Testimony 

Before the Subcommittee on Social 

Security, Committee on Ways and Means, 

House of Representatives 

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 1:00 p.m. EST 

Thursday, July 10, 2003 SOCIAL SECURITY 

NUMBERS 

Ensuring the Integrity of the 

SSN 

Statement of Barbara D. Bovbjerg, Director 

Education, Workforce, and Income Security Issues 

GAO-03-941T 
Public and some private sector entities rely extensively on SSNs. We reported 

last year that federal, state and county government agencies rely on the SSN to 

manage records, verify eligibility of benefit applicants, and collect outstanding 

debt. SSNs are also displayed on a number of public record documents that are 

routinely made available to the public. To improve customer service, some state 

and local government entities are considering placing more public records on 

the Internet. In addition, some private sector entities have come to rely on the 

SSN as an identifier, using it and other information to accumulate information 

about individuals. This is particularly true of entities that amass public and 

private data, including SSNs, for resale. Certain laws have helped to restrict the 

use of SSN and other information by these private sector entities to specific 

purposes. However, as a result of the increased use and availability of SSN 

information and other data, more and more personal information is being 

centralized into various corporate and public databases. Because SSNs are often 

the identifier of choice among individuals seeking to create false identities, to 

the extent that personal information is aggregated in public and private sector 

databases it becomes vulnerable to misuse. 

As the agency responsible for issuing SSNs and maintaining the earnings records 

for millions of SSN holders, SSA plays a unique role in helping to prevent the 

proliferation of false identities. Following the events of September 11, 2001, SSA 

formed a task force to address weaknesses in the enumeration process and 

developed major new initiatives to prevent the inappropriate assignment of SSNs 

to non-citizens, who represent the bulk of new SSNs issued by SSA’s 1,333 field 

offices. SSA now requires field staff to verify the identity information and 

immigration status of all non-citizen applicants with the Department of 

Homeland Security (DHS), prior to issuing an SSN. However, other areas remain 

vulnerable and could be targeted by those seeking fraudulent SSNs. These 

include SSA’s process for assigning social security numbers for children under 

age one and issuing replacement social security cards. SSA also provides a 

service to states to verify the SSNs of driver license applicants. Fewer than half 

the states have used SSA’s service and the extent to which they regularly use it 

varies. Factors such as cost, problems with system reliability, and state 

priorities and policies affect states’ use SSA’s service. We also identified a 

weakness in SSA’s verification service that exposes some states to fraud by 

those using the SSNs of deceased persons. 

In 1936, the Social Security 

Administration (SSA) established 

the Social Security Number (SSN) 

to track worker’s earnings for 

social security benefit purposes. 

However, the SSN is also used for a 

myriad of non-Social Security 

purposes. Today, the SSN is used, 

in part, as a verification tool for 

services such as child support 

collection, law enforcement 

enhancements, and issuing credit 

to individuals. Although these uses 

of SSNs are beneficial to the public, 

SSNs are also a key piece of 

information in creating false 

identities. Moreover, the 

aggregation of personal 

information, such as SSNs, in large 

corporate databases, as well as the 

public display of SSNs in various 

public records, may provide 

criminals the opportunity to 

commit identity crimes. SSA, the 

originator of the SSN, is 

responsible for ensuring SSN 

integrity and verifying the 

authenticity of identification 

documents used to obtain SSNs. 

Although Congress has passed a 

number of laws to protect an 

individual’s privacy, the continued 

use and reliance on SSNs by private

and public sector entities and the 

potential for misuse underscores 

the importance of identifying areas 

that can be strengthened. 

Accordingly, this testimony focuses 

on describing (1) public and private 

sector use and display of SSNs, and 

(2) SSA’s role in preventing the 

proliferation of false identities. 

www.gao.gov/cgi-bin/getrpt?GAO-03-941T.

