizona

Hawaii

Arkansas

California

Georgia

Illinois Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Michigan

Minnesota

Mississippi

Montana

New 

York

North Carolina

Oklahoma

Oregon

Pennsylvania

Texas

Utah

Vermont

New Hampshire

Massachusetts

Rhode Island

Connecticut

New Jersey

Delaware

Maryland

Washington, D.C.

West

Virginia

Wisconsin

Colorado

New 

Mexico

Alabama

Nevada

South 

Carolina

Florida

Virginia

Tennessee

North 

Dakota

South

Dakota

Nebraska

Wyoming

Washington

Idaho

Ohio

Missouri
Page 9 GAO-03-920 SSNs and Driver Licensing 

exclusively. For example, one state that used the batch method in 2001 to 

verify over 8.3 million existing records has since used the on-line method 

exclusively. SSA officials noted that only one state currently uses the 

batch method on a continuous basis to verify SSNs for all of its customers. 

For states that issue permanent licenses on the spot, the on-line service 

also offers an advantage, namely, the ability to instantly verify the SSN and 

other key information submitted by individuals seeking initial licenses, as 

well as those converting out-of-state licenses. Between fiscal years 

1998 and 2002, the number of states participating in SSA’s on-line service 

grew by about 3 states each year. As shown in figure 2, the volume of online verification requests processed by SSA has also increased significantly 

from 300,000 in fiscal year 1998 to 5.5 million in fiscal year 2002. 

Figure 2: SSA’s On-line Transactions, Fiscal Years 1998-2002 

Although the volume of on-line requests grew between 1998 and 2002, 

usage varied significantly among states and within individual states from 

year to year. As shown in figure 3, 5 states accounted for over 70 percent 

of the total transactions over a 5-year period, and a single state was 

responsible for submitting about one-third of the total transactions. In 

addition, in some states, the use of the on-line service varied from year to 

Extent of States’ Use of 

the On-line Verification 

Method Varied 

Number of verification requests in millions

0

1

FY1998

(4 states)

FY1999

(7 states)

FY2000

(11 states)

FY2001

(15 states)

FY2002

(18 states)

2

3

4

5

6

Source: GAO analysis of SSA data.
Page 10 GAO-03-920 SSNs and Driver Licensing 

year. For example, one state sent in about 250,000 requests in 1 year and 

about half that number the following year. 

Figure 3: Distribution of On-line Verification Requests, Fiscal Years 1998-2002 

Various factors—such as costs, performance problems, and state 

priorities—may affect states’ decisions about whether or not to use SSA’s 

verification service. The nonverifying states we contacted frequently cited 

cost as a reason why they did not use SSA’s verification service. In 

addition to the per-transaction fees that SSA charges, states may incur 

additional costs to set up and use SSA’s service, including the cost for 

computer programming, equipment, staffing, training, and so forth. State 

estimates associated with establishing an on-line SSN verification process 

with SSA varied considerably based on factors such as the system 

modifications they planned to make. For example, one state we contacted 

estimated that it would cost approximately $770,000 to implement the online service. Another state estimated that using the on-line service would 

have a start-up cost of about $230,000. 

Many nonverifying states we contacted expressed a reluctance to use 

SSA’s verification service based on performance problems they had heard 

were encountered by other states. Some states cited concerns about 

frequent outages and slowness of the on-line system. Other states 

mentioned that the extra time to verify and resolve SSN problems could 

States Weigh 

Considerations in Deciding 

to Use SSA’s Verification 

Service 

29%

•

•

13 states

5 states

34.4%

Tennessee

9.6%

Massachusetts

9.1%

Ohio

9.1%

Missouri

8.6%

Arizona

71%

Source: GAO analysis of SSA data.
Page 11 GAO-03-920 SSNs and Driver Licensing 

increase customer waiting times because a driver license would not be 

issued until verification was complete. 

States’ decisions about whether to use SSA’s service, or the extent to 

which to use it, are also driven by internal policies, priorities, and other 

concerns. For example, some of the states we visited have policies 

requiring their driving licensing agencies to verify all customers’ SSNs. 

Officials in one of these states acknowledged that the growing prevalence 

of identity theft and the events of September 11, 2001, directly affected 

their decision to begin using SSA’s service. Conversely, another state we 

visited that had submitted only 51 transactions over a 3-year period told us 

that it was delaying full use of SSA’s service until spring 2003 to coincide 

with the roll-out of its new driver-license issuance system. Finally, we 

found that states may limit their use of the on-line method to certain 

targeted populations. For example, one state reported that its policy was 

to use the on-line method only if fraud was suspected, while another used 

the service only for initial licenses and out-of-state conversions, but not 

for renewals of in-state licenses. 

Weaknesses in the design and management of SSA’s on-line verification 

service have contributed to capacity and performance problems and 

ultimately limited its usefulness. SSA recently took steps to increase 

systems capacity and to give more management attention to the service; 

however, problems remain. In designing the system, SSA used an available 

infrastructure and encountered capacity problems early on. Although the 

problems worsened after the pilot phase, SSA did not monitor or modify 

the system to improve its performance. Beyond system design problems, 

SSA’s day-to-day management of the service has also been problematic. 

This lack of management attention to the service is evidenced by the fact 

that SSA has failed to bill and collect in a timely fashion more than 

$370,000 from AAMVA over the last several years. SSA officials have taken 

some steps to address system capacity problems, but the agency still lacks 

key performance goals for the on-line service. Despite an increased focus 

on daily management and oversight of the service, SSA still has not 

addressed other problem areas such as a high nonmatch rate or states’ 

vulnerability to fraud associated with individuals who use the SSNs of 

deceased individuals to obtain licenses. These issues may affect states’ 

willingness to use the service and expose them to a higher risk of fraud. 

