Social Security Numbers: Governments Could Do More to Reduce Display in Public Records and on Identity Cards
Published: 2004-11-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: While the use of Social Security numbers (SSN) can be very beneficial to the public sector, SSNs are also a key piece of information used for committing identity crimes. The widespread use of SSNs by both the public and private sectors and their display in public records have raised concern over how SSNs might be misused and how they should be protected. In light of this concern, GAO was asked to examine (1) the extent to which SSNs are visible in records made available to the public, (2) the reasons for which governments collect SSNs in records that display them to the public, and (3) the formats in which these records are stored and ways that the public gains access to them. As well as looking at public records, GAO also examined the practices of several federal agencies regarding the display of entire nine-digit SSNs on health insurance and other identification cards issued under their authority.
section_title: What GAO Found
paragraphs: Social Security numbers appear in any number of records exposed to public view almost everywhere in the nation, primarily at the state and local levels of government. State agencies in 41 states and the District of Columbia reported visible SSNs in at least one type of record and a few states have them in as many as 10 or more different records. SSNs are most often to be found in state and local court records and in local property ownership records, but they are also scattered throughout a variety of other government records. In general, federal agency display of SSNs in public records is prohibited under the Privacy Act of 1974. While the act does not apply to the federal courts, they have taken action in recent years to prevent public access. With regard to the SSNs maintained in public records, various state and local officials commonly reported needing them for identity verification. A few, however, said they had no use for the SSN, but that documents submitted to their offices often contained them. States also commonly reported using the SSN to facilitate the matching of information from one record to another. The federal courts largely collect SSNs when required by law to do so; however, due to privacy concerns, SSNs are not in documents that are available electronically to the public. Public records with SSNs are stored in a multiplicity of formats, but public access to them is most often limited to the inspection of individual paper copies on site or via mail by request. Few state agencies make records with SSNs available on the Internet; however, 15 to 28 percent of the nation's 3,141 counties do place them on the Internet and this could affect millions of people. Overall, GAO found that the risk of exposure for SSNs in public records at the state and local levels is highly variable and difficult for any one individual to anticipate or prevent. Another form of SSN exposure results from a government practice that does not involve public records per se. GAO found that SSNs are displayed on cards issued to millions of individuals under the authority of federal agencies for identity purposes and health benefits. This involves approximately 42 million Medicare cards, 8 million Department of Defense identification cards, as well as some insurance cards, and 7 million Veterans Affairs identification cards, which display the full nine-digit SSN. While some of these agencies are taking steps to remove the SSNs, there is no governmentwide federal policy that prohibits their display. Although we did not examine this phenomenon across all federal programs, it is clear that the lack of a broad, uniform policy allows for unnecessary exposure of personal Social Security numbers.

section_title: Letter
paragraphs: The Social Security number (SSN) is used by federal, state, and local  government agencies for a myriad of purposes, including data sharing,  research, and the administration of programs that deliver services and  benefits to the public. In the course of public business, government  agencies create, collect, or maintain many records or documents that  contain SSNs, many of which are often made available to the public in  their entirety for inspection. These governments may also handle SSNs  that, while not exposed in public records, are nevertheless subject to  public view because they are printed on individual eligibility and  identification cards. While federal and state laws may authorize or require  the use of SSNs, there is no single federal law governing their handling by  all levels and branches of government or restricting their display to the  public. State laws also vary in regulating SSN use and exposure to public  view.
While the use of SSNs can be extremely beneficial to the public sector,  SSNs are also a key piece of information used in identity thefts, including  creating false identities for financial misuse or for assuming another  individual’s identity. The widespread use and retention of SSNs by both  the public and private sectors may provide opportunities for criminals to  easily obtain and misuse this personal information. In particular, the  availability of individuals’ SSNs in public records has raised concern over  how this personal information might be misused and how it should be  protected. Historically, the general public has gained access to public  records by visiting the offices that maintain them—this offered practical  limits on the volume of SSNs that could be disclosed. Today, however, the  growth in electronic record keeping and the increasing availability of such  information in volume over the Internet have heightened concern about  misuse, particularly in view of the rise in identity thefts. We previously  reported in 2002 that few government entities that display SSNs in public  records were making them available on their Web sites, but some were  considering doing so or expanding the volume and type of such posting.