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-03-941T, a report to the 

Subcommittee on Social Security, 

Committee on Ways and Means, House of 

Representatives 

July 10, 2003

SOCIAL SECURITY NUMBERS 

Ensuring the Integrity of the SSN 
Page 1 GAO-03-941T 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss ways to better protect Social 

Security Numbers (SSN) to help prevent the proliferation of false 

identities whether for financial misuse or for assuming an individual’s 

identity. Although the Social Security Administration (SSA) originally 

created SSNs as a means to track worker’s earnings and eligibility for 

Social Security benefits, over time the SSN has come to be used for a 

myriad of purposes. As you know, SSNs are a key piece of information in 

creating false identities. Allegations of SSN misuse include, for example, 

incidents where a criminal uses the SSN of another individual for the 

purpose of fraudulently obtaining credit, acquiring goods, violating 

immigration laws, or fleeing the criminal justice system. 

Although Congress has passed a number of laws to protect the security of 

personal information, the continued use of and reliance on SSNs by 

private and public sector entities and the potential for misuse underscores 

the importance of identifying areas that can be further strengthened. 

Accordingly, you asked us to talk about the uses of SSNs and ways that the 

integrity of the SSN may be preserved. My remarks today will focus on 

describing (1) public and private sector use and display of SSNs and (2) 

SSA’s role in preventing the proliferation of false identities. My testimony 

is based on a report we did for this Subcommittee on government uses of 

the SSN,1

 ongoing work that focuses on private sector SSN uses, and work 

we are completing on SSA’s enumeration process and the agency’s 

verification of SSNs for state driver licensing. 

In summary, public and some private sector entities rely extensively on 

SSNs. We reported last year that federal, state, and county government 

agencies rely extensively on the SSN to manage records, verify eligibility 

of benefit applicants, collect outstanding debt, and conduct research and 

program evaluations. SSNs are also displayed on a number of public 

record documents that are routinely made available to the public. To 

improve customer service, some state and local government entities are 

considering placing more public records on the Internet. In addition, some 

private sector entities have come to rely on the SSN as an identifier, using 

it and other information to accumulate information about individuals. This 

 1

U.S. General Accounting Office, Social Security Numbers: Government Benefits from 

SSN Use but Could Provide Better Safeguards, GAO-02-352 (Washington D.C.: May 31, 

2002). 
Page 2 GAO-03-941T 

is particularly true of entities that amass public and private data, including 

SSNs, for resale. Certain laws have helped to restrict the use of SSNs and 

other information by these private sector entities to specific purposes. 

However, as a result of the increased use and availability of SSN 

information and other data, more and more personal information is being 

centralized into various corporate and public databases. Because SSNs are 

often the identifier of choice among individuals seeking to create false 

identities, to the extent that personal information is aggregated in public 

and private sector databases, it becomes vulnerable to misuse. 

As the agency responsible for issuing SSNs and maintaining the earnings 

records and other personal information for millions of SSN holders, SSA 

plays a unique role in helping to prevent the proliferation of false 

identities. Following the events of September 11, 2001, SSA formed a task 

force to address weaknesses in the enumeration process and developed 

major new initiatives to prevent the inappropriate assignment of SSNs to 

noncitizens, who represent the bulk of new SSNs issued by SSA’s 1,333 

field offices. For example, SSA now requires field staff to independently 

verify the identity information and immigration status of all noncitizen 

applicants with the Department of Homeland Security (DHS), prior to 

issuing an SSN. However, some SSA field staff are relying exclusively on 

the DHS verification system, while neglecting other standard practices for 

visually inspecting documents. SSA’s automated system for assigning SSNs 

also does not prevent the issuance of a SSN if staff by-pass required 

verification steps. Other areas remain vulnerable and could be targeted by 

those seeking fraudulent SSNs. These include SSA’s process for assigning 

SSNs for children under age one and issuing replacement social security 

cards. In addition to its enumeration process, SSA provides a service to 

states to verify the SSNs of individuals seeking driver’s licenses. We found 

that fewer than half the states have used SSA’s service and the extent to 

which they regularly use the service varies widely across states. Factors 

such as cost, problems with system reliability, and state priorities and 

policies determine whether or not states use SSA’s service. We also 

identified a weakness in SSA’s verification service that exposes some 

states to fraud by those who would use the SSN of a deceased individual. 

