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915.5 General

915.5.1 When Required

Proof of age is required of every applicant for any annuity except:

• A spouse annuity based on having an entitled child in her care; or

• A widow's annuity based on having the employee's entitled child in her care.

Although POA is not required in the above excepted cases, it should be secured for 

future use when the spouse or widow(er) no longer has a qualifying child in care.

Proof of age is required for the employee in the following situations:

In “A” cases POA is required only if the employee's DOB has not been previously 

verified.

Effective 03-01-2004 POA of deceased employee is required in all “D” cases when a 

survivor recurring application is filed.

915.5.2 Preliminary Evaluation

Every reasonable effort must be made to establish an applicant's correct date of birth on 

RRB records. In case of conflicting information, an examiner will determine the value of 

the birth evidence on the basis of its probative value, not just the numerical value. 

However, even if the probative value is low, SSA’s MBR or NUMIDENT can be used as 

POA without further development if the guidelines in FOM1 905.5.5 are met.

Numerical value serves as an objective guide for determining the relative worth of a 

document such as a birth certificate as compared with a military record. Numerical 

value is used for comparison purposes only. Probative value represents an assessment 

of a document's validity in supporting a claim. A birth certificate has high probative 

value because it is a commonly recognized legal document generally recorded near the 

time of birth.

Multiple proofs of age may be submitted and recorded on APPLE. This is encouraged 

when it appears that only evidence of low probative value can be secured. If the date of 

birth on any of the documents disagrees with the claimed date of birth explain, in the 

Remarks section of the APPLE screen, why the document is included as evidence. 

To record SSA or NUMIDENT DOB on APPLE:

• When SSA’s MBR is used for proof of age, the type of document is “other” and 

the date of the record is the date of filing shown on the MBR. Indicate in remarks 

that the MBR was used. 
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• When SSA’s NUMIDENT is used for proof of age, the type of document is “other” 

and the date of the record is the CYD date on the internal line of the record. 

Indicate in remarks that the NUMIDENT was used. 

Please note that while the date of birth on the MBR and the NUMIDENT can be used for 

POA, the MBR and the NUMIDENT cannot be used for proof of relationship.

Evidence of low probative value that agrees with the claimed date of birth may not 

establish the DOB. If the claimed DOB is not in agreement with, or reasonably 

supported by, other information on record with the RRB, an examiner will determine 

which evidence is most convincing proof of the individual's birth date.

RRB and SSA must usually establish the same DOB for an individual. Ordinarily, birth 

evidence of the higher probative value will govern when discrepant dates of birth have 

to be reconciled.

915.5.3 Evidence Only Establishes Applicant's Year of Birth

When a document establishes only the applicant's year of birth, secure additional 

evidence to establish the individual's month and, if possible, day of birth. The additional 

evidence can be one of the proofs listed in FOM1 915.15 or another document such as 

a driver's license which shows the applicant's month, day and year of birth. The 

supporting evidence may be more recent than the proof showing only the applicant's 

year of birth.

Inform the individual that the RRB will establish a date of birth based on information in 

existing RRB records or information available from SSA.

The claimed month, day and year of birth will be established if there is no discrepant 

information in RRB or SSA records. If the claimed DOB differs from information 

previously recorded, handle according to the guidelines in FOM1 915.20. 

915.5.4 Attainment Concept

A person attains a given age on the day preceding the anniversary date of his birth. For 

example, a person born on March 2, 1925 attained age 65 on March l, l990; if his DOB 

had been March 1, 1925, he would have attained age 65 on February 28, 1990.

915.10 Evaluating Evidence

915.10.1 Probative Value of POA

Determining the probative value of a particular piece of birth evidence is a matter of 

judgment. Evaluate each piece of evidence to determine the probative values. In 

making the evaluation, consider all of the following factors:

A. Age of the evidence or date the evidence was established;
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B. The purpose for which the evidence was established (i.e., would it have served 

the person's interest to falsify his age at the time the evidence was established?);

C. Basis for the record (i.e., was proof of the person's age required?);

D. Formality of the record (i.e., was the record made under oath, witnessed, or was 

there a penalty provided for a false statement?).