In light of the potential for increasing exposure, theft, and misuse of SSNs,  you asked us to identify common methods of storing public documents  with SSNs and to determine the extent to which the public has access to  them. To do this, we addressed three questions: (1) To what extent are  SSNs visible in records that are made available to the public? (2) For what  purpose do governments collect SSNs in records that display them to the  public? (3) How are these records stored and what methods can the public  use to access them? In addition to looking at public records, we examined  the practices of several federal executive branch agencies pertaining to the  display of SSNs on health insurance cards and other identification cards  issued under their authority.
To answer these questions, we conducted research at federal, state, and  local levels of government. To obtain information at the federal level, we  reviewed the Privacy Act and other related statutes and conducted  personal interviews with officials of 10 federal agencies. Data gathering at  the state level included a Web-based survey to state agency heads that  oversee eight pre-selected programs or functions in all 50 states and the  District of Columbia (D.C.). In a previous GAO survey, these programs or  functions were identified as frequent users of SSNs and likely to have  public records. They included (1) human services, (2) health and vital  statistics, (3) selected professional licensing offices, (4) law enforcement,  (5) the judiciary, (6) corrections, (7) public safety, and (8) labor. At the  state level, our survey of the judiciary consisted of the office of the State  Court Administrator in each state. We also conducted a survey of various  local government officials within a probability sample of 200 counties  across the United States, allowing us to generalize to the population of U.S  counties. At the local level, we surveyed (1) courts, (2) health  departments, (3) law enforcement, (4) recording officials, (5) social  services, (6) tax assessors, and (7) voter registrars. At the local level, our  survey of the judiciary included trial courts and courts of limited  jurisdiction operating in the counties in our sample. The state survey  results are based on responses from 338 out of 542 state agencies, with  responses from all 50 states and D.C. The local government survey results  are estimated with a response rate of about 81 percent. The questions  asked in each survey are listed in appendix II. We conducted our work  between March 2003 and September 2004 in accordance with generally  accepted government auditing standards. For additional information on  our methodology, see appendix I.
subsections: section_title: Background
paragraphs: Because the SSN is unique for every individual, both the public and private  sectors increasingly use it as a universal identifier. It is particularly useful  to government for data matching or identity verification to ensure that  individuals are eligible for program benefits or services. Though the use of  SSNs by government entities is often mandated or authorized by law, there  is no one law that regulates the overall use of SSNs by all levels and  branches of government, and state laws pertaining to SSN display vary in  terms of the restrictions they impose on both use and disclosure. Due to  the pervasive use of SSNs, individuals are routinely asked to disclose their  SSNs along with other personal, identifying information, for numerous  purposes. In some instances where individuals provide their SSNs to  government entities, documents containing the SSN are routinely made  available to the public for inspection.
Generally, the overall use and disclosure of SSNs by the federal  government is restricted under the Privacy Act, which, broadly speaking,  seeks to balance the government’s need to maintain information about  individuals with the rights of individuals to be protected against  unwarranted invasions of their privacy.  Section 7 of Public Law 93-579  requires that any federal, state, or local government agency, when  requesting an SSN from an individual, tell individuals whether disclosing  their SSN is mandatory or voluntary, cite the statutory or other authority  under which the request is being made, and state what uses it will make of  the individual’s SSN.  Based on a survey for prior work, we reported that  while nearly all government entities we surveyed collect and use SSNs for  a variety of reasons, many of these entities reported they do not provide  individuals the information required under this statute when requesting  their SSNs.  Further, it is unclear who has responsibility for overseeing  these requirements placed on state and local governments.
The growth in the use of SSNs is important to individual SSN holders  because these numbers, along with names and birth dates, are among the  three personal identifiers most often sought by identity thieves, and recent  statistics indicate that the incidence of identity theft is growing. The  widespread disclosure of SSNs in public records has raised concern  because it can put individuals at increased risk for identity theft. The  passage of identity theft legislation by the federal government and state  governments indicates that this type of crime is widely recognized as a  serious problem. Some of these laws include limits or restrictions on the  display of SSNs, and government agencies have taken other measures to  restrict the exposure of SSNs as well. For instance, most states have  modified their policies on placing SSNs on state drivers’ licenses, some  prohibit the use of SSNs as a student identification number, and others  have removed SSNs from checks and benefit statements. These actions  suggest that the risk of SSN exposure is also widely recognized.