The Social Security Act of 1935 authorized the SSA to establish a 

recordkeeping system to help manage the Social Security program, and 

resulted in the creation of the SSN. Through a process known as 

“enumeration,” unique numbers are created for every person as a work 

and retirement benefit record for the Social Security program. Today, 

SSNs are generally issued to most U.S. citizens and are also available to 

Background 
Page 3 GAO-03-941T 

noncitizens lawfully admitted to the United States with permission to 

work. Lawfully admitted noncitizens may also qualify for a SSN for 

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

obtain a particular welfare benefit or service. SSA staff collect and verify 

information from such applicants regarding their age, identity, citizenship, 

and immigration status. Most of the agency’s enumeration workload 

involves U.S. citizens who generally receive SSNs via SSA’s birth 

registration process handled by hospitals. However, individuals seeking 

SSNs can also apply in person at any of SSA’s field locations, through the 

mail, or via the Internet. 

The uniqueness and broad applicability of the SSN have made it the 

identifier of choice for government agencies and private businesses, both 

for compliance with federal requirements and for the agencies’ and 

businesses’ own purposes. In addition, the boom in computer technology 

over the past decades has prompted private businesses and government 

agencies to rely on SSNs as a way to accumulate and identify information 

for their databases. As such, SSNs are often the identifier of choice among 

individuals seeking to create false identities. Law enforcement officials 

and others consider the proliferation of false identities to be one of the 

fastest growing crimes today. In 2002, the Federal Trade Commission 

received 380,103 consumer fraud and identity theft complaints, up from 

139,007 in 2000.2

 In 2002, consumers also reported losses from fraud of 

more than $343 million. In addition, identity crime accounts for over 80 

percent of social security number misuse allegations according to the SSA. 

As we reported to you last year, federal, state, and county government 

agencies use SSNs.3

 When these entities administer programs that deliver 

services and benefits to the public, they rely extensively on the SSNs of 

those receiving the benefits and services. Because SSNs are unique 

identifiers and do not change, the numbers provide a convenient and 

efficient means of managing records. They are also particularly useful for 

data sharing and data matching because agencies can use them to check or 

compare their information quickly and accurately with that from other 

agencies. In so doing, these agencies can better ensure that they pay 

benefits or provide services only to eligible individuals and can more 

 2

Identity theft records broken out of consumer fraud totaled per year: 31,117 (2000), 86,198 

(2001), and 161,819 (2002). 

3

GAO-02-352 (Washington D.C.: May 2002). 

Public and Private 

Sector Uses and 

Display of SSNs 
Page 4 GAO-03-941T 

readily recover delinquent debts individuals may owe. In addition to using 

SSNs to deliver services or benefits, agencies also use or share SSNs to 

conduct statistical research and program evaluations. Moreover, most of 

the government departments or agencies we surveyed use SSNs to varying 

extents to perform some of their responsibilities as employers, such as 

paying their employees and providing health and other insurance benefits. 

Many of the government agencies we surveyed in our work last year 

reported maintaining public records that contain SSNs. This is particularly 

true at the state and county level where certain offices such as state 

professional licensing agencies and county recorders’ offices have 

traditionally been repositories for public records that may contain SSNs. 

These records chronicle the various life events and other activities of 

individuals as they interact with the government, such as birth certificates, 

professional licenses, and property title transfers. Generally, state law 

governs whether and under what circumstances these records are made 

available to the public, and they vary from state to state. They may be 

made available for a number of reasons, including the presumption that 

citizens need key information to ensure that government is accountable to 

the people. Certain records maintained by federal, state, and county courts 

are also routinely made available to the public. In principle, these records 

are open to aid in preserving the integrity of the judicial process and to 

enhance public trust and confidence in the judicial process. At the federal 

level, access to court documents generally has its grounding in common 

law and constitutional principles. In some cases, public access is also 

required by statute, as is the case for papers filed in a bankruptcy 

proceeding. As with federal courts, requirements regarding access to state 

and local court records may have a state common law or constitutional 

basis or may be based on state laws. 

Although public records have traditionally been housed in government 

offices and court buildings, to improve customer service, some state and 

local government entities are considering placing more public records on 

the Internet. Because such actions would create new opportunities for 

gathering SSNs from public records on a broad scale, we are beginning 

work for this Subcommittee to examine the extent to which SSNs in public 

records are already accessible via the Internet. 