A probative value judgment should not be based solely on any one factor. For instance, 

while the age of the evidence is an important factor (the earlier a record was made, the 

more reliable it tends to be), do not base the probative value decision on this factor 

alone. Note that, even if the probative value is low, SSA’s MBR or NUMIDENT can be 

used as POA without further development if the guidelines in FOM1 905.5.5 are met.

915.10.2 Numerical Value of Evidence

The following tables, which have been developed for electronic data processing 

purposes, are merely a guide for determining the relative weight of birth evidence. The 

document with the highest numerical value is not necessarily the one with the highest 

probative value.

To determine the numerical value, total the values assigned for the type of document 

and the age of the document. For example, a census record made 25 years after birth 

would have a value of 30 (15 based on type and 15 based on age).

TYPE OF DOCUMENT NUMERIC

VALUE

Civil Record of Birth 

Church Record of Birth or Baptism 

Notification of Registration of Birth

30

Hospital Birth Record or Certificate

Physician's or Midwife's Birth Record

Bible or Other Family Record

25

Naturalization Record

Military Record

Immigration Record

Passport

Draft Registration Record

20

School Record

Vaccination Record

Census Record

15
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Insurance Record

Labor Union or Fraternal Record

Marriage Record

Employer's Record

10

Other records not classified above 5

NUMBER OF YEARS AFTER DOB RECORD WAS MADE NUMERIC

VALUE

Record made within 5 years of DOB 24

Record made 5 through 10 years after DOB 21

Record made 11 through 20 years after DOB 18

Record made 21 through 30 years after DOB 15

Record made 31 through 40 years after DOB 12

Record made 41 through 50 years after DOB 9

Record made 51 through 60 years after DOB 6

Record made 61 through 70 years after DOB 3

915.10.3 Acceptability of Birth Evidence

Any document an applicant offers as proof of age may be accepted by the field office 

and submitted provided it would otherwise be acceptable even though the evidence is 

not in agreement with the applicant's claim. However, to VERIFY the applicant's claim,

the evidence must meet the following requirements:

A. It must be an original document or a certified copy of an original document. A 

photocopy may also be acceptable (see FOM1 905.10.3.D for additional 

information). A notarized copy of the proof of age is not acceptable.

B. It must not contain:

1. Material alterations in age, DOB or in the name of the person which are 

sufficient to cause doubt that the entry pertains to the person for whom it 

was submitted. An alteration in the day of the month will not discredit 

entries showing the month and year of birth if there is no indication that 

either of those entries has been altered. Likewise, an alteration in the 

month will not discredit the year of birth if the latter entry is unaltered.
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2. Material differences in the name claimed and the name shown on the 

evidence, unless the variation in name is reconciled.

In addition to the requirements above, the original entry of the age or date 

of birth of an employee shown on the evidence submitted must have been 

made more than 5 years before the filing date of the application. Evidence 

submitted to establish the age of a dependent or survivor must have been 

recorded more than 5 years before the date of submission or the filing 

date of the application, whichever is first; accept evidence submitted to 

establish the age of a child under 5 years of age, if recorded at or near the 

time of such child's birth and it is otherwise acceptable.

915.15 Specific Types of POA

915.15.1 Civil Record of Birth

A. Record Made At or Near Time of Birth - A copy of the public record of birth made 

at or near the time of birth, or a statement of the DOB shown by such record (as 

certified by the custodian of the records) is usually the best evidence of age.

B. Certificate of Delayed Registration - A certificate of delayed registration issued by 

a civil authority, or pursuant to a court order, is acceptable if it shows that the 

record of the DOB was made MORE than 5 years before the official filing date of 

the application for annuity, regardless of the source of the record.

If the certificate of delayed registration shows that the record of the DOB was 

made LESS than 5 years before the official filing date of the application, accept it 

if:

1. The basic evidence used to establish the delayed record was of earlier 

origin than 5 years before the application filing date; and

2. Such basic evidence is otherwise acceptable to the RRB.

NOTE: In assigning numerical values to delayed birth registrations, use the 

values that would be assigned to the evidence on which the registration is based. 

For example, if the registration is based on affidavits, assign a value of "5" for 

type of document. Consider the date of the oldest acceptable evidence used to 

obtain a delayed birth certificate as the date of the document. If no acceptable 

evidence is described on the document, use the date the delayed birth certificate 

was issued.

