SOCIAL SECURITY 

ADMINISTRATION

Observations on Use 

and Costs of 

Social Security Cards

Statement of Elizabeth H. Curda, Director, Education, 

Workforce, and Income Security

Testimony 

Before the Subcommittee on Social 

Security, Committee on Ways and 

Means, U.S. House of Representatives

For Release on Delivery 

Expected at 10 a.m. EDT

Thursday, May 17, 2018

GAO-18-507T

United States Government Accountability Office
United States Government Accountability Office

Highlights of-GAO-18-507T, a testimony

before the Subcommittee on Social Security, 

Committee on Ways and Means, House of 

Representatives

May 17, 2018

SOCIAL SECURITY ADMINISTRATION

Observations on Use and Costs of Social Security Cards

What GAO Found

GAO identified two federal requirements for individuals to show a Social Security 

card. Based on a search of federal statutes and regulations, GAO did not identify 

any federal statutory requirements for individuals to present their Social Security 

card. GAO identified two federal regulations that require individuals to present 

their card in order to verify their Social Security number (SSN) in certain 

circumstances, such as when updating a service member’s or dependent’s SSN 

information in certain Department of Defense records systems.

Stakeholders we interviewed identified certain situations where, even though not 

required, the card is commonly used to verify identity or an SSN. For example,

officials from an association representing human resource managers said the 

card is one option on a list of acceptable documents that employees can present 

to prove they are eligible to work in the United States. Financial and education 

association officials told GAO that they may, in rare circumstances request the 

card if there is a discrepancy with the SSN provided by the individual.

Representatives from an association of state human services agencies also told

GAO that the card is not required when applying for certain public benefit 

programs, such as the Supplemental Nutrition Assistance Program, although 

applicants may use it as a form of identification.

Organizations who use SSNs said eliminating the paper card would not change 

their current processes. Social Security Administration (SSA) officials and 

stakeholders we interviewed cited some issues to consider for use of cards and 

for alternative approaches, including:

• Identity verification: According to stakeholders, the card can help ensure 

an SSN is recorded accurately. However, they also noted that it is not 

sufficient to verify identity, and stakeholders often require electronic 

verification of SSNs.

• Cost: SSA officials said eliminating the card may result in only limited cost 

savings, if any, and alternatives may create new costs. In fiscal year 2016, 

SSA estimated that the cost to produce a card ranged from $6 to $34, 

depending on the mode by which the card was requested, including staff 

time, technology, printing, and postage. Officials said that printing and 

mailing account for only 60 cents of that cost. In fiscal year 2016, SSA 

officials stated that the agency spent about $8 million on printing and delivery 

of the cards. SSA officials said they have not developed cost estimates for an 

alternative system because the law requires SSA to issue cards.

• Other factors: Stakeholders also said there are other issues to consider in 

developing electronic approaches, including privacy, cost, and the effect on

vulnerable populations, such as individuals with limited access to computers. 

Several government entities, including the Department of Homeland Security

(DHS) and foreign governments, have begun to use electronic methods rather 

than cards to authenticate individual identities. For example, one electronic 

method allows users to print a copy of a document that contains identity 

information, if needed, although the document is maintained in an electronic 

system.

View GAO-18-507T. For more information, 

contact Elizabeth Curda at (202) 512-7215 or 

curdae@gao.gov. 

Why GAO Did This Study

SSA has issued about 500 million 

SSNs and cards since the first design 

of the SSN and card in 1936. SSA 

provides a card to each individual 

when it issues an SSN, as required by 

law, and also issues replacement 

cards upon request. Concerns about 

costs and identity security in an 

increasingly paperless society have 

raised the question of whether a paper 

SSN card is still needed. GAO was 

asked to examine the use of the card.

This testimony focuses on (1) federal 

requirements for individuals to present

an SSN card; 2) stakeholder views on 

the purposes for which the cards are 

used; and (3) potential implications of 

eliminating SSN cards and developing 

alternative approaches.

GAO reviewed federal laws and 

regulations; reviewed SSA fiscal year 

2016 data on card costs (the most 

recent year available); conducted a 

literature search to identify paperless 

identification alternatives; and 

interviewed SSA officials, as well as 

federal, state, and private sector 

stakeholders that may need and are 

legally authorized to collect an SSN.

Stakeholders included associations 

representing state agencies, financial 

institutions, and human resource 

managers.