In our current work, we found that some private sector entities also rely 

extensively on the SSN. Businesses often request an individual’s SSN in 

exchange for goods or services. For example, some businesses use the 

SSN as a key identifier to assess credit risk, track patient care among 

multiple providers, locate bankruptcy assets, and provide background 
Page 5 GAO-03-941T 

checks on new employees. In some cases, businesses require individuals 

to submit their SSNs to comply with federal laws such as the tax code. 

Currently, there is no federal law that generally prohibits businesses from 

requiring a person’s SSN as a condition of providing goods and services. If 

an individual refuses to give his or her SSN to a company or organization, 

they can be refused goods and services unless the SSN is provided. 

To build on previous work we did to determine certain private sector 

entities use of SSNs, we have focused our initial private sector work on 

information resellers and consumer reporting agencies (CRAs).4

 Some of 

these entities have come to rely on the SSN as an identifier to accumulate 

information about individuals, which helps them determine the identity of 

an individual for purposes such as employment screening, credit 

information, and criminal histories. This is particularly true of entities, 

known as information resellers, who amass personal information, 

including SSNs. Information resellers often compile information from 

various public and private sources.5

 These entities provide their products 

and services to a variety of customers, although the larger ones generally 

limit their services to customers that establish accounts with them, such 

as entities like law firms and financial institutions. Other information 

resellers often make their information available through the Internet to 

persons paying a fee to access it. 

CRAs are also large private sector users of SSNs. These entities often rely 

on SSNs, as well as individuals’ names and addresses to build and maintain 

credit histories. Businesses routinely report consumers’ financial 

transactions, such as charges, loans, and credit repayments to CRAs. CRAs 

use SSNs to determine consumers’ identities and ensure that incoming 

consumer account data is matched correctly with information already on 

file. 

Certain laws such as the Fair Credit Reporting Act, the Gramm-LeachBliley Act, and the Driver’s Privacy Protection Act have helped to limit the 

use of personal information, including SSNs, by information resellers and 

 4

U.S. General Accounting Office, Social Security: Government and Commercial Use of the 

Social Security Number is Widespread, GAO/HEHS-99-28 (Washington, D.C.: Feb. 16, 

1999). 

5

The information compiled may include public records of bankruptcy, tax liens, civil 

judgments, criminal histories, deaths, real estate ownership, driving histories, voter 

registration, and professional licenses. Private data sources include information from 

telephone directories and copyrighted publications. 
Page 6 GAO-03-941T 

CRAs. These laws limit the disclosure of information by these entities to 

specific circumstances. In our discussion with some of the larger 

information resellers and CRAs, we were told that they take specific 

actions to adhere to these laws, such as establishing contracts with their 

clients specifying that the information obtained will be used only for 

accepted purposes under the law. 

The extensive public and private sector uses of SSNs and availability of 

public records and other information, especially via the Internet, has 

allowed individuals’ personal information to be aggregated into multiple 

databases or centralized locations. In the course of our work, we have 

identified numerous examples where public and private databases has 

been compromised and personal data, including SSNs, has been stolen. In 

some instances, the display of SSNs in public records and easily accessible 

Web sites provided the opportunity for identity thieves. In other instances, 

databases not readily available to outsiders have had their security 

breached by employees with access to key information. For example, in 

our current work, we identified a case where two individuals obtained the 

names and SSNs of 325 high-ranking U.S. military officers from a public 

Web site, then used those names and identities to apply for instant credit 

at a leading computer company. Although criminals have not accessed all 

public and private databases, such cases illustrate that these databases are 

vulnerable to criminal misuse. 

Because SSA is the issuer and custodian of SSN data, SSA has a unique 

role in helping to prevent the proliferation of false identities. Following the 

events of September 11, 2001, SSA began taking steps to increase 

management attention on enumeration and formed a task force to address 

weaknesses in the enumeration process. As a result of this effort, SSA has 

developed major new initiatives to prevent the inappropriate assignment 

of SSNs to noncitizens. However, our preliminary findings to date 

identified some continued vulnerabilities in the enumeration process, 

including SSA’s process for issuing replacement Social Security cards and 

assigning SSNs to children under age one. SSA is also increasingly called 

upon by states to verify the identity of individuals seeking driver licenses. 