Weaknesses in SSA’s 

Design and 

Management of the 

SSN Verification 

Service Has Limited 

Its Usefulness 
Page 12 GAO-03-920 SSNs and Driver Licensing 

Weaknesses in the design and management of SSA’s on-line system have 

contributed to capacity and performance problems. In designing the 

system, SSA connected its server to AAMVA’s network, to which driver 

licensing agencies across the country were linked.13 SSA connected the 

two systems using a low-speed data communication line. In 1997, SSA 

piloted the on-line service with three states participating. A joint SSA and 

AAMVA evaluation of the pilot estimated that the on-line service could 

verify 43,200 requests in a 12-hour period or 12.5 million per year. It was 

also estimated that states would submit 7.7 million requests in 1998. While 

the system experienced some problems during the pilot—such as slow 

response times and outages—SSA expressed confidence that its system 

would be sufficient to handle all requests. SSA acknowledged that only 

limited capacity testing was done. However, SSA planned to monitor the 

system’s performance as needed to ensure it could meet states’ needs. 

Following the pilot phase, problems worsened as more states began using 

SSA’s service. AAMVA’s data show that in 1999 the system experienced an 

average of three major outages per month, increasing to an average of five 

per month in 2000. More recent AAMVA data showed that from August 

2002 through March 2003, outages continued to occur frequently and 

lasted from about 30 minutes to as long as 1 day. Such outages can affect 

customer service because employees in one state told us that when the 

service is down, they cannot process customers’ transactions. However, 

because SSA did not collect or monitor performance data on response 

times and outages, SSA did not know the magnitude or specifics of the 

problem. 

The capacity problems inherent in the design of the on-line system have 

affected states’ use of SSA’s verification service. Officials in one state told 

us that they have been forced to scale back their use of the system 

because they were told by SSA that the volume of transactions was 

overloading the system. In addition, AAMVA representatives told us that 

because of concerns about performance and reliability, they have not 

allowed new states to use the service since the summer of 2002. At the 

time of our review, 10 states had signed agreements with SSA and were 

waiting to use the on-line system, and 17 states had received funds from 

 13AAMVA’s network serves as the conduit for transmitting verification requests from 

individual state driver licensing agencies to SSA, as well as receiving verification responses 

from SSA and transmitting them to individual states. 

The Design and 

Management of the On-line 

System Contributed to 

Capacity and Performance 

Problems 
Page 13 GAO-03-920 SSNs and Driver Licensing 

DOT for the purpose of verifying SSNs with SSA.14 It is uncertain how 

many of the 17 states will ultimately opt to use SSA’s on-line service. 

However, even if they signed agreements with SSA today, they may not be 

able to use the service until the backlog of waiting states is addressed. 

In addition to design weaknesses, SSA did not sufficiently focus on the 

management of its service. In particular, SSA previously lacked a 

designated person to oversee the day-to-day operations of the service and 

to coordinate with AAMVA on various management issues. As a result, 

AAMVA lacked a focal point within SSA to resolve persistent performance 

problems that arose with the system. AAMVA officials told us they would 

start by calling SSA’s general help desk, as directed by SSA, but would end 

up calling several different components within the agency. This situation 

impeded the timely and effective resolution of problems necessary to meet 

states’ verification needs. SSA’s lack of management attention to the 

service is also evidenced by the fact that the agency failed to timely bill 

and collect fees from AAMVA over the last several years. Each year SSA is 

required to reach agreement with AAMVA on the per transaction cost of its 

service. However, for several years SSA and AAMVA have not done this. 

Under the agreement, SSA is also required to send AAMVA a final billing 

each year based on the number of transactions processed. SSA billed and 

collected payments from AAMVA for the first 2 fiscal years—1997 and 

1998. However, between fiscal years 1999 and 2002, SSA failed to bill and 

collect more than $370,000 it calculated as being due from AAMVA. 

SSA and AAMVA officials have acknowledged problems stemming from 

the design and management of the on-line service and have made some 

necessary improvements. For example, according to SSA, in April 2003 the 

service began using software that AAMVA recently revised to increase the 

volume of transactions states could submit and receive through AAMVA’s 

network. About the same time, SSA completed an upgrade of its data 

communication line and server to enhance its system capacity and 

response time. SSA officials told us these upgrades should reduce outages 

and enhance performance. SSA provided us with information showing that 

in May 2003, 2 states had increased their volume of transmissions and an 

additional 3 states had begun using the service. SSA plans to add 4 new 

states that are currently testing the on-line system. AAMVA estimates that 

 14Included in the 10 states that have signed agreements with SSA and the 17 that received 

DOT funding are 6 batch states. Of the 25 states that received DOT funding, 17 were not 

online users. 
Page 14 GAO-03-920 SSNs and Driver Licensing 

2003 verification requests may increase to 28 million, more than five times 

the number received in 2002. Despite this projection, however, at the time 

of our review, SSA still had not established key goals for the level of 

service it will provide driver licensing agencies. SSA officials told us they 

are currently monitoring the volume of transactions and response times as 

new states are added. However, until SSA establishes key goals, the quality 

and effectiveness of SSA’s on-line service cannot be fully assessed. More 

recently, SSA also designated a project manager responsible for 

overseeing the day-to-day operation of its service, as well as an individual 

responsible for the billing and collection of AAMVA payments. At the time 

of our review, SSA had collected $330,000 from AAMVA for fiscal years 

1999-2002.15 SSA officials told us that they are in the process of updating 

the cost estimates and payments for fiscal year 2003. 