What GAO Recommends

GAO is not making any 

recommendations. DHS and SSA 

provided technical comments, which 

we incorporated as appropriate.
Page 1 GAO-18-507T Social Security Administration

Chairman Johnson, Ranking Member Larson, Members of the 

Committee:

Thank you for the opportunity to discuss our work on the use of Social 

Security cards. The Social Security Administration (SSA) has issued 

about 500 million Social Security numbers (SSN) and cards since the first 

design of the SSN and card in 1936. SSA provides a counterfeit-resistant 

paper card to each individual when it issues an SSN, as required by law, 

and it also issues replacement cards upon request.1 SSNs have become 

a central means for establishing and confirming identity, but also can be 

used to perpetrate identity theft. Aside from concerns about the use and 

security of the SSN itself, there is interest in the cost of producing a paper 

Social Security card and whether the card enhances SSN security or 

adds to its risk.

Issues regarding identity security and cost in an increasingly paperless 

society have raised the question of whether a paper Social Security card 

is still needed. My remarks today are based on work requested by this 

committee. For this statement, we examined (1) the federal requirements 

for individuals to present their Social Security card; (2) stakeholder views 

on the purposes for which the cards are generally used; and (3) the 

potential implications of eliminating the cards, and developing alternative 

approaches.

For the first objective, we searched federal laws and regulations to 

identify what requirements exist for an individual to present his or her

Social Security card. For the second objective, we interviewed federal, 

state, and private sector stakeholders that may need, and are legally 

authorized, to collect an SSN, in order to learn when a paper Social 

Security card may be requested or required by policy or practice. 

Stakeholders included associations representing financial and higher 

education institutions, human resource managers, and state agencies, 

such as those that administer certain human services programs. For the 

third objective, we reviewed SSA data on actual costs for producing and 

mailing Social Security cards, as well as its estimates of the per-card cost 

for issuing Social Security cards in fiscal year 2016 (the most recent year 

available). We assessed the reliability of SSA’s actual cost data and 

estimated per card cost data by reviewing existing information about the 

data and the systems that produced them, and interviewing agency 

 1 See 42 U.S.C. § 405(c)(2)(G). 
Page 2 GAO-18-507T Social Security Administration

officials knowledgeable about them. We determined that these data were 

sufficiently reliability for the purposes of this testimony. We conducted a 

literature search to identify paperless identification alternatives in use or 

being developed by government, both in the United States and abroad.

We interviewed SSA officials regarding the production and mailing of 

Social Security cards. We also asked SSA officials and stakeholders 

about possible effects of eliminating the card.

We conducted the work on which this statement is based from October 

2017 to May 2018 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions.

In 1936, following the enactment of the Social Security Act of 1935, the 

newly-created Social Security Board (which later became SSA) created 

the 9-digit SSN to uniquely identify and determine Social Security benefit 

entitlement levels for U.S. workers. SSA uses a process known as 

“enumeration” to create and assign unique SSNs for every eligible person 

as part of their work and retirement benefit record.

Originally, the SSN was never intended to serve as a personal identifier 

outside of SSA’s programs, but, due to its universality and uniqueness, 

government agencies and private sector entities increasingly used the 

SSN as a convenient means of identifying people. The expansion of 

government use of the SSN began with Executive Order 9397, issued by 

President Franklin D. Roosevelt in 1943. This required all federal 

agencies to use the SSN exclusively to identify individuals in their 

systems.2 Since Executive Order 9397 was issued, additional federal 

statutes have authorized or required the collection or use of SSNs for a 

 2 In 2008, Executive Order 13478 amended Executive Order 9397 to rescind the 

requirement for federal agencies to use SSNs exclusively. 

Background
Page 3 GAO-18-507T Social Security Administration

wide variety of government activities.3 Appendix I lists examples of such 

statutes.

At the inception of the program, all SSNs and cards were issued based 

solely on information provided by the applicant. However, in the 1970s, 

SSA began requiring proof of age, identity, and citizenship. According to 

SSA, the agency has instituted numerous evidentiary requirements to 

further safeguard and preserve the integrity of the SSN and to ensure 

issuance of SSNs and cards only to eligible individuals.

SSA reported that 16.4 million Social Security cards were issued in fiscal 

year 2017. This total includes 5.8 million new cards issued when 

someone is enumerated—issued an SSN—either at birth, upon entering 

the United States, or becoming a permanent resident. SSA issued 10.6 

million replacement cards, many through their Internet SSN replacement 

card (iSSNRC) system, which allows people to order replacement cards 

online. By law, SSA generally must limit the number of replacement cards 

an individual may receive to 3 per year and 10 in a lifetime, beginning 

with cards issued on or after December 17, 2005.4

SSA issues three types of Social Security cards:

• One shows a person’s name and SSN, and lets someone work 

without restriction; it is issued to U.S. citizens and people lawfully 

admitted to the United States on a permanent basis.