As governments move increasingly to electronic record keeping, access to  documents that include Social Security numbers has become easier. To  the extent that such records are available through the Internet, ease of  access can increase exponentially. The growth of electronic record  keeping has, in fact, made it easier for some agencies to provide or even  sell their data in bulk. In our previous research, a few government  agencies and courts reported to us that they were also considering the  prospect of expanding the volume and type of public records that would  be available on their Web sites. Currently, congressional lawmakers are  considering legislation to curtail such exposures, looking at both public  and private sector uses.
Not all records held by government or public agents are “public” in terms  of their availability to any inquiring person. Governments hold many  records that are not generally available and other records that are  protected from public access. For example, adoption records are generally  sealed. Personnel records are often not readily available to the public,  although newspapers may publish the salaries of high, elected officials.  Furthermore, governments may release portions of records but protect  sensitive information within them, which includes Social Security  numbers. Treatment of similar types of records varies among federal,  state, and local governments. Furthermore, there is no common definition  of public records. For this report, however, we refer to public records as  those records generally made available to the public in their entirety for  inspection by a federal, state, or local government agency. Such  documents are typically accessed in a public reading room, clerk’s office,  or on the Internet.
In our previous review of government use of SSNs, we found that they are  prevalent in records held by government agencies, some of which were  available to the public. We also learned that courts at all three levels of  government maintain public records containing SSNs, such as divorce  decrees, child support orders, and bankruptcy cases. At that time, some  officials who maintained these records told us their primary responsibility  was to preserve the integrity of these records rather than protect the  privacy of the individual SSN holder. However, we also found that some  agencies were trying to better safeguard the SSN by using innovative  approaches, such as by modifying their processes or their forms. Some  agencies and courts also reported limiting the practice of placing public  records containing SSNs on Web sites. The most far-reaching efforts we  identified took place in states that had established statewide policies and  procedures. However, this research focused, in general, on how and why  governments use SSNs, and did not examine in detail, the extent to which  SSNs are exposed to the general public and potentially available for  misuse.
section_title: SSNs Are Widely Exposed in a Variety of Public Records Held by States, Local Jurisdictions, and Courts, but Less Exposed in Federal Records
paragraphs: We found that SSNs are widely exposed to public view in state and local  records, but less so in federally held records. Specifically, 41 states and the  District of Columbia reported displaying SSNs in public records, and we  estimate that over three-quarters of counties do so as well. The number  and type of records in which SSNs are displayed varies greatly for both  states and counties, but they are most often found in court records and  local property records. For federal executive branch agencies, records are  covered by the Privacy Act of 1974, which generally prohibits disclosure of  SSNs and other personal information. However, we found that SSNs are  available in some federal court records.
subsections: section_title: Most States Display SSNs in at Least Some Public Records, but the Types of Records Vary
paragraphs: According to our survey, most states maintain at least one type of public  record that reveals individual SSNs. Agencies in 41 states as well as the  District of Columbia reported holding at least one type of public record  that shows the SSN. This may understate their exposure, however, given  that we received responses from only 62 percent of the state agencies we  surveyed. Nevertheless, we received responses from agencies in every  state. The number of these reported records ranged from 1 to 9 for most  states, but was much higher for a few states. (See table 1.) (Appendix III  provides a complete list of state and state function response rates).
Among the types of records reported by the 338 state agencies responding,  we found no one public record in which the SSN was always displayed.  The most frequently cited, however, were those held by state courts. These  ranged from criminal proceedings and litigation and civil case files to  traffic records and records of judgments. (See fig. 1.) Appendix IV shows  how state agencies responded to our question on whether SSNs are  displayed in public records.
section_title: More Than 75 Percent of U.S. Counties Hold Some Public Records That Display SSNs
paragraphs: We estimate that individuals’ SSNs are displayed in some public records in  80 to 94 percent of U.S. counties. While not everyone would be identified  in such records, we estimate that this exposure could potentially affect  any one of the estimated 91 to 97 percent of the U.S. population that lives  in these counties.