Despite SSA’s recent efforts to focus more management attention on its 

verification service, problems regarding the high nonmatch rate and states’ 

continued vulnerability to fraud associated with the use of SSNs of 

deceased individuals by driver license applicants remain. These problems 

pose a concern for states because of the additional workloads associated 

with resolving discrepancies between SSA and states’ driver records as 

well as the potential for identity theft. SSA’s data over the last 5 years 

show that an average of 11 percent of all transactions submitted by states 

failed to verify with SSA’s records. Some states have experienced 

nonmatch rates as high as 30 percent. In fiscal year 2002, about 

800,000 records failed verification. Generally, about one-half of these 

failed because the name submitted with the SSN did not match the name 

in SSA’s records. Such mismatches may occur, for example, if a person’s 

SSN record lists a maiden name, but the person is applying for a license 

under a married name. The states and AAMVA have voiced their concerns 

to SSA about the need for additional disclosure of information. In a May 

2001 letter to one state, SSA’s Acting Deputy Commissioner specified the 

agency’s disclosure policy for driver licensing agencies and stated that 

SSA closely scrutinizes requests involving SSN use for purposes not 

related to the Social Security program. In doing so, SSA has decided to 

provide its verification service in a limited manner by informing driver 

licensing agencies which data elements match or do not match. 

 15According to AAMVA, in May 2003 it paid SSA the remaining amount owed. 

SSA Has Not Focused on 

Other Key Weaknesses in 

the Service It Provides 

States 
Page 15 GAO-03-920 SSNs and Driver Licensing 

State concerns about the potential workloads associated with resolving 

nonmatch issues may affect their willingness to fully use SSA’s service. 

Officials in one state told us that a planned start up of the on-line service 

may be delayed due to concerns about the high nonmatch rate they have 

experienced using SSA’s batch service. Officials in another state indicated 

that they have not done a batch clean up of their existing databases 

because they are unable to devote the additional funding and staff 

resources to address nonverification issues. SSA officials told us that they 

are aware of states’ concerns and have recently begun discussions to 

address disclosure issues with the states. 

In reviewing SSA’s verification service, we also identified a key weakness 

in the batch method that exposes states to a higher risk of fraud by 

allowing them to inadvertently issue licenses to individuals using the SSNs 

of deceased individuals. Unlike the on-line service, SSA does not match 

batch requests against its death records. As a result, the batch method will 

not identify and prevent the issuance of a license in cases where an SSN of 

a deceased individual is being used. SSA officials told us that they initially 

developed the batch method several years ago, and they did not design the 

system to match SSNs against its death files. However, a death match was 

built into the on-line system. At the time of our review, SSA acknowledged 

that it had not explicitly informed states about the limitation of the batch 

service. 

Our own analysis of 1 month of SSN transactions submitted to SSA by one 

state using the batch method identified at least 44 cases in which 

individuals used the SSN, name, and date of birth of persons listed as 

deceased in SSA’s records to obtain a license or an identification card.16

We forwarded this information to state investigators who quickly 

confirmed that licenses or identification cards had been issued in 41 cases 

and were continuing to investigate the others. To further assess states’ 

vulnerability in this area, our own investigators, working in an undercover 

capacity, were able to obtain licenses in two batch states using a 

counterfeit out-of-state license and other fraudulent documents and the 

SSNs of deceased persons. In both states, driver licensing employees 

accepted the documents we submitted as valid. Our investigators 

completed the transactions in one state and left with the new valid 

 16SSA’s death records may contain inaccuracies because SSA records all reports of death 

but only verifies those involving benefit payments. 
Page 16 GAO-03-920 SSNs and Driver Licensing 

license.17 In the second state, the new permanent license arrived by mail 

within weeks. The ease in which they were able to obtain these licenses 

confirmed states’ vulnerability to accepting fraudulent documents, and for 

those states that use SSA’s batch process, to issuing licenses to individuals 

using SSNs of deceased individuals. SSA officials have told us that the 

agency has not made a decision about whether the current batch system 

will be modified to include a death match. 

Our field work shows that licensing officials in states that use or have used 

the batch process were often unaware that SSA did not match SSNs 

against its death records. As a result, these states lacked information that 

they could have used to make more informed decisions in choosing either 

the batch or on-line method or to seek alternative strategies to avoid 

issuing licenses to individuals using SSNs of deceased persons. Moreover, 

states that have used the batch method in prior years to clean up their 

records and to verify the SSNs of millions of driver license holders, may 

have also unwittingly left themselves open to identity theft and fraud. 

States may use tools beyond visual inspection to verify documents, but 

lack the ability to systematically exchange identity information on all 

drivers with other states. Although driver licensing agencies rely primarily 

on visual inspection of documents to verify applicants’ identity 

information, states may employ more extensive measures such as using 

independent sources to corroborate applicants’ identity information. 

Despite the extra measures, states remain vulnerable to identity fraud 

because they lack a systematic means to exchange information on all 

drivers. As a result, states may unknowingly accept false out-of-state 

licenses as valid identity documents or license individuals who use the 

identity information of others. 