• A second also shows a person’s name and SSN, with a note saying 

“Valid for work only with DHS authorization.” It is issued to people 

lawfully admitted into the United States on a temporary basis who 

have Department of Homeland Security (DHS) authorization to work.

• The third has a person’s name and SSN, and the note “Not valid for 

employment.” SSA issues it to people from other countries who are 

lawfully admitted to the United States without work authorization from 

DHS, but have a valid non-work reason for needing an SSN.

 3 In recent years, there have been efforts to reduce the use and display of SSNs in 

government programs. For example, in April 2018, the Centers for Medicare and Medicaid

Services began issuing Medicare cards that use new unique numbers in place of 

cardholder SSNs.

4 See Intelligence Reform and Terrorism Prevention Act of 2004, Pub. L. No. 108-458, 

§ 7213(a), 118 Stat. 3638, 3831.
Page 4 GAO-18-507T Social Security Administration

While the design of original and replacement cards has been the same 

since 1976, SSA changed the design many times in prior decades. 

Counterfeit protections were first put on the card in 1983, but older 

versions of the card remain in circulation and are valid. As a result of the 

Intelligence Reform and Terrorism Prevention Act of 2004, SSA reported 

that it implemented additional security features in 2007 based on 

recommendations by an interagency task force. In the past, Congress 

and SSA have considered enhanced cards that were more resistant to 

tampering and counterfeiting. Prior GAO work found several limitations 

regarding the security of the Social Security card.5 First, expertise of 

counterfeiters and the wide availability of state-of-the-art technology make 

it increasingly difficult to develop and maintain a document that cannot be 

counterfeited. In addition, while the employment verification process relies 

on a variety of documents to establish identity, the role of the Social 

Security card in proving authorization to work has limitations, in part 

because SSA did not begin requiring identification documents from all 

persons until 1978. Prior work also found that improvements to state 

drivers’ licenses and identification cards, as a result of the REAL ID Act of 

2005,6 may enhance the government’s ability to identify individuals and 

establish better links to the Social Security card and employment eligibility 

determinations.

 5 GAO, Social Security Administration: Improved Agency Coordination Needed for Social 

Security Card Enhancement Efforts, GAO-06-303 (Washington, D.C., Mar. 29, 2006).

6 See Pub. L. No. 109-13, Div. B, 119 Stat. 302. The REAL ID Act sets minimum security 

standards for driver’s license issuance and production, including procedures for states to 

follow when verifying the identity of license applicants, and prohibits Federal agencies 

from accepting for certain purposes driver’s licenses not meeting these minimum 

standards.
Page 5 GAO-18-507T Social Security Administration

We did not identify any federal statutory requirements for individuals to

present their paper Social Security card. However, we identified two

federal regulations that call for individuals to present their Social Security 

card in order to verify their SSN in certain circumstances (see table 1). 

We also spoke with officials at SSA, and they said they were unaware of 

any federal requirements to present the paper card.

GAO Identified Two

Federal 

Requirements for 

Individuals to Present 

Their Social Security 

Card, and These 

Requirements Involve 

Verifying an 

Individual’s Social 

Security Number
Page 6 GAO-18-507T Social Security Administration

Table 1: Federal Requirements for Presentation of a Paper Social Security Card

Federal Provision Social Security Card Requirement

32 C.F.R. § 161.23(l) Department of Defense regulations require members of the uniformed services and their dependents 

seeking to change their SSN in the Defense Enrollment Eligibility Reporting System (DEERS) to 

provide certain documentation, including Social Security cards establishing the individual’s old and 

new SSN.

34 C.F.R. § 681.51(b)a Department of Education regulations regarding the Health Education Assistance Loan (HEAL) 

Program require schools to verify the information provided by students in their HEAL application,

including, but not limited to, the student’s citizenship status and SSN. To comply with this 

requirement, the school may request the student provide documentation required by the school, 

including a paper Social Security card.