According to our survey, the county records in which SSNs are most often  revealed are those held by recorders and court clerks. (For a description  of the types of records held by each program area see app. V.) Specifically,  we estimate that 58 to 68 percent of records held by courts and 50 to 68  percent held by recording offices contain publicly accessible SSNs, while  only 5 to 9 percent of records held by all other functions included in our  survey contain SSNs. Figure 2 shows our estimates of the percent of  records that display SSNs to the public held by different types of local  government offices.
Courts and recording offices hold a substantial variety of records. For  example, courts hold criminal proceedings, civil cases files, and traffic  records, among others. Recorders also maintain a variety of records,  including many concerning property ownership. We estimate that 80 to 94  percent of U.S. counties have publicly available court or property  ownership records with SSNs. Specifically, SSNs are available to the  public in records of criminal proceedings in 44 to 64 percent of counties  and in divorce records in 12 to 26 percent of counties—two kinds of  records that are often held by courts. SSNs are also displayed in some  other types of records—including, military discharge records and Uniform  Commercial Code (UCC) filings. Figure 3 shows the percent of counties  in which specific types of records display SSNs to the public.
While we know of no particular type of record relevant to all individuals in  a given county, there are some records that may pertain to a large number  of residents. These would be records that document activities or  transactions many people engage in—for instance, home mortgage records  or voter registrations.
To illustrate the potential for an individual’s SSN to be identified in a  public record, we have estimated the percent of the population that lives  in counties in which SSNs are available in certain types of records. For  instance, we estimate that 27 to 41 percent of the population lives in  counties in which SSNs are available to the public in traffic records.  Further, from 49 to 63 percent of the population lives in counties in which  SSNs are available in mortgage and real property transfer records, and  from 16 to 28 percent lives in counties in which SSNs are available in  divorce records.
section_title: Under the Law, SSNs Are Generally Not Available to the Public in Federal Executive Records, but They Can Be Viewed in Some Federal Court Records
paragraphs: While the federal government compiles a wide range of information on  individuals that often includes SSNs, the Privacy Act of 1974 may prohibit  their disclosure, along with other personal information, without the  consent of the individual. Specifically, SSNs in record systems—specific  groups of records—held by federal executive agencies are generally not  available to the public. SSNs that are not held in a system of records,  however, may not be governed by any other law or regulation and,  therefore, may be exposed on a limited basis. However, there was no way  to ascertain where they might be or the degree of any public access.  Nevertheless, officials we interviewed in 5 selected agencies reported that  they were not aware of any records maintained by their agencies—in a  system or otherwise—that display SSNs to the public.
Federal court records are generally available to the public, but the courts  have supervisory power to withhold certain information from public  examination. Statutes also require records disclosure in some instances.   Social Security numbers are sometimes found in these records.  According to officials of the Administrative Office of the U.S. Courts, SSNs  are available in certain types of records because the SSNs are required by  law. Occasionally, but not routinely, SSNs are available in other files  throughout the federal court system when attorneys of record include this  information in documents filed with the court. In the last 2 years, however,  the Judicial Conference of the United States, which establishes policy for  the federal judiciary, revised federal policy in bankruptcy cases so that  only the last four digits of any SSN will be visible to the general public in  new record entries.
section_title: Identity Verification Is the Most Common Use of SSNs in Public Records
paragraphs: State and local government respondents to our survey reported frequently  using SSNs in public records to verify identities or to meet state legal  requirements, but some agencies said they had no need for them. For  state agencies, the second most frequently cited purpose for using SSNs  was to match information in other records or databases. Among local  government agencies the second most frequently cited reason was to  comply with state law or regulations. However, some state and local  offices reported that they had no specific use for the SSNs in certain  records, although they were often contained in documents submitted to  their offices. The federal courts reported routinely collecting SSNs to  ascertain the identities and holdings of debtors involved in bankruptcy  filings. Courts also reported routinely collecting SSNs for Social Security  claims cases.
subsections: section_title: In State Public Records the SSN is Most Often Collected or Used for Identity Verification
paragraphs: Identity verification was the most frequent reason given by our state  survey respondents for collecting or using SSNs that are shown in public  records. Fifty-four state agencies representing 30 states cited this reason.  Ten agencies, representing 8 states, indicated there was no specific reason  for collecting or using the SSN in a particular type of public record. Table  2 shows the reasons cited for collecting or using SSNs in public records  and the number of state agencies that gave each reason.