In the states we visited, driver-licensing agencies rely primarily on visual 

inspection to determine the authenticity of documents provided by 

applicants. As proof of identity, applicants must present one or more stateapproved documents that are generally inspected by staff. Applicants may 

present a variety of documents, such as a social security card, a U.S. birth 

 17This state does not use SSA’s batch verification process for initial licenses, but only for 

license renewals. Therefore, the use of the deceased person’s SSN will not be caught when 

the state ultimately verifies it using the batch method. 

States May Use 

Safeguards Beyond 

Visual Inspection of 

Identity Documents, 

but Lack a Systematic 

Means to Share All 

Driver Records 

Visual Inspection of 

Documents Is a Primary 

Practice for Verifying 

Identity 
Page 17 GAO-03-920 SSNs and Driver Licensing 

certificate, a driver license from another state, or passport. For noncitizen 

applicants, staff also review a myriad of passports and U.S. immigration 

documents. In reviewing identity documents, staff look for security 

features such as watermarks and raised seals that are difficult to 

counterfeit and are designed to reveal evidence of tampering. They also 

inspect documents for other indications of authenticity such as signs of 

appropriate aging. If employees are unsure if a particular document is 

authentic or if it actually belongs to the applicant, they may use 

interviewing techniques to ensure that the individual can corroborate key 

information. 

In the states we visited, staff responsible for processing driver license 

applications generally received some training and basic assistance to 

support the visual inspection. For example, all of the states provided 

training to help employees distinguish between authentic and fraudulent 

documents. This generally occurred once or twice a year and was 

sometimes presented as part of a larger training module covering other 

policies and procedures of the agencies. In addition to training, office 

managers and supervisors with more experience in detecting false 

documents were available on site to help with the visual inspection if 

needed. In several states, supervisors and office managers told us that they 

have directly contacted issuing agencies to determine whether documents, 

such as birth certificates, were valid. However, this was not routinely done 

because it can be a time-consuming and labor-intensive process. Nearly 

every state we visited provided staff with some basic tools to help with the 

visual inspection, such as reference manuals describing the security 

features included in various state and federal government issued identity 

documents. Other tools such as black lights and magnifying glasses were 

also commonly available to help staff view the security features embedded 

in certain documents. However, we found that the extent to which staff 

actually used these tools varied. 

Despite the training and other measures to aid visual inspection, these 

approaches are often not enough for employees to make a definitive 

determination of a document’s authenticity. Staff and managers we 

interviewed frequently expressed concern that the variety of valid state 

birth certificates, social security cards, out-of-state licenses and 

immigration documents, made it extremely difficult to catch those that are 
Page 18 GAO-03-920 SSNs and Driver Licensing 

forged, short of them being obvious fakes.18 They also frequently expressed 

a need for better access to automated means of verifying these documents. 

Because of the vulnerabilities associated with the visual inspection of 

documents, states employ more extensive safeguards to better deter and 

detect identity theft and fraud. These include seeking out independent 

third-party data sources to corroborate identity information and 

documents provided by driver license applicants, utilizing computer 

systems to strengthen the integrity of their licensing process, and using 

other innovative tools to better verify applicants’ identity information and 

deter fraud. 

At the time of our review, a number of states we visited were either using 

or pursuing the use of other tools to electronically verify identity 

information with issuing agencies and other independent third parties. 

Officials in several states we visited told us that they wanted access to the 

Department of Homeland Security (DHS)19 immigration information to 

verify the identity documents of noncitizen applicants. Further, a state 

with a large immigrant and noncitizen population had contracted with 

DHS to routinely authenticate immigration documents and other 

information relevant to a person’s citizenship and immigration status.20 A 

second state was in the process of negotiating access to these records. 

Statewide birth and death information was also viewed by state 

administrators as key to the identity verification process. Accordingly, 

several of the states we visited have periodically used electronic queries or 

data matches to access birth or death records. 

Three of the nine states we visited were pilot-testing or considering the 

use of private vendors to strengthen their identity verification and fraud 

detection procedures. These private vendors typically access various 

information sources, including civil and criminal records, credit 

 18SSA has issued 53 versions of the social security card. Those issued before 1983 lack 

counterfeit-resistance and tamper proof security features. When issuing new versions of 

the social security card, SSA allows prior versions to remain valid because issuing new 

cards to all number holders would be costly. U.S. birth certificates, issued by each of the 

50 states and the District of Columbia and in some cases by local government units within 

the state, vary according to the provisions of the issuing government unit. 

19The former Immigration and Naturalization Service has been transferred to DHS. 

20In some states, noncitizens must document that they have a legal presence in the United 

States, as well as proof of their identity, as a condition for receiving a license. 

States Employ Additional 

Safeguards to Verify 

Identity and Prevent Fraud 
Page 19 GAO-03-920 SSNs and Driver Licensing 

information, address information, state driver records, and state birth and 

death data to help driver licensing agencies corroborate information 

provided by applicants and correctly issue licenses. At the time of our 

review, one state was pilot-testing on-line access to a private vendor in a 

limited number of sites. AAMVA officials did not have national data on the 

extent to which other states are using innovative third-party verification 

tools to strengthen the integrity of their licensing procedures. However, 

they generally noted that such practices are not routinely used to 

supplement states’ primary practice of visually inspecting documents. 

Several states we visited made extensive use of computer systems to 

prevent identity theft and fraud. Several states have computer systems 

capable of screening for multiple individuals in their state with the same 

or similar identity information. For example, one state’s computer system 

automatically cross-matches first-time applicants’ personal information 

against existing driver records in the database to search for such 

situations. When states do not have the capability to routinely perform 

such cross-matches, employees may inadvertently issue licenses to 

individuals who may be using the identity information of someone the 

state has previously licensed. 