We found that fewer than half the states have used SSA’s service and the 

extent to which they regularly use the service varies widely. Factors such 

as costs, problems with system reliability, and state priorities have 

affected states’ use of SSA’s verification service. We also identified a key 

weakness in the service that exposes some states to inadvertently issuing 

licenses to individuals using the SSNs of deceased individuals. We plan to 

issue reports on these issues in September that will likely contain 

SSA Has a Role in 

Preventing SSNs from 

Being Used to Create 

False Identities but 

Some Areas Remain 

Vulnerable 
Page 7 GAO-03-941T 

recommendations to improve SSA’s enumeration process and its SSN 

verification service. 

SSA has increased document verifications and developed new initiatives to 

prevent the inappropriate assignment of SSNs to noncitizens who 

represent the bulk of all initial SSNs issued by SSA’s 1,333 field offices. 

Despite SSA’s progress, some weaknesses remain. SSA has increased 

document verifications by requiring independent verification of the 

documents and immigration status of all noncitizen applicants with the 

issuing agency—namely DHS and the Department of State (State 

Department) prior to issuing the SSN. However, many field office staff we 

interviewed are relying heavily on DHS’s verification service, while 

neglecting standard, in-house practices for visually inspecting and 

verifying identity documents. We also found that while SSA has made 

improvements to its automated system for assigning SSNs, the system is 

not designed to prevent the issuance of a SSN if field staff by-pass 

essential verification steps. SSA also has begun requiring foreign students 

to show proof of their full-time enrollment, and a number of field office 

staff told us they may verify this information if the documentation appears 

suspect. However, SSA does not require this verification step, nor does the 

agency have access to a systematic means to independently verify 

students’ status. Consequently, SSNs for noncitizen students may still be 

improperly issued. 

SSA has also undertaken other new initiatives to shift the burden of 

processing noncitizen applications from its field offices. SSA recently 

piloted a specialized center in Brooklyn, New York, which focuses 

exclusively on enumeration and utilizes the expertise of DHS document 

examiners and SSA Office of Inspector General’s (OIG) investigators. 

However, the future of this pilot project and DHS’ participation has not yet 

been determined. Meanwhile, in late 2002, SSA began a phased 

implementation of a long-term process to issue SSNs to noncitizens at the 

point of entry into the United States, called “Enumeration at Entry” (EAE). 

EAE offers the advantage of using State Department and DHS expertise to 

authenticate information provided by applicants for subsequent 

transmission to SSA who then issues the SSN. Currently, EAE is limited to 

immigrants age 18 and older who have the option of applying for a SSN at 

one of the 127 State Department posts worldwide that issue immigrant 

visas. SSA has experienced problems with obtaining clean records from 

both the State Department and DHS, but plans to continue expanding the 

program over time to include other noncitizen groups, such as students 

SSA’s Enumeration 

Process Helps Prevent the 

Proliferation of False 

Identities, but Additional 

Actions are Needed to 

Safeguard the Issuance of 

SSNs 
Page 8 GAO-03-941T 

and temporary visitors. SSA also intends to evaluate the initial phase of 

EAE in conjunction with the State Department and DHS. 

While SSA has embarked on these new initiatives, it has not tightened 

controls in two key areas of its enumeration process that could be 

exploited by individuals seeking fraudulent SSNs. One area is the 

assignment of SSNs to children under age one. Prior work by SSA’s 

Inspector General identified the assignment of SSNs to children as an area 

prone to fraud because SSA did not independently verify the authenticity 

of various state birth certificates. Despite the training and guidance 

provided to field office employees, the OIG found that the quality of many 

counterfeit documents was often too good to detect simply by visual 

inspection. Last year, SSA revised its policies to require that field staff 

obtain independent third party verification of the birth records for U.S. 

born individuals age one and older from the state or local bureau of vital 

statistics prior to issuing a SSN card.6

 However, SSA left in place its policy 

for children under age one and continues to require only a visual 

inspection of documents, such as birth records. 