C. Amended Birth Certificate – A birth certificate showing a date of record more than 

5 years after the date of birth because the individual was adopted is an amended 

birth certificate. Consider the date the amended birth certificate was issued as 

the date of record.
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915.15.2 Naturalization Papers or Record

A. Naturalization Papers - Although naturalization papers may be surrendered, the 

making of copies is forbidden; however, a Form G-91 transcript may be made of 

pertinent excerpts and used to establish DOB or as POA if otherwise acceptable.

B. Naturalization Record - If the applicant is a naturalized citizen, POA or DOB may 

be established from a record furnished by the Immigration and Naturalization 

Service. Address all requests for records made before 4-1-56 to the Immigration 

and Naturalization Service, ll9 D Street NE, Washington, D.C. 20536. Requests 

for records made after 3-31-56 should be directed to the INS district office 

servicing the area where the person was naturalized.

In order to help locate the record, the applicant should furnish as much of the 

following information as possible:

1. Name on certificate (as spelled when naturalized or when declaration was 

filed); 

2. Number of the certificate of declaration if final papers were issued;

3. Address when naturalized;

4. Place of birth;

5. Alleged date of birth;

6. Name and location of the court which issued the certificate (or in which the 

declaration was filed); and

7. Date of naturalization (date issued).

915.15.3 Immigration Record

If a naturalization record is not obtainable, an applicant can establish POA or DOB on 

the basis of an immigration record. There are two types of immigration records, an 

arrival record and an alien registration record.

A. Arrival Record - Only the person's age is shown on this record, not his DOB. If 

the applicant arrived before 7-1-24, requests for this record should be directed to 

the Verification Center of the INS at the address of the office having jurisdiction 

as follows:

Place of Entry Address
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Canadian Border 74 Kingman Street

St. Albans,

Vermont 05478

Mexican Land Border Post Office Box 9398

El Paso, Texas 79984

Ports along the eastern seaboard, and 

the Gulf of Mexico as far west as, and 

including New Orleans, Louisiana

26 Federal Plaza

New York, New York

10007

Ports along the western seaboard, as well 

as ports on the Gulf of Mexico from New

Orleans, Louisiana, southwest to the 

border

630 Sansome Street

San Francisco, 

California 94111

To help locate the record, the applicant should furnish the exact name given on 

arrival, date of arrival, name of ship, and the port of embarkation.

If the applicant arrived after 6-30-24, the record is available from the INS district 

office having jurisdiction over the area in which the alien resides. These records 

will indicate DOB since visas and birth records or other supporting evidence were 

required for arrivals after 6-30-24.

B. Alien Registration Record - Age information from this record is available from the 

INS district office having jurisdiction over the area in which the alien resides. The 

information on the original alien registration record is based on the DOB given 

under oath when the applicant registered under the Alien Registration Act of 

1940. However, the age on the alien registration card in the applicant's 

possession may be based upon a more recent allegation of the applicant if a new 

card was issued to him at a later date.

915.15.4 Passport

A. U.S. Passport - According to State Department regulations, American passports 

may not be surrendered; therefore, transfer pertinent excerpts onto a Form G-91. 

Do not make or accept as evidence handwritten or typewritten copies, 

photocopies, or other facsimiles.

B. Japanese Passport - Some passports issued by the Japanese government may 

show the person's age in years and months but not the DOB. Under the 

Japanese method of computing age, a person is considered 1 year old at the 

time of birth and attains the age of 2 years on the following January 1st. Thus, 

any Japanese document reporting only attained age probably does not reflect the 

person's true age.
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When the only acceptable DOB evidence of record consists of a Japanese 

passport which shows the attained age, ask the applicant to submit one of the 

following forms of evidence:

1. Family records which are issued to Japanese subjects and which give the 

dates of birth of family members; or

2. Village officer's certificates, which are also issued to Japanese subjects 

and show DOB; or

3. Statements obtained from immigration authorities as to the DOB given by 

the person at the time application for passport or visa was made.

915.15.5 Military Records

Accept as POA a certificate of discharge or a release to inactive duty from a branch of 

the Armed Forces, a certified copy of such a certificate, or a certification of the M/S from 

a branch of the Armed Forces showing the applicant's claimed age or DOB as 

established if the date of release or discharge is more than 5 years prior to the 

application filing date. Accept a photocopy of such a document as POA.