Some states’ computer systems are designed to prevent the issuance of a 

license in certain high-risk situations. For example, one state’s system 

terminates the processing of a transaction if identity information does not 

verify with SSA, or if staff attempt to by-pass this verification step. Staff 

are also prevented from overriding the system and issuing the license 

unless an authorized person—generally a higher-level official—intervenes. 

Similarly, some states had systems that could prevent issuance of a license 

if an individual’s personal information already existed in the states’ driver 

records, or DHS information failed to verify. Further, in cases where fraud 

is suspected, most states’ systems—although not all—are capable of 

flagging the transaction and automatically transmitting this information to 

other offices within the state to prevent persons from “shopping” sites 

once they were denied at the first location. Officials in one state that 

lacked this protection told us that in cases of suspected fraud, staff relied 

on manual processes such as telephone calls and e-mails to alert other 

offices about suspicious individuals and false documents. 

Finally, to varying degrees, the states we visited have instituted additional 

controls to better address identity theft and fraud issues. Due to concerns 

about the quality and integrity of other state licensing systems, three states 

prohibit or limit the acceptance of out-of-state licenses as a sole or 

primary identity document. Officials from another state told us that they 
Page 20 GAO-03-920 SSNs and Driver Licensing 

would not accept such documents from 20 states that they have 

determined to have less stringent verification processes. A few other 

states have also instituted policies requiring that two employees review or 

sign-off on the authenticity of documents provided by applicants before a 

license can be issued. This separation of responsibilities provides for 

additional scrutiny of documents and may act as a further check against 

employee fraud. Another common practice among several states was to 

copy all identity documents if during the application process, fraud was 

suspected. This provides the licensing agency with key information for 

investigating the individual’s alleged identity. An official in one state told 

us that staff are trained to collect and copy identity documents upfront 

regardless of whether fraud is suspected at the time. 

All nine states we visited also store and transmit information such as 

digital photographs and signatures for verification purposes. Two states 

also captured fingerprints at the time of application, but only one of them 

used biometric technology to electronically verify this identity information 

for individuals renewing licenses. Another safeguard used by two states is 

the issuance of temporary licenses when identity information has not been 

corroborated at the time of application. Such licenses lack photographs 

and security features common to permanent licenses or clearly state that 

they are not valid for identity verification purposes. However, a third 

state’s temporary license looks the same and includes identical 

information as its permanent license. As a result, this license could 

continue to be presented as an identity document by individuals even if 

the circumstances under which it was issued are ultimately determined to 

be fraudulent. 

Despite the additional safeguards taken by some states, licensing agencies 

lack a systematic means to exchange information on all drivers 

nationwide, limiting their ability to deter identity theft and fraud. 

Currently, states have automated access and are required to use the NDR, 

which is a DOT database of 39 million problem drivers. With this system, 

licensing agencies have the ability to simultaneously query all 50 states to 

determine whether an applicant’s name appears in the database. For 

commercial drivers, states obtain information on their licensing, 

identification, and disqualification from the CDLIS database of 11 million 

records. States are required to input driver information into CDLIS and to 

use the system to verify commercial driver record information during the 

licensing process. 

States Lack a Systematic 

Means to Exchange 

Records on All Drivers 
Page 21 GAO-03-920 SSNs and Driver Licensing 

Because the NDR and CDLIS target specific driver populations and do not 

include the records and identity information of the approximately 

188 million drivers operating in the United States, state driver licensing 

agencies lack a single inquiry process to determine whether or not a 

person has ever been issued a license. Numerous officials in the states we 

visited told us that having a more efficient means of electronic interstate 

communications, that included the electronic transfer of identity 

information such as digital photographs and signatures, would improve 

the integrity of their licensing process. Officials in the states we visited 

were particularly concerned about individuals using licenses issued by 

other states as identity documents and their inability to quickly query all 

states’ databases to corroborate key information. As a result, states are 

limited in their ability to determine whether other states’ identity 

documents are authentic or to identify multiple individuals using the same 

personal identifying information in other states. 

Our analysis of one state’s data demonstrates the potential vulnerabilities 

driver licensing agencies currently face when accepting out-of-state 

licenses as proof of identity. We examined data from one state’s internal 

state cross-match of its existing driving records and identified numerous 

instances where the same out-of-state license number had been used by 

multiple individuals with different names and dates of birth to apply for 

and obtain a new license. We forwarded about 100 of these license 

numbers to the alleged issuing state and asked them to provide us with 

key information on the owner of record. We found 96 cases of potential 

identity fraud involving 52 of the driver licenses numbers. For example, 

states reported some license numbers as invalid or as being issued to 

someone other than the persons that had used them. One state reported 

back that the license number we submitted to them was actually a zip 

code, rather than a genuine state-issued license number. Another license 

was reported by the issuing state to be a valid number that had been 

counterfeited and used in several states. 