Source: GAO review of the U.S. Code and Code of Federal Regulations. | GAO-18-507T

Note: We used a legal database and appropriate search terms to conduct a search in the U.S. Code 

and the Code of Federal Regulations for provisions that require individuals to present their own paper 

Social Security card and provisions that authorize an entity to require individuals to present their 

paper Social Security card. Consistent with the purpose of our search, we excluded any provisions 

we identified that mention a Social Security card but do not require an individual to present his or her 

own card. See 42 U.S.C. § 675(5)(I) and 25 C.F.R. § 20.506(h). In addition, we determined that 

provisions that allow individuals to present their Social Security card to verify their identity or SSN, but 

do not require them to do so, were outside the scope of this objective, and therefore did not include 

them in this table. For example, we identified two provisions that require individuals to present their 

Social Security card if they have it available; however, these provisions do not describe the 

circumstances that would make a card unavailable, and they allow individuals to provide other 

documentation or take other steps instead of providing the card. See 6 C.F.R. § 37.11(e) and 26 

C.F.R. § 31.6011(b)-2. We did not interview relevant agency officials about the agency requirements 

we identified, nor did we attempt to identify and review related agency guidance or other 

documentation.

a

The making of new HEAL Program loans was discontinued on September 30, 1998. See 42 U.S.C. 

§ 292a(a). However, the reporting, notification, and recordkeeping associated with refinancing HEAL 

loans, servicing outstanding loans, and administering and monitoring of the HEAL Program 

regulations continues. In 2014, the HEAL Program and the authority to administer it were transferred 

from the Department of Health and Human Services (HHS) to the Department of Education. See Pub. 

L. No. 113-76, § 525, 128 Stat. 5, 413. Regulations promulgated by HHS in 1992 contain the same 

language as the Department of Education regulations. See 42 C.F.R. § 60.51(b). However, according 

to the Department of Education, HHS intends to remove the HEAL Program regulations from its 

regulations. See 82 Fed. Reg. 53,374, 53,374 (Nov. 15, 2017).
Page 7 GAO-18-507T Social Security Administration

In addition to the two requirements described above, stakeholders 

described instances where individuals may present a Social Security 

card, among other acceptable forms of documentation, in order to verify 

identity or their SSN.

The Social Security card is the most commonly used document to verify 

employment eligibility, according to officials from an association that 

represents human resource managers we interviewed. The Immigration 

Reform and Control Act of 1986 amended the Immigration and Nationality 

Act to require all U.S. employers to complete an employment eligibility 

verification (Form I-9) process to verify a newly-hired employee’s identity

and employment eligibility.7 The card is one of a list of acceptable 

documents that employees may present to prove that they are eligible to 

work in the United States. Other acceptable documents include a U.S. 

passport or permanent residence card. Employers are required by 

regulation to physically examine the documentation that the individual 

presents to verify that the document is genuine and relates to the 

individual.8

According to DHS officials, employers may also use E-Verify, an internetbased employment eligibility system administered by U.S. Citizenship and 

Immigration Services (USCIS), to verify identity and employment 

eligibility. While all U.S. employers must have all newly-hired employees

 7 See Pub.L. 99-603, § 101(a), 100 Stat. 3359, 3360-72 (codified as amended at 8 U.S.C. 

§ 1324a).

8 See 8 C.F.R. § 274a.2(b)(1)(ii)(A).

Stakeholders 

Reported that the 

Social Security Card 

Is One of Several 

Documents that May 

Be Used to Verify 

SSNs

Employers
Page 8 GAO-18-507T Social Security Administration

fill out an I-9 form, E-Verify is optional for most employers.9 E-Verify 

electronically compares information the employer enters from the Form I9 to SSA and DHS records. While use of E-Verify does not require a card, 

according to a USCIS official, about 77 percent of E-Verify cases in the 

last 5 years used SSNs collected from cards presented for the I-9.

According to an official from an association that represents human 

resource managers, employers are required to complete a wage and tax 

statement (W-2) for every employee and provide this information to the

government, in order to transmit earnings records to the employee’s 

Social Security record. IRS guidance states that employers should 

examine the paper card if presented to verify that the SSN is correctly 

recorded on the employee’s W-2. Employees are not required to present 

the card to verify their SSN, but employers may ask for it because they 

can be penalized for providing incorrect information on the W-2. In 

addition, according to this official, new employees have to provide their 

SSN to their employer, such as by providing a card, for enrollment in 

employee health benefits. According to another official, the Patient 

Protection and Affordable Care Act includes a requirement for employers 

to report the number of employees receiving health care, and the SSN of 

each employee and dependent.10

Representatives of financial institution associations said that although 

applicants for new accounts are not required to present a Social Security 

card, presenting the card is one way individuals can prove their identity 

when setting up a new account. Financial institutions may use the paper 

card as one of multiple forms of identification to establish a customer’s 

identity. In addition, pursuant to provisions in the USA PATRIOT Act11

 9 E-Verify is a voluntary program. However, employers with federal contracts or 

subcontracts that contain the Federal Acquisition Regulation E-Verify clause are required 

to enroll in E-Verify as a condition of federal contracting. Employers may also be required 

to participate in E-Verify if their states have legislation mandating its use. According to 