Other reasons state agencies gave were primarily to collect fines, fees, or  judgments, and because the SSNs were already included in documents that  became part of the public records. Some of these respondents gave  specific examples of how the SSN is used for identify verification or  benefits determination. Three respondents noted that SSNs are used to  facilitate investigations of wrongdoing.
section_title: SSNs in Local Government Public Records Are Most Often Used for Identity Verification, but Many Recording Offices Receive Records with SSNs They Do Not Need
paragraphs: SSNs in local government public records are most often collected or used  for identity verification. After identity verification, other common reasons  include complying with state laws and regulations and matching with  other records. Additionally, quite a few offices maintain public records  that contain SSNs for which they have no use. Figure 4 shows reasons that  SSNs are in local public records and our estimates for the percent of such  records that contain SSNS for each purpose.
Reasons for collecting SSNs in public records varied across different  functional areas at the county level. Among local courts, identity  verification is the single most common use of SSNs in public records,  while recording offices collect or use SSNs in public records to comply  with state laws or regulations more often than any other specific purpose.  Among all other functions, SSNs are most frequently used for identity  verification, matching with other records, and complying with state laws  or regulations. Recorders also frequently maintain records that contain  SSNs for which they have no use. On the basis of our survey, we estimate  that 25 to 51 percent of records with SSNs held by recording offices  contain the number for no specific purpose. In addition, the survey  responses of some recording officials indicated that SSNs are not required  or requested by their offices, but they may appear in records filed in their  offices nonetheless. Some respondents indicated that their job is to  maintain the record only—they cannot amend or change it. Table 3 is a  sample of responses from those who checked the “other” option to the  question asking why SSNs are collected or used in specific types of public  records. (For the complete survey question and response categories, see  appendix II.)
section_title: Federal Executive and Judicial Branches Collect and Use SSNs for Purposes Required or Permitted by Law
paragraphs: Federal agencies engage in a wide range of required or permitted uses of  SSNs, such as electronic matching of information in databases. Various  federal laws and regulations require or permit federal agencies to collect  and use SSNs when administering federal programs. However, as noted  above, due to Privacy Act provisions, in most cases these SSNs are not  available to the public. Concerning the federal judiciary, SSNs are  generally required for bankruptcy and Social Security claims cases. SSNs  are generally not required with regard to other civil or criminal cases.
section_title: Public Documents with SSNs Are Stored in a Multiplicity of Formats, but Hard Copy Is Still the Most Widely Available Form of Public Access
paragraphs: Storage methods and forms of public access to records with SSNs vary  somewhat among the different levels of government, but hard copy is the  most common form of access for the public, and some agencies have  begun to reduce SSN exposure. State government offices tend to store  such records electronically, while most such local government records are  stored on microfiche or microfilm. However, for both these levels of  government, inspection of paper copies is the most commonly available  method for public access to such records. Few state agencies make them  available on the Internet. In counties, however, we estimate that offices in  as many as 15 to 28 percent—several hundred—do so. For the future,  however, few state or local offices reported any plans to place additional  records on the Internet. Some state and local offices reported that in  recent years they had begun to restrict access to SSNs in public records.  At the federal level, the National Archives stores many federal agency  documents, with access restricted by law. For its part, the federal court  system has recently taken action to restrict access to SSNs in its public  bankruptcy records, including those on the Internet.
subsections: section_title: While State Public Records Containing SSNs Tend to be Stored Electronically, Public Access Is Usually Limited to Hard Copies
paragraphs: State agencies responding to our survey generally store public records that  display SSNs electronically. Electronic databases or indexes was the most  frequently cited storage method. Microfiche or microfilm and computer  usable media such as DVDs, CD-ROMs, diskettes, or tapes were also  frequently cited. Figure 5 shows the number of state agencies using each  storage method we asked about in our survey.
Many state offices also use more than one method to store the same type  of records. This pattern could be due to retention of older records in  noncomputerized formats such as microfiche/film and placement of newer  records into computerized formats, rather than having a single record  available in multiple formats. Table 4 shows the extent of this practice.