A July 2001 report to the Congress prepared by DOT in cooperation with 

AAMVA, identified alternatives to improving state data exchanges and 

discussed various options for change.21 The specialized nature of NDR and 

CDLIS does not allow states to verify licenses for all drivers—a means to 

 21U.S. Department of Transportation, NHTSA in conjunction with Federal Motor Carrier 

Safety Administration and American Association of Motor Vehicle Administrators, Report 

to Congress: Evaluation of Driver Licensing Information Programs and Assessment of 

Technologies. (July 2001). 
Page 22 GAO-03-920 SSNs and Driver Licensing 

identify potential identity fraud. However, the report concluded that an 

alternative system encompassing all driver records could operate 

efficiently using existing programs developed for CDLIS and on hardware 

that is currently in use. However, the report also concluded that before 

such a system could be developed, several potential obstacles should be 

addressed. These include agreeing on the use of a unique identifier by 

which to query all state driving records, ensuring that all states participate, 

defining the role of the federal government, and funding the costs of 

developing and converting to an all-driver system. The report also 

acknowledged that state resources for development and implementation 

would be necessary to cover projected costs, which AAMVA has estimated 

to be about $78 million over 3 years. However, the report concluded that, 

once operational, user fees similar to those imposed for CDLIS could be 

levied by states to cover operational expenses. 

The driver license is a key identity document that can be used by 

individuals to obtain a range of public and private services nationwide. 

Accordingly, state driver license agencies face a daunting task in ensuring 

that the identity information of those to whom they issue licenses is 

verified. However, states’ effectiveness in this area is often dependent on 

several factors, including the receipt of timely and accurate identity 

information from SSA, the extent to which they implement additional 

identity verification and fraud detection tools, and their ability to quickly 

and systematically share key driving record information with other state 

licensing systems. Deficiencies in any of these areas may weaken states’ 

efforts to ensure the integrity of their licensing decisions. 

Unfortunately, design and management weaknesses associated with SSA’s 

verification service have limited its effectiveness. States that are unable to 

take full advantage of the service and others that are waiting for the 

opportunity to use it remain vulnerable to identity theft and fraud. SSA’s 

recent efforts to refocus management attention on improving its service 

represents a positive step and may be key to moving more state licensing 

agencies away from processes that rely heavily on fraud-prone visual 

inspections of identity documents, to one in which information such as an 

individual’s SSN, name, and date of birth can be quickly and independently 

corroborated. However, sustained attention to improving its service is 

needed. Furthermore, states that continue to rely primarily or partly on 

SSA’s batch verification service still risk issuing licenses to individuals 

using the SSNs and other identity information of deceased individuals. 

This remains a critical flaw in SSA’s service and states’ efforts to 

strengthen the integrity of the driver license. 

Conclusion 
Page 23 GAO-03-920 SSNs and Driver Licensing 

Since September 11th, more state driver licensing agencies have begun to 

reassess their prior view that driver licenses are simply an authorization to 

operate a motor vehicle and have taken aggressive actions to strengthen 

the integrity of this important identity document. However, licensing 

programs remain state-administered and may vary considerably in the 

tools provided to front-line staff to verify identity information, such as 

access to automated independent third-party data sources. This has 

potentially serious consequences for the numerous public and private 

sector service providers who rely on the driver license as an identity 

document, but may be unaware that not all states’ licenses are equal in 

terms of the integrity of the identifying information included on them. 

Beyond the actions taken by individual states, coordination and data 

sharing is key to addressing many of the factors that allow identity theft 

and fraud to continue in the driver licensing process. No single state has 

overarching authority to require information sharing nationwide, define 

minimum standards for proof of identity, or mandate the development of a 

systematic means for interstate communication. However, cooperative 

efforts between the federal government, the states, and AAMVA have 

identified and facilitated technological options for improving the exchange 

of driver record data among all states. We recognize that potential barriers 

related to system’s design, funding, privacy rights, and states’ willingness 

to use such a tool have yet to be fully resolved. However, given the 

potential economic and national security implications associated with 

identity theft at the point of driver licensing, sustained leadership at the 

federal level could be the catalyst for needed change. 

In light of the homeland security implications associated with states’ 

inability to systematically exchange driver license identity information and 

the need for sustained leadership in this area, the Congress, in partnership 

with the states, should consider authorizing the development of a national 

data sharing system for driver records. 

Considering the significant increase in the number of on-line requests that 

SSA anticipates receiving from states, as well as the weaknesses that we 

identified in SSA’s service that may increase states’ vulnerability to 

identity fraud, we recommend that the Commissioner of Social Security 

take the following actions: 

• Develop performance measures essential to assessing the quality of the 

service provided. 

Matter for 

Congressional 

Consideration 

Recommendations 
Page 24 GAO-03-920 SSNs and Driver Licensing 

• Develop a strategy for improving the nonmatch rate for SSA’s verification 

service. This should include identifying additional information it can 

reasonably and legally disclose to state driver-licensing agencies as well as 

actions states can take to prevent nonmatches. 

• Modify SSA’s batch verification method to include a match against its 

nationwide death records. 

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

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

SSA also provided additional technical comments, which we incorporated 

in the report as appropriate. We also requested that AAMVA officials 

review the technical accuracy of our discussion of AAMVA’s role in the 

SSN verification process, as well as our characterization of states’ identity 

verification and fraud prevention activities. We incorporated AAMVA’s 

comments in the report as appropriate. 

SSA generally agreed with our findings regarding its SSN verification 

service and said that recent improvements have increased states’ use of 

the service. The agency noted that it is continuing to investigate the 

sequence of events surrounding our ability to obtain driver licenses with 

counterfeit documents and the SSNs of deceased individuals. SSA also 

said that its service only offers confirmation that SSNs and other identity 

information provided by driver license applicants are consistent with its 

records and should not be perceived as a means for verifying identity. 