USCIS, employers who wish to employ F-1 OPT foreign students with STEM extensions 

and agricultural employers who would like to immediately employ a new H-2A employee 

already working for another employer as an H-2A in the United States must be enrolled in 

E-Verify. Additionally, according to USCIS, all federal departments and agencies (OMB 

Memo M-07-21) and in the Legislative Branch, each Member of Congress, each officer of 

Congress and the head of each agency of the legislative branch that conducts hiring must 

enroll in E-Verify.

10 See Pub. L. No. 111-148, 124 Stat. 119 (2010).

11 See Pub. L. No. 107-56, § 326, 115 Stat. 272, 317-18 (2001) (codified at 31 U.S.C. 

§ 5318).

Financial Institutions
Page 9 GAO-18-507T Social Security Administration

and the Bank Secrecy Act12 financial institutions are generally required to 

verify certain information when customers open new accounts such as 

date of birth, address, and identification number.13 According to officials

we interviewed from a financial association, the goal of this requirement is 

to prevent money laundering, fraud, and misuse of the banking system. 

Financial institutions may also use other government-issued documents, 

or non-documentary methods (such as by contacting the customer), to 

verify identity. Officials said that a person could still open an account or 

apply for a loan if he or she does not have their card as long as they have 

photo identification and some other government-issued documentation, 

such as a passport.

According to officials representing post-secondary educational 

institutions, students are rarely asked to present a card or even an SSN 

to enroll. Officials told us that the only time a school might request a 

paper card is to resolve discrepancies in a student’s personal information, 

such as when the student’s name and SSN on a financial aid form do not 

match information on other databases.

According to an official representing motor vehicle administrators, the 

REAL ID Act of 2005 requires DMVs to collect and verify the SSN when 

issuing a driver’s license. A person must provide proof of his SSN or proof 

that he is not eligible for an SSN.14 A stakeholder told us the most 

common proof provided for REAL ID purposes is the card, although other 

documents, such as the W-2, can be used.

According to officials from an association that represents state human 

services agencies, while the SSN is required for certain public benefit 

programs such as the Supplemental Nutrition Assistance Program and 

Temporary Assistance for Needy Families programs, states that 

administer these programs do not require the paper card to determine 

 12 See Pub. L. No. 91-508, 84 Stat. 1114-24 (1970) (codified as amended at 31 U.S.C. 

§ 5311 et seq.).

13 An identification number could be an SSN if the person has been issued one, or a 

Taxpayer Identification Number, which is issued by the IRS in the administration of tax 

laws.

14 According to USCIS officials, Form I-9 does not require that the driver’s license be 

REAL ID compliant when completing Form I-9. Official uses are defined as accessing 

federal facilities, entering nuclear power plants, and boarding federally-regulated 

commercial aircraft. Therefore, according to USCIS, driver’s licenses that are not REAL 

ID compliant are acceptable for Form I-9 and E-Verify.

Educational Institutions

State Departments of Motor 

Vehicles (DMVs)

Federal benefits
Page 10 GAO-18-507T Social Security Administration

eligibility. According to these officials, program applicants and recipients 

may provide the card as a source of identification, but the SSN is verified 

through electronic systems. A stakeholder representing state Medicaid 

agencies also told us that the card is not required for Medicaid services 

and requesting one would, in their opinion, be a very unusual practice.

Most of the federal, state, and private sector stakeholders we interviewed 

who have reason to collect SSNs said their current processes would not 

change if the card was eliminated. For example, officials from one 

association we spoke with stated that without the card, individuals could 

continue to use the SSN and verify their identity using other governmentissued documents such as a passport or driver’s license.

Several stakeholders mentioned that a card can help to verify the SSN 

rather than accepting a person’s recollection, which may be incorrect, and 

helps those who may not have committed it to memory. This can help 

ensure the SSN is recorded accurately, which can help avoid fines or 

time-consuming efforts to determine whether an incorrect SSN was 

fraudulent or simply an error. One stakeholder said that in light of recent 

data breaches, it could be helpful to have a physical record to show that 

an SSN was originally linked to the person named on the card. Another 

stakeholder said it can also be helpful for those who may need access to 

accounts of deceased family members.