915.15.6 Census Record

If after reasonable effort, the applicant is unable to secure acceptable evidence to 

establish a date of birth, or the only evidence available is of limited value, a search of 

the Bureau of the Census records may be undertaken at no expense to the applicant.

To secure a search of the census records, the applicant must complete a Form G-256 

authorizing the Bureau of the Census to conduct a search and report the results to the 

Board. Refer to FOM1 1720 for instructions on preparing and releasing Form G-256.

The Bureau of the Census will search only 2 years’ records on one request. Assist the 

applicant in completing the request for the earliest two census years for which he has 

the most complete information.

The Bureau of the Census has records taken every ten years, starting 1900, for all 50 

states. Information for Puerto Rico begins with 1910. Other U.S Territories’ census 

records begin 1920.

915.15.7 School Record

A school record showing DOB or age at the time of school admission is generally 

accessible and acceptable as POA.

(Exception: Mississippi School Census Records made before l923. This evidence may

be acceptable, but requires special consideration. The school census was taken 

between February 1 and the first Monday in June each year. Thus, the recording date 

varied from year to year and county to county. Since the child's age on the recording 
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date is shown, but the actual recording date is not, examiners must verify the recording 

date in each case. When data is transcribed from a Mississippi School Census Record 

for POA, clearly indicate this fact in the remarks section of Form G-91.)

915.15.8 Insurance Policies

A. Ordinary Life Insurance Policies - These policies generally indicate the exact 

DOB of the insured in a photocopy of the application attached to the policy. 

When this type of insurance policy does not state the exact DOB or whether the 

age of the person was given as of the next or the nearest birthday, consider the 

age shown to have been attained as of the NEAREST birth date.

B. Industrial Life Insurance Policies - These policies are issued in small amounts, 

usually not over $500.00. Premiums are stated in weekly amounts and are 

generally collected at the home by an agent of the company. Such a policy 

generally shows only the age of the insured and does not have the application 

attached to the policy. In the absence of a showing to the contrary, consider the 

age shown to be the age at the NEXT birthday as of the time the policy was 

issued.

915.15.9 Labor Union or Fraternal Record

Accept as POA a statement as to the applicant's DOB on the stationery of a labor 

organization or fraternal order (or which bears the seal of the lodge) and is signed by 

the lodge secretary (or officer responsible for the duties of a secretary). The statement 

should be in the form shown in the example below or should show the age or DOB of 

the applicant and the date the record was established.

EXAMPLE:

(Date)_______

Dear (Name of Applicant):

The records of Lodge (name and number) show that you joined it on (date) and at that 

time gave the date of your birth as (date) ...................... or ...................... your age as 

(number of years.)

(Signed) John Doe

Secretary

915.15.10 Employer Record

This record, when on official company stationery or on Form AA-2P may be accepted as 

POA of the employee if his age or DOB was entered on employer records more than 5 

years before his application filing date. If the employer record shows that the age or 
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DOB of the employee was verified by documentary evidence, secure that documentary 

evidence if possible. 

Because an employer record of age or DOB, when not verified, has a low probative 

value, make reasonable effort to secure more convincing POA.

915.15.11 Pullman Company Insurance Record

Consider a photocopy of an application for Pullman Company group insurance an 

acceptable insurance record (as distinguished from an employer record) to establish an 

employee's age or DOB if the record was made more than 5 years before the official 

filing date of the annuity application.

915.15.12 Indian Tribal Census Rolls and National Archives Records

A. Navajo Indian Tribal Census Rolls - Navajo tribal census records are normally 

established at birth based on copies of the same hospital notice as those sent to 

the various public recorders serving the Navajo reservations. These records are 

maintained at Window Rock, Arizona. Include the following information about the 

applicant in requests for records: full name (including Indian name and 

nicknames); alleged DOB; place of birth (if known); parents' names (including 

Indian names and nicknames); parents' census number; and the individual 

Navajo census number involved.

Address the request letter to the Navajo Tribe and sent it to the RRB district 

office in Albuquerque NM. See Appendix A6 in FOM1 Art 9 Appendices. 

B. Seneca Indian Tribal Census Records - From 1882 until about 1940, a yearly 

census was conducted in the Seneca Indian Nation. Beginning about 1906, 

these census records were based on New York state birth records. The 

individual's specific DOB was recorded in the first census taken after his or her 

birth.