While state agencies generally store most public records displaying SSNs  electronically, in most cases, members of the public are not able to access  the records electronically. Despite reliance on electronic storage methods,  based on our survey responses, walk-in inspection of paper copies and  mail requests are the most commonly available forms of access to state  public records containing SSNs. Fifty-four state agencies—out of 90 where  public records display SSNs—reported these were the only way for the  public to access such records. Comparatively few state agencies  responding to our survey provided Internet access to records containing  SSNs. In most offices where it is available, a fee or user registration is  required. Of those offices that make records available on the Internet,  more reported making court records and UCC filings available than any  other type of record. Figure 6 compares the extent of Internet access with  walk-in inspections and on site electronic databases.
Based on their responses to our survey, state agencies are not planning to  significantly expand Internet access to public records that show SSNs.  Only 4 state agencies indicated plans to make such records available on  the Internet, and one agency plans to remove them from Internet access.  Three agencies plan changes in Internet access. One said that a state law,  with limited exceptions, barred the release of SSNs held by any state  government entity. Another agency plans to charge a fee for Internet  access to records it maintains. The third agency plans to remove SSNs and  place records on the Internet  Our survey results show that state offices have recently taken some  measures to change the way they display or share SSNs in public records.  Again, because of the number of nonrespondents, the results may not  account for all such measures. As figure 7 shows,  state agencies most  often have either redacted—covered or otherwise hidden from view— SSNs from public versions of records or restricted access.
Specific restrictions and other actions state agencies reported taking  included blocking or removing SSNs from electronic versions of records,  allowing individuals identified in records to keep their SSNs out of  publicly available versions, replacing SSNs with alternative identifiers, and  restricting access only to individuals identified in the records. A number of  state agencies also described broader policy changes taken by their state  governments in the last 2 years. According to survey respondents, at least  8 states have enacted new laws to restrict public disclosure of SSNs. These  states, with brief descriptions of the newly enacted laws are listed in table  5.
We previously reported that Washington and Minnesota had enacted  comprehensive policies to restrict the display of SSNs. Minnesota’s law— the Minnesota Government Data Practices Act—among other provisions  specifically classifies SSNs collected by state and local government  agencies as nonpublic. Washington’s policy was implemented through an  executive order signed by the governor in April 2000. In response, state  agencies removed SSNs from forms and documents where their display  was found to be not vital to the business of the agency. They also changed  the format of certain public records to limit disclosure of SSNs, such as  recording SSNs on portions of forms or duplicate forms that are not  released to the public.
In October 2002, the Conference of Chief Justices and the Conference of  State Court Administrators issued a report (CCJ/COSCA Guidelines) for  state court systems regarding public access to court records, which  recommended that courts take various means to protect SSNs within the  court records they maintain.  One strategy discussed in the Guidelines  would be for courts to have SSNs be available in records only when  viewed at a court facility. Such records might be available electronically,  but only through workstations in a court facility. The Guidelines also  suggest that parties to a case or individuals identified in records be  allowed to request additional restrictions for good cause. Finally, the  Guidelines advise state court systems not to disclose SSNs protected by  any state or federal law.
section_title: Local Government Records with SSNs Are Most Often Stored on Microfiche or Microfilm, but Are also Posted to the Internet
paragraphs: Overall, microfiche or microfilm are the most commonly used methods of  storing local government public records that contain SSNs—38 to 52  percent of such records are stored in these manners. To a lesser degree,  county offices use DVDs and CD-ROMs, electronic text files, portable data  files, and electronic databases. We found no real variation in the storage  methods used by different functions.
Overall, the predominant methods for gaining access to local government  public records containing SSNs are by visiting an office in person to  inspect paper copies or requesting a copy through the mail. Records  containing SSNs are available in onsite electronic databases in 49 to 68  percent of counties. According to our survey, the Internet is the least  common form of access, although records with SSNs are accessible on the  Internet in 15 to 28 percent of U.S. counties. We estimate that 34 to 48  percent of the population lives in these counties. Figure 8 shows the  estimates for the percent of counties in which different methods can be  used to access public records with SSNs.
According to our survey, few or no offices other than courts or recording  offices currently make records containing SSNs available via the Internet.  With regard to future plans, while we estimate that offices in only 2 to 8  percent of counties plan to introduce Internet access to records containing  SSNs, this may have consequences for the 13 to 25 percent of the U.S.  population that lives in those counties.