Stakeholders also raised disadvantages of continued use of the card, 

including that the card itself is not sufficient to authenticate someone’s 

identity. SSA officials acknowledged that the card is not an identity 

Eliminating the Card 

Likely Would Have a 

Limited Effect on 

Stakeholders’

Processes and SSA 

Cost Savings, While 

Paperless 

Alternatives Raise 

Issues to Consider

Most Stakeholders 

Indicated Eliminating 

Cards Would Not Affect 

Processes
Page 11 GAO-18-507T Social Security Administration

document; it is merely a record of the SSN issued to the person whose 

name is shown on the card. Even when someone presents a card, it may 

be difficult to determine whether the card is valid, in part because people 

sometimes laminate the card, which invalidates certain card security 

features. Stakeholders we interviewed said they need electronic 

verification of SSNs even when a person presents a card. SSA services 

allow employers and others to determine whether an SSN matches

information in SSA’s records.15 These efforts help to link the SSN to the 

person presenting the documents. Finally, a card can be lost or stolen, 

which can contribute to disclosure of the SSN and identity theft.16

SSA officials said that eliminating the card may result in only limited cost 

savings, if any. According to SSA officials, the costs of printing and 

mailing the cards are small compared to other costs associated with 

producing the card, and an alternative approach likely would introduce 

new costs that would offset any savings. They said the total cost varies by 

the circumstances of the card request, which can happen by: (1) visiting 

an SSA field office; (2) birth of a newborn; (3) admittance of a lawful 

permanent resident; and (4) using SSA’s internet application for 

replacement cards. In fiscal year 2016, SSA estimated that its cost for 

producing a card requested at a field office was about $34, while the cost 

for one requested online was about $6 (see table 2). According to SSA, 

the agency’s costs vary because SSA field offices handle the SSN 

application, whereas for the other methods, the application information is 

provided by another entity outside SSA.

 15 The Social Security Number Verification Service allows registered employers to quickly 

verify whether a person’s name and SSN match Social Security’s records, without needing 

the Social Security card. This service is used for wage reporting purposes only. The 

Consent-Based SSN Verification Service is typically used by companies that provide 

banking and mortgage services, process credit checks, provide background checks, and 

satisfy licensing requirements. This service does not verify identity, citizenship, or 

employment eligibility. According to SSA, which administers both services, in fiscal year 

2017, these two systems received over 2.1 billion queries to verify SSNs.

16 SSA officials said that the agency has included language in certain SSA publications to 

promote safeguarding the Social Security card and keeping it in a secure place to prevent 

identity theft. See for example, SSA, Understanding the Benefits, Pub. No. 05-10024. 

According to SSA Officials, 

Eliminating the Card May 

Not Result in Cost Savings
Page 12 GAO-18-507T Social Security Administration

Table 2: SSA Fiscal Year 2016 Estimated Total Cost per Social Security Card

Card request method Cost per card Number of cards issued

SSA Field Office $34a 12,212,643

Enumeration at Birth (EAB) $10 4,001,936

Enumeration at Entry (EAE) $6 326,767b

Internet Social Security Number 

Replacement Card (iSSNRC) 

Application

$6 98,967c

Source: SSA data. | GAO-18-507T

a

According to SSA officials, approximately 75 percent of all Social Security cards are requested and 

issued through field offices. The majority of field office requests are for replacement cards. With 

respect to cards issued in response to field office requests, SSA is unable to distinguish between 

original and replacement Social Security cards in estimating its costs.

b The number of cards issued for the Enumeration at Entry program includes both original and 

replacement cards.

c According to SSA officials, in FY 2016, iSSNRC was available in 14 states and the District of 

Columbia. As of FY 2017 it has been rolled out to an additional 10 states.

SSA’s cost estimate of producing a card includes staff time devoted to 

taking and processing the application for the card; information technology 

(IT) support associated with maintaining SSN records; and the actual cost 

of printing, paper, and delivery of the card.17 Agency officials said that the 

main portion of the cost is the staff time to interview applicants and review 

their documentation. Of the $34-per-card estimate for a field office, 

approximately $28 was attributed to operational costs, such as front-line 

personnel who take applications and review documentation, and 

associated management costs. Costs associated with IT systems used 

for enumeration account for another $5 of this total. This amount also 

includes personnel costs for staff who produce cards at SSA facilities. 