SSA’s policies relating to enumerating children under age one expose the 

agency to fraud. During our fieldwork, we found an example of a 

noncitizen who submitted a counterfeit birth certificate in support of a 

SSN application for a fictitious U.S. born child under age one. In this case, 

the SSA field office employee identified the counterfeit state birth 

certificate by comparing it with an authentic one. However, SSA staff 

acknowledged that if a counterfeit out-of-state birth certificate had been 

used, SSA would likely have issued the SSN because of staff unfamiliarity 

with the specific features of the numerous state birth certificates. Further, 

we were able to prove the ease with which individuals can obtain SSNs by 

exploiting SSA’s current processes. Working in an undercover capacity our 

investigators were able to obtain two SSNs. By posing as parents of 

newborns, they obtained the first SSN by applying in person at a SSA field 

office using a counterfeit birth certificate and baptismal certificate. Using 

 6

Most U.S. born individuals receive a SSN through a process SSA refers to as Enumerationat-Birth (EAB). Under EAB parents can apply for a SSN for their newborn child at the 

hospital as part of the birth registration process. Under this process hospitals send birth 

registration information to a state or local bureau of vital statistics where it is put into a 

database. SSA accepts the data captured during the birth registration process as evidence 

of age, identity, and citizenship, and assigns the child a SSN without further parental 

involvement. The appropriate bureau of vital statistics forwards SSA the required 

information, usually by electronic means. Once SSA receives the required information, it 

performs edits, assigns the SSN, and issues the card. 
Page 9 GAO-03-941T 

similar documents, a second SSN was obtained by our investigators who 

submitted all material via the mail. In both cases, SSA staff verified our 

counterfeit documents as being valid. SSA officials told us that they are reevaluating their policy for enumerating children under age one. However, 

they noted that parents often need a SSN for their child soon after birth for 

various reasons, such as for income tax purposes. They acknowledge that 

a challenge facing the agency is to strike a better balance between serving 

the needs of the public and ensuring SSN integrity. 

In addition to the assignment of SSNs to children under the age of one, 

SSA’s policy for replacing Social Security cards also increases the 

potential for misuse of SSNs. SSA’s policy allows individuals to obtain up 

to 52 replacement cards per year. Of the 18 million cards issued by SSA in 

fiscal year 2002, 12.4 million, or 69 percent, were replacement cards. More 

than 1 million of these cards were issued to noncitizens. While SSA 

requires noncitizens applying for a replacement card to provide the same 

identity and immigration information as if they were applying for an 

original SSN, SSA’s evidence requirements for citizens are much less 

stringent. Citizens applying for a replacement card need not prove their 

citizenship; they may use as proof of identity such documents as a driver’s 

license, passport, employee identification card, school identification card, 

church membership or confirmation record, life insurance policy, or 

health insurance card. The ability to obtain numerous replacement SSN 

cards with less documentation creates a condition for requestors to obtain 

SSNs for a wide range of illicit uses, including selling them to noncitizens. 

These cards can be sold to individuals seeking to hide or create a new 

identity, perhaps for the purpose of some illicit activity. SSA told us the 

agency is considering limiting the number of replacement cards with 

certain exceptions such as for name changes, administrative errors, and 

hardships. However, they cautioned that while support exists for this 

change within the agency, some advocacy groups oppose such a limit. 

Field staff we interviewed told us that despite their reservations regarding 

individuals seeking excessive numbers of replacement cards, they were 

required under SSA policy to issue the cards. Many of the field office staff 

and managers we spoke to acknowledged that the current policy weakens 

the integrity of SSA’s enumeration process. 
Page 10 GAO-03-941T 

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, SSN, or other documents such as birth certificates to secure this 

key credential. 

Given that most states collect SSNs during the licensing process, 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 

reports it generally responds within 48 hours. The other way is to send an 

individual request on-line, to which SSA responds immediately. 

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

with SSA and the extent to which they use the service on a regular basis 

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, batch states estimated submitting over 84 

million batch requests to SSA compared to 13 million requests submitted 

by on-line users. 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. 

Various factors, such as costs, problems with system reliability, and state 

priorities affect states’ decisions regarding use of 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. Moreover, 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 driver licensing agencies to verify all customers’ 

SSNs. Other states may limit their use of the on-line method to certain 

SSA’s Verification of Driver 

License Applicants Helps 

Prevent Fraudulent 

Documents, but 

Vulnerabilities Still Exist 
Page 11 GAO-03-941T 

targeted populations, such as where fraud is suspected or for initial 

licenses, but not for renewals of in-state licenses. The nonverifying states 

we contacted expressed 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 increase customer waiting times because 

a driver license would not be issued until verification was complete. 

Indeed, weaknesses in SSA’s design and management of its SSN on-line 

verification services have limited its usefulness and contributed to 

capacity and performance problems. SSA used an available infrastructure 

to set up the system and encountered capacity problems that continued 

and worsened after the pilot phase. The capacity problems inherent in the 

design of the on-line system have affected state 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 their 

volume of transactions were overloading the system. In addition, because 

of issues related to performance and reliability, no new states have used 

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 the Department of 

Transportation for the purpose of verifying SSNs with SSA. 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. 

More recently, SSA has made some necessary improvements to increase 

system capacity and to refocus its attention to the day-to-day management 

of the service. However, at the time of our review, the agency still has not 

established goals for the level of service it will provide to driver licensing 

agencies. 

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

expose some states to issuing licenses to applicants using the personal 

information of deceased individuals. Unlike the on-line service, SSA does 

not match batch requests against its nationwide death records. As a result, 

the batch method will not identify and prevent the issuance of a license in 

cases where an SSN name and date of birth 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, in developing the on-line system for 

state driver licensing agencies, a death match was built into the new 
Page 12 GAO-03-941T 

process. 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 one 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.7

 We 

forwarded this information to state investigators who quickly confirmed 

that licenses and 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 

transaction in one state and left with a new valid license.8

 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 the vulnerability 

of states currently using the batch method as a means of SSN verification. 

Moreover, states that have used the batch method in prior years to clean 

up their records and verify the SSNs of millions of driver license holders, 

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

The use of SSNs by both public and private sector entities is likely to 

continue given that it is used as the key identifier by most of these entities 

and there is currently no other widely accepted alternative. To help 

control such use, certain laws have helped to safeguard such personal 

information, including SSNs, by limiting disclosure of such information to 

specific purposes. To the extent that personal information is aggregated in 

public and private sector databases, it becomes vulnerable to misuse. In 

addition, to the extent that public record information becomes more 

available in an electronic format, it becomes more vulnerable to misuse. 

The ease of access the Internet affords could encourage individuals to 

engage in information gathering from public records on a broader scale 

 7

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

but only verifies those involving benefit payments. 

8

This 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 by the 

system when the state ultimately verifies it using the batch method. 

Conclusions 
Page 13 GAO-03-941T 

than they could before when they had to visit a physical location and 

request or search for information on a case-by-case basis. 

SSA has made substantial progress in protecting the integrity of the SSN 

by requiring that the immigration and work status of every non-citizen 

applicant be verified before an SSN is issued. However, without further 

system improvements and assurance that field offices will comply fully 

with the new policies and procedures this effort may be less effective than 

it could be. Further, as SSA closes off many avenues of unauthorized 

access to SSNs, perpetrators of fraud will likely shift their strategies to 

less protected areas. In particular, SSA’s policies for enumerating children 

and providing unlimited numbers of replacement cards may well invite 

such activity, unless they too are modified. 

State driver license agencies face a daunting task in ensuring that the 

identity information of those to whom they issues licenses is verified. 

States’ effectiveness verifying individuals’ identities is often dependent on 

several factors, including the receipt of timely and accurate identity 

information from SSA. 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 

crimes. In addition, 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. 

GAO is preparing to publish reports covering the work I have summarized 

within the next several months, which will include recommendations 

aimed at ensuring the integrity of the SSN. We look forward to continuing 

to work with this Subcommittee on these important issues. I would be 

happy to respond to any questions you or other members of the 

Subcommittee may have. 

For further information regarding this testimony, please contact Barbara 

D. Bovbjerg, Director, or Dan Bertoni, Assistant Director, Education, 

Workforce, and Income Security at (202) 512-7215. Individuals making key 

contributions to this testimony include, Andrew O’Connell, John Cooney, 

Tamara Cross, Paul DeSaulniers, Patrick DiBattista, Jason Holsclaw, 

George Ogilvie, George Scott, Jacquelyn Stewart, Robyn Stewart, and Tony 

Wysocki. 

Contacts and 

Acknowledgments 

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