The records are maintained by the clerk of the Seneca Nation. The clerk is 

changed every 2 years when the headquarters of the Nation is rotated between 

the Allegheny reservation in Salamanca, NY, and the Cattaraugus reservation in 

Irving, NY. The records will be in Irving from November 1996 to November 1998; 

they will then return to Salamanca for 2 years and continue to rotate in November 

of even-numbered years. Include the following information about the applicant in 

requests for records: name at birth, alleged DOB and parents' names. There is 

no charge to members of the Seneca Nation.

Address the request letter to the Clerk of the Seneca Nation and send it to the 

RRB district office in Buffalo, NY. Both Irving and Salamanca, NY, are in the 

area serviced by the Buffalo D/O. See Appendix A7 in FOM1 Art 9 Appendices. 
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C. National Archives Indian Records - The National Archives in Washington, D.C., 

has extensive records from the Bureau of Indian Affairs. Two types of records are 

especially helpful for establishing age for Indian claimants:

*Indian Census Rolls, 1885-1940 - The rolls are grouped by families, showing the 

age or DOB of each person and his or her relationship to the head of the family. 

The records are not complete because a census was not taken for every 

reservation or group of Indians for each year. Some Indians are not listed 

because they did not maintain a formal affiliation with a tribe under Federal 

supervision. Moreover, few records are kept at the National Archives for the 

following Oklahoma tribes: Cherokee, Chickasaw, Choctaw, Creek and 

Seminole.

*Quarterly Reports of Indian Schools, 1910-1939 - These records involve both 

Federal government-operated and private contract schools, and list students and 

their ages. However, these records are not complete; they do not list all schools 

or even all students in a given school.

For a particular tribe, other types of records may be available. Because of the 

variety of information contained in the National Archives, it is best to consider 

each case on an individual basis. If enough information about an applicant is 

known, the personnel at the National Archives can determine what types of 

records might list him or her.

Requests for information from the National Archives should include: applicant's 

name (including Indian name and nicknames); tribe, band, reservation or agency 

if known; alleged DOB; place of birth; parents' names (including Indian names 

and nicknames); place(s) of residence as a child; siblings' names; name and 

location of Indian school(s) attended; and the approximate dates of school 

attendance.

Address the request letter to the National Archives, Washington, DC, and send it 

to the RRB branch office in Washington, DC. See Appendix A8 in FOM1 Art 9 

Appendices. 

915.15.13 Affidavits

The sworn statements of two persons having personal knowledge of the age or DOB of 

an applicant may be acceptable. These statements should contain the following 

information:

A. The applicant's age, approximate age, or DOB; and

B. The circumstances under which the affiant has knowledge of the facts sworn to; 

and

C. The extent of the affiant's knowledge upon which the statement is based
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915.15.14 SSA Data Bases

For information about using SSA’s databases for POA, see FOM1 905.5.5

915.20 Reconciling Discrepant Dates of Birth

915.20.1 General

If the age evidence in file conflicts with the claimed date of birth, a claims examiner will 

establish the claimed DOB when:

A. The evidence of highest probative value agrees with the claimed DOB and is 

clearly superior to any conflicting evidence in file; or

B. The evidence of highest probative value is not in agreement with the claimed 

DOB, but the discrepancy does not affect:

1. The applicant's current or future eligibility for an annuity or for Medicare 

benefits, or

2. The employee's or spouse's ABD by more than 30 days, or

3. The monthly annuity rate by more than $1.00.

C. It is supported by the 1910, 1920 or 1930 Census. A 1910, 1920 or 1930 census 

record corroborates the claimed DOB when:

1. The claimed DOB and that shown on the census record are the same or 

differ by only 1 year; or

2. There is additional proof of age in file that was recorded at least 5 years 

before the filing date of the current application which supports claimed 

DOB and the discrepant evidence has less probative value.

915.20.2 Interagency Discrepancy

SSA and RRB have agreed that when both agencies are concerned with the DOB for an 

applicant or annuitant the same DOB should be established by both agencies. During 

the adjudication process, SSA reports DOBs on various forms. When the DOB in an 

RRB correspondence and the one of record at SSA disagree, a discrepancy message is 

printed on the social security earnings record (Form G-90). The claims examiner will 

begin an investigation which will involve an exchange of evidence with SSA.