Also, SSA said that any attempts to reduce the nonmatch rate for its 

service by relaxing the match criteria would be inconsistent with the need 

for “tighter match requirements” and increased security in the post 

9/11 era. We agree that SSA’s service does not allow states to definitively 

determine the identity of driver license applicants and have made small 

changes to ensure that our report will not be misinterpreted. However, we 

continue to believe that the verification service, in combination with other 

verification tools used by the states, is key to corroborating the identity 

information presented by driver license applicants. We also are not 

suggesting that SSA compromise the integrity of its verification service in 

order to reduce the nonmatch rate. However, our report shows that about 

half of all verification failures are for name mismatches. Such mismatches 

are thought to commonly occur due to changes in marital status. We 

continue to believe that opportunities exist for SSA to work with the states 

to explore options for addressing this issue and to ultimately improve the 

overall quality of its service. 

Agency Comments 

and Our Evaluation 
Page 25 GAO-03-920 SSNs and Driver Licensing 

In response to our specific recommendations, SSA disagreed that it should 

develop measures for assessing the quality of its SSN on-line verification 

service. Instead, SSA said that it plans to develop a performance baseline 

for enumeration accuracy to measure whether applicants were entitled to 

receive an SSN based on supporting documentation. SSA did not believe 

that developing performance measures specifically for its verification 

service would result in improved identity authentication. However, we 

continue to believe that the verification service, in combination with other 

tools used by the states, is key to corroborating driver license applicants’ 

identity information. As our report notes, performance concerns and 

issues often affected the extent to which states used SSA’s verification 

service, or whether they opted to use the service at all. Thus, some states 

lacked a key tool for corroborating the identity information of driver 

license applicants. We continue to believe that SSA should develop 

measures for its service to monitor and assess systems availability, 

outages, response times and other key aspects of performance. Without 

such measures, SSA lacks a means to identify performance problems and 

take corrective actions when needed. 

SSA agreed with our recommendations that it develop a strategy for 

improving the nonmatch rate for its service and that it modify the batch 

process to include a match against its death records. However, the agency 

said that factors such as legal restrictions on the information it may 

disclose to states and limited systems resources could restrict the actions 

it can take. Indeed, we encourage SSA to work within the existing law to 

develop policies to reduce nonmatches and to better assist states when 

they occur. Also, in view of states’ vulnerability to licensing individuals 

using deceased persons’ SSN information and the volume of batch 

verification requests submitted to SSA by the states, we believe immediate 

action is needed. 

We are sending copies of this report to the Commissioner of SSA 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. If you have any questions concerning this 
Page 26 GAO-03-920 SSNs and Driver Licensing 

report, please call me on (202) 512-7215. The major contributors to this 

report are listed in appendix III. 

Barbara D. Bovbjerg 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Scope and Methodology 

Page 27 GAO-03-920 SSNs and Driver Licensing 

This appendix provides additional details about our analysis of the Social 

Security Administration’s (SSA) verification services and states’ practices 

for verifying the identity of driver license applicants. To attain our 

objectives, we obtained and reviewed various reports related to the issue 

of identity verification from state auditors, SSA’s Office of Inspector 

General, and the American Association of Motor Vehicle Administrators 

(AAMVA). We reviewed federal requirements governing social security 

number (SSN) use in the driver licensing process, SSA’s policies for 

disclosing identity information to licensing agencies, and numerous 

verification agreements between SSA and the states. We analyzed 

nationwide data on states’ use of SSA’s verification service, including the 

volume of records submitted, trends in usage, and the rate at which SSNs 

failed to verify between October 1997 through May 2003.1

 We interviewed 

SSA officials responsible for the SSN verification data with regard to the 

reliability of the data, and determined the data to be sufficiently reliable 

for our reporting purposes. We telephoned or visited states that were not 

using SSA’s service to obtain general information about their identity 

verification practices, as well as their plans for using SSA’s service in the 

future. 

To obtain more specific information on the design and management of 

SSA’s batch and on-line verification service, we interviewed key SSA line 

and management officials as well as AAMVA officials responsible for comanaging the on-line service. We also reviewed an SSA/AAMVA evaluation 

of a pilot of the on-line method. 2

 To determine batch service states’ 

vulnerability to individuals who may use deceased persons’ SSNs to obtain 

a license, we matched approximately 500,000 batch verification requests 

submitted by one state for the month of December 2002 against SSA’s 

Master Death file.3

 We identified 44 instances in which SSA verified an SSN 

submitted by the state that matched an SSN in the death record where the 

death occurred before December 2002. In order to determine whether 

these individuals actually received a license or identity card, we submitted 

 1

“States” for the purposes of this report is defined as the 50 states plus the District of 

Columbia. 

2

Evaluation of the Social Security Number Online Verification System for the American 

Association of Motor Vehicle Administrators, Social Security Administration (Jan. 1998). 

3

These transactions include any transaction where an SSN was collected from an applicant 

(i.e., issuance of licenses, IDs, motor vehicle registration, etc.). SSA maintains a death 

master file containing about 70 million records of persons who have been reported to the 

agency as being deceased. SSA only verifies the deaths of persons if it needs to make 

benefit decisions. The Master Death File for this review was current as of January 31, 2003. 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 28 GAO-03-920 SSNs and Driver Licensing 

the 44 cases to the state licensing agency for its review. The state officials 

confirmed that licenses or identification cards had been issued in 41 cases 

and are currently reviewing the remaining cases. Because we selected a 

judgmental sample of cases to review, our findings are not generalizable to 

the entire state over time or to any other state. 