Postage, printing and paper costs account for only about 60 cents per 

card. In fiscal year 2016, SSA officials stated that the agency spent about 

$8 million on printing and delivery of Social Security cards.

According to agency officials, SSA is required to create and deliver the 

card, and therefore has not developed a formal proposal or cost estimate 

for eliminating the card or any replacement delivery system. However, the 

agency pointed out that while eliminating the card could reduce some 

costs, such as printing and some personnel costs, it could also create 

 17 SSA estimates operational and systems costs using the agency’s cost allocation 

methodology, while postage, printing and paper costs are actual costs incurred.
Page 13 GAO-18-507T Social Security Administration

costs, depending on what alternative replaced the cards. SSA officials 

noted that current agency systems do not support electronic or paperless 

delivery of SSNs; if this type of alternative was chosen, the officials said 

the agency would have to design, build, and maintain a new system to 

support it. Officials further stated that in addition to cost considerations, 

SSA would need time to develop new processes. Even if no alternative 

replaced the card, the agency would still have to inform people of their 

SSNs—for example, by mailing a letter with the SSN to each person—

which could also create costs. Officials said that any change is likely to 

result in transition costs, such as increased traffic at the SSA field offices 

and phone calls to customer service because people would call with 

questions about the change in policy. 

Several government entities, including federal agencies and foreign 

governments, have begun to use electronic methods, rather than cards, 

to identify and authenticate individuals (see table 3). Although these 

methods apply to systems that are very different in purpose and scale to 

SSNs, they could provide insight into some considerations to moving to a 

paperless system. For example, one of these methods allows users to 

print a copy of the document if needed, although the document is 

maintained in an electronic system. Others capture biometric data, such 

as a fingerprint, upon enrollment that is later used to authenticate identity.

Table 3: Examples of Government-Sponsored Paperless Identity Alternatives

Agency/government entity Purpose of program Description

Department of Homeland 

Security (DHS), Customs and 

Border Protection (CBP), I-94

Immigration/travel CBP issues an I-94 number to certain people legally visiting the United 

States. Previously, the I-94 number was provided on a hard copy form that 

was attached to the person’s passport. Now, for entries at air and sea 

ports, CBP creates an electronic record, and a paper copy can be 

downloaded from a website if needed as proof of legal-visitor status.

DHS, CBP, Global Entry Travel Participants submit an on-line application and complete enrollment with an 

in-person appointment, which includes a background check and 

fingerprinting. When arriving at the airport, participants present a passport 

or permanent resident card and place fingerprints on a scanner for 

verification.

DHS, Transportation Security 

Administration, Pre TM

Travel Participants submit an on-line application and complete enrollment with an 

in-person appointment, which includes a background check and 

fingerprinting. Accepted applicants receive a Known Traveler Number; no 

card is issued. 

State Departments of Motor 

Vehicles (DMV)

Mobile identification Some state departments of motor vehicles are piloting a Mobile Driver’s 

License concept where driving credentials are accessed via an application 

on a smartphone. 

Federal Agencies and 

Others Already Use Some 

Paperless Alternatives to 

Verify Identity, and 

Stakeholders Raised 

Issues to Consider in 

Developing Alternatives
Page 14 GAO-18-507T Social Security Administration

Agency/government entity Purpose of program Description

Austria, Citizen Card Mobile identification Despite its name, the Citizen Card is a virtual, technology-neutral concept 

that can be implemented on a smart phone, smart card or other device. 

The user authenticates his/her identity using their chosen device and a 

secure Personal Identification Number.

Estonia, Mobiil-ID Mobile identification Estonia has created a government-issued, digital identity that allows people 

to use a mobile phone as a form of secure digital ID, which can be used to 

access government services, bank accounts, voting and other secure 

services.

New Zealand, RealMe® Mobile identification Users sign up for a RealMe account online by providing personal 

information such as passport and birth information. A mobile phone is used 

in the verification process. After the user’s identity has been verified by the 

government, the RealMe account can be used to access government 

services, including registering to vote, opening a bank account, and 

renewing a passport.

Source: GAO analysis of literature search results and stakeholder interviews. | GAO-18-507T

Note: We conducted a literature search to identify paperless identification alternatives in use or being 

developed by government, both in the United States and abroad. To describe the programs used 

abroad, we relied exclusively on secondary materials and did not do any independent legal research.