A. When RRB age evidence is clearly higher in probative value, SSA will ordinarily 

change its record to agree with the DOB established by RRB.

B. When SSA has age evidence clearly higher in probative value, the examiner will 

ask you to secure:
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1. Evidence of higher probative value than that furnished to SSA; and

2. An explanation of the discrepant DOBs, including the applicant's reason 

for having claimed a different DOB if he had done so; and

3. A signed statement from the person if he wants to amend the age or DOB 

previously claimed with the RRB; and

4. A copy of the evidence used by SSA, if not in file.

If the applicant does not submit evidence of higher probative value than that used 

by SSA, the examiner will determine whether the DOB should be changed or 

administrative finality applied.

C. When SSA's and RRB's evidence have almost identical probative values and the 

DOB discrepancy is within the same month and year; establish the claimed DOB 

if the birth day is other than the first or second of the month. If the claimed day is 

on the first or second of the month, secure a third piece of evidence before 

resolving the matter.

Example: RRB had established a spouse's DOB as 6-14-18, based on her claim. 

SSA established the DOB as 6-15-18, based on a transcript of an original 

document. The probative value is identical. We would use the applicant's 

claimed DOB to establish her DOB.

915.20.3 Administrative Finality

A. Defined - Once a date of birth has been established and it is material to an award 

(even though only a partial award may have been made) or is the basis for a 

determination of entitlement to Medicare, the DOB is final for the purpose(s) for 

which it was established and may be changed only if the claim is reopened 

because:

1. The determination was caused by fraud or other fault of the applicant; or

2. There is a clear and obvious mistake of fact or a clear and obvious 

mistake of law; or

3. New and material evidence received after the determination would result 

in a decision favorable to the applicant.

B. Effects - The effect of a declaration of administrative finality will depend on the 

favorability of the established date of birth to the annuitant.

1. DOB Favorable - Normally, evidence that established that an applicant is 

older is considered favorable to him. However, do not consider that the 

evidence would result in a decision favorable to the applicant if 

establishing an earlier DOB for an employee born before 9-2-16 changes 
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an employee's closing date and disqualifies him from receiving a 

supplemental annuity.

2. DOB Not Material - A date of birth determination is not material to the 

award in some cases.

a. A disabled employee begins receiving an occupational disability 

annuity. His DOB would not be material to the award until he 

reaches age 65. If at or before age 65 it is determined that SSA 

has POA of higher probative value or has enrolled the employee for 

SMIB under a DOB different from the one on our records, our DOB 

will be changed to agree with the one established by SSA.

b. A widow(er) or spouse is receiving an annuity on the basis of 

having a child in care. Depending upon other adjudicative factors 

in the case, the DOB would not be material until the widow(er) 

reaches age 60 or 65 or until the spouse reaches age 62 or 65.

In a case where the DOB is not material to the award, the DOB 

may be changed on the basis of evidence of higher probative value 

even though the change would be considered unfavorable to the 

annuitant. However, at the point that the DOB on our records is 

material to the award, the determination is final.

3. DOB Unfavorable - If new evidence, superior to the original birthdate 

evidence, establishes that the annuitant is younger than was previously 

believed, administrative finality will be applied to the DOB used in any 

annuity awarded or Medicare determination made prior to the time the 

new evidence is received, providing that the original determination was not 

caused by fraud or other fault of the annuitant.

When administrative finality is applied to a DOB determination, no action 

will be taken to correct any previous Medicare entitlement determinations 

or awards (i.e., the PIA used in the calculations, the age reductions and 

the date of entitlement will not be changed). All future adjustments, 

whether caused by cost-of-living increases, amendments or changes in a 

family group, will be based on the original DOB. 

A DOB will be established for the annuitant on the basis of superior 

evidence for all new awards and Medicare entitlement determinations, 

such as the award of a regular annuity following a determination of 

entitlement to Medicare, the later award of a supplemental annuity or 

spouse annuity or the inclusion of a husband or wife in the award under 

the overall SSA minimum.
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915.20.4 Right of Appeal

If, as a result of a reconciliation of a discrepant DOB with SSA, the person's DOB is 

changed on RRB records, he or she has the right to appeal that decision. The appeals 

paragraph must be included in the decision notice.