To gain more in-depth information on specific challenges states may 

encounter in their efforts to verify applicant identity documents, as well as 

their policies and procedures for doing so, we conducted field work in 

California, Florida, Georgia, Maine, Maryland, Massachusetts, Ohio, 

Pennsylvania, and Tennessee. At these locations we interviewed key 

management and line staff and obtained data and documents relative to 

their verification processes and tools. We selected states that were 

geographically dispersed to obtain a mix that (1) did, and did not, issue 

temporary licenses before issuing permanent licenses, and (2) have, and 

have not, used one or both of SSA’s verification services. We also chose 

some states that had large immigrant populations or were identified as 

using innovative practices to verify identity. We also interviewed and 

obtained information from representatives of private businesses that offer 

commercial services to assist driver licensing agencies in verifying identity 

information. 

Finally, to assess states’ vulnerability to accepting fraudulent out-of-state 

driving licenses as an identity document, we used one state’s listing 

representing numerous instances where the same out-of-state license 

number was used multiple times to obtain a license in another state. We 

selected about 100 cases where the name and date of birth of the 

individual were clearly different from one record to the next and 

submitted about 100 of them to the original issuing states. We obtained 

information from the states identifying the name and date of birth of the 

owner of the driver license to determine whether there was possible 

identification fraud. We conducted internal reliability checks for data 

received from state driver licensing agencies. Because we selected a 

judgmental sample of cases to review, our findings are not generalizable. 

We conducted our work from July 2002 through May 2003 in accordance 

with generally accepted government auditing standards. 
Appendix II: Comments from the Social Security Administration 

Page 29 GAO-03-920 SSNs and Driver Licensing 

Appendix II: Comments from the Social 

Security Administration 
Appendix II: Comments from the Social Security Administration 

Page 30 GAO-03-920 SSNs and Driver Licensing 
Appendix II: Comments from the Social Security Administration 

Page 31 GAO-03-920 SSNs and Driver Licensing 
Appendix II: Comments from the Social Security Administration 

Page 32 GAO-03-920 SSNs and Driver Licensing 
Appendix III: GAO Contacts and Staff 

Acknowledgments 

Page 33 GAO-03-920 SSNs and Driver Licensing 

Barbara Bovbjerg, Director, (202) 512-7215 

Daniel Bertoni, Assistant Director, (202) 512-5988 

Jacquelyn Stewart, Analyst-in-Charge, (202) 512-7232 

In addition to those named above, the following team members 

contributed to this report throughout all aspects of its development: Raun 

Lazier, Caterina Pisciotta, and Dorothy Yee. In addition, Daniel Schwimer, 

Mary Dorsey, Shana Wallace, Raymond Wessmiller, and Corrina Nicolaou 

made contributions. 

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 
Related GAO Products 

Page 34 GAO-03-920 SSNs and Driver Licensing 

Social Security Numbers: Ensuring the Integrity of the SSN. GAO-03-

941T. Washington, D.C.: July 10, 2003. 

Social Security Numbers: Government Benefits from SSN Use but Could 

Provide Better Safeguards. GAO-02-352. Washington, D.C.: May 31, 2002. 

Social Security Numbers: SSNs Are Widely Used by Government and 

Could Be Better Protected. GAO-02-691T. Washington, D.C.: April 29, 2002. 

Child Support Enforcement: Most States Collect Drivers’ SSNs and Use 

Them to Enforce Child Support. GAO-02-239. Washington, D.C.: February 

15, 2002. 

Responses to Questions From May 18th Hearing on Uses of Social 

Security Numbers. HEHS/AIMD-00-289R. Washington, D.C.: August 21, 

2000. 

Social Security Numbers: Subcommittee Questions Concerning the Use 

of the Number for Purposes Not Related to Social Security.

HEHS/AIMD-00-253R. Washington, D.C.: July 7, 2000. 

Social Security: Government and Other Uses of the Social Security 

Number are Widespread. GAO/T-HEHS-00-120. Washington, D.C.: May 18, 

2000. 

Social Security: Use of the Social Security Number is Widespread.

GAO/T-HEHS-00-111. Washington, D.C.: May 9, 2000. 

Social Security: Government and Commercial Use of the Social Security 

Number Is Widespread. GAO/HEHS-99-28. Washington, D.C.: February 16, 

1999. 

Related GAO Products 

(130178) 
The General Accounting Office, the audit, evaluation and investigative arm of 

Congress, exists to support Congress in meeting its constitutional responsibilities 

and to help improve the performance and accountability of the federal 

government for the American people. GAO examines the use of public funds; 

evaluates federal programs and policies; and provides analyses, 

recommendations, and other assistance to help Congress make informed 

oversight, policy, and funding decisions. GAO’s commitment to good government 

is reflected in its core values of accountability, integrity, and reliability. 

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

through the Internet. GAO’s Web site (www.gao.gov) contains abstracts and fulltext files of current reports and testimony and an expanding archive of older 

products. The Web site features a search engine to help you locate documents 

using key words and phrases. You can print these documents in their entirety, 

including charts and other graphics. 

Each day, GAO issues a list of newly released reports, testimony, and 

correspondence. GAO posts this list, known as “Today’s Reports,” on its Web site 

daily. The list contains links to the full-text document files. To have GAO e-mail 

this list to you every afternoon, go to www.gao.gov and select “Subscribe to e-mail 

alerts” under the “Order GAO Products” heading. 

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

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

GAO also accepts VISA and Mastercard. Orders for 100 or more copies mailed to a 

single address are discounted 25 percent. Orders should be sent to: 

U.S. General Accounting Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

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

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

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

E-mail: fraudnet@gao.gov

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

Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800 

U.S. General Accounting Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Public Affairs