In the past 2 years, the vast majority of local government offices have not  made changes to the way they display or share SSNs in particular records.  However, we estimate that offices in 13 to 27 percent of counties have  begun redacting SSNs on copies of records provided to the public and  offices in 12 to 26 percent of counties have begun restricting access to  records containing SSNs. Some offices also have begun using partial SSNs  in public records.
section_title: Access to Many Federal Records Is Restricted, and Federal Courts Are Removing SSNs from Their Web Sites
paragraphs: Federal agencies transfer paper records containing SSNs to records  centers operated by the National Archives and Records Administration  (NARA) for storage. Access to these records remains under the legal  authority of the transferring agencies, which, as noted previously,  generally do not make SSNs accessible to the public. According to NARA  officials, NARA is considering adding electronic records storage services  to the records center program, but the same rules of access would apply to  those records.
At the end of the period in which the agency records are expected to be  needed, those that have continuing value are transferred into the National  Archives and NARA’s legal custody. NARA provides public access to  archival records unless the records have access restrictions. Some records  are subject to restrictions prescribed by statute, executive order, or by  restrictions specified in writing in accordance with 44 U.S.C. 2108 by the  agency that transferred the records to the National Archives of the United  States. Additionally, the Archivist of the United States imposes general  restrictions to certain kinds of information or classes of records.
NARA has many series of federal agency records in its legal custody that  contain SSNs. NARA officials told us that it has two broad categories of  archival records with SSNs: (1) name retrievable records and   (2) operations records that are not name retrievable. NARA is unable to  screen the latter records for SSNs unless the records must be screened for  another restriction. In response to requests for name retrievable records  made under the Freedom of Information Act, NARA screens the records  and redacts SSNs (if the individual is not deceased) prior to public  disclosure or release. NARA also masks the SSNs of living individuals in  archival databases that NARA makes available to the public on its Internet  Web site.
We discussed Judicial Conference policies and procedures pertaining to  privacy and SSNs with officials from the Administrative Office of the U.S.  Courts. They told us that the Conference has taken a number of actions in  recent years to increase privacy and reduce Internet access to SSNs that  are in federal court documents. These actions include (1) implementing a  rule for bankruptcy cases, effective December 1, 2003, that requires SSNs,  except for the last four digits, to be redacted from electronically available  (Internet) documents accessible to the public; (2) issuing a “model local  rule” for criminal cases that eliminates SSNs from documents filed with  the court, unless necessary, and includes only the last four digits of SSNs  in publicly available paper and electronic versions of such documents; and  (3) issuing privacy policy guidance for electronically available court  documents in civil cases. Citing its bankruptcy case rule and model local  rule for criminal cases, the Conference also advises attorneys for parties  filing court documents to include only the last four digits of SSNs. In its  report, the committee that developed the policy noted that there should be  “consistent, nationwide policies in federal courts in order to ensure that  similar privacy protections and access presumptions apply regardless of  which federal court is the custodian of a particular case file.”
section_title: Millions of Federal Health Insurance and Identity Cards Display the SSN
paragraphs: Although they are not displayed in public records en masse, we found that  millions of SSNs are still subject to exposure on individual identity cards  issued under federal auspices. Although some agencies are taking action  to address this display of the SSN, we found that, currently, an estimated  42 million Medicare cards display entire nine-digit SSNs, as do some  Department of Defense insurance cards and approximately 8 million  identification cards, as well as 7 million Department of Veterans Affairs  (VA) beneficiary cards. In addition, approximately 830,000 federal  employees carry health insurance cards issued through Federal  Employees Health Benefits Program that display the bearer’s full SSN.  Such cards are used at the point of service – at pharmacies, medical  offices, or merely to enter buildings – and are usually carried almost  everywhere, circulating through many hands and even photocopiers,  increasing opportunities for the card and the SSN on it to be stolen,  copied, or even lost.
Three of four federal agencies have begun taking action to remove SSNs  from such health insurance or identification cards issued under their  auspices. In 2003, the federal Office of Personnel Management, which  handles personnel for executive branch agencies, directed all health  insurance carriers affiliated with the Federal Employee Health Benefit  Program to eliminate SSNs from insurance cards as soon as it is  operationally and financially practical. As of August 2004, about 57 percent  of these insurers were using numbers others than SSNs on their cards— this represents over 79 percent of the subscribers in