Stakeholders we spoke with provided general views on cardless systems 

that can electronically authenticate an individual’s identity. They 

suggested a variety of issues that should be considered in developing any 

such electronic approach:

• Vulnerability of such a system to data breaches;

• Privacy considerations (i.e., control over personal information);

• The need for strong authentication systems;

• Acceptance by federal regulators (for example, related to oversight of 

financial institutions or federal financial aid);

• Costs of implementation for institutions and individuals; and

• Effect on vulnerable populations, such as those with limited access to 

electronic technology.

SSA officials also noted several issues that would need to be considered 

in developing an alternative to the current card. While SSA officials 

indicated that the agency continues to look for ways to reduce external 

reliance on cards, they noted that any alternative must be as secure as 

the current Social Security card and processes. In particular, an SSA 

official said that SSA and the U.S. Postal Service have protocols in place 

so that Social Security cards are delivered to the intended recipients, and 
Page 15 GAO-18-507T Social Security Administration

that they get returned if they cannot be delivered to a secure location.18

Further, SSA officials stated they were unsure about potential effects on 

fraud and identity theft if paper cards were no longer used, and they 

stated that an electronic system would need to address concerns about 

personally identifiable information and security.

Chairman Johnson, Ranking Member Larson, and Members of the 

Subcommittee, this concludes my prepared statement. I will be pleased to 

answer any questions that you or other members of the subcommittee 

may have.

For future contact regarding this testimony, please contact Elizabeth 

Curda at (202) 512-7215 or curdae@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this statement. Key contributors to this testimony were 

Mark Glickman (Assistant Director), Dana Hopings, and Vernette Shaw. 

In addition, key support was provided by John de Ferrari, Holly Dye, 

David Forgosh, Rebecca Gambler, Sarah Gilliland, Gina Hoover, 

Lawrence Malenich, Mimi Nguyen, Sheila McCoy, Almeta Spencer, and 

Adam Wendel.

 18 SSA Office of Inspector General (OIG) found in 2018 that about 360,000 undeliverable 

Social Security cards are returned to SSA each year, and that about 150,000 of these 

cards could have been delivered to the correct address had there been a process in place 

to validate the address. See SSA OIG, Undeliverable Social Security Number Cards 

(Limited Distribution), A-15-17-50279 (Baltimore, Md.: April 2, 2018).

GAO Contact and 

Staff 

Acknowledgments
Page 16 GAO-18-507T Social Security Administration

Federal statute Government entity and authorized or required use 

7 U.S.C. § 2025(e) Requires the Secretary of Agriculture and state agencies to require SSNs for participation in the 

Supplemental Nutrition Assistance Program. 

20 U.S.C. § 1090(a)(12) Authorizes the Secretary of Education to include the SSNs of parents of dependent students on 

certain financial assistance forms. 

26 U.S.C. § 6109(d) Authorizes the Commissioner of the Internal Revenue Service to require that taxpayers include 

their SSNs on tax returns. 

42 U.S.C. § 405(c)(2)(C)(i) Authorizes states to collect and use SSNs in administering any tax, general public assistance, 

driver’s license, or motor vehicle registration law. 

42 U.S.C. § 405(c)(2)(C)(ii) Requires states to obtain parent’s SSNs before issuing a birth certificate unless there is good 

cause for not requiring the number. 

42 U.S.C. § 405(c)(2)(C)(iii) Authorizes the Secretary of Agriculture to require the SSNs of officers or owners of retail and 

wholesale food concerns that accept and redeem food stamps. 

42 U.S.C. § 405(c)(2)(D)(i) Authorizes states and political subdivisions to require that blood donors provide their SSNs. 

42 U.S.C. § 405(c)(2)(E) Authorizes states and political subdivisions of states to use SSNs to determine eligibility of 

potential jurors. 

42 U.S.C. § 666(a)(13) Requires states to include SSNs on applications for driver’s licenses and other licenses; on 

records relating to divorce decrees, child support orders, or paternity determinations; and on 

death records. 

42 U.S.C. § 1320b-7(a) (1) Requires that, as a condition of eligibility for certain program benefits, including Medicaid benefits, 

applicants for and recipients of these benefits furnish their SSNs to the state administering 

program. 

42 U.S.C. § 3543(a) Authorizes the Secretary of the Department of Housing and Urban Development to require 

program applicants and participants to submit their SSNs as a condition of eligibility for housing 

assistance. 

Source: GAO-17-553 | GAO-18-507T

Appendix I: Examples of Federal Statutes 

that Authorize or Require the Collection or 

Use of Social Security Numbers (SSNs)

(102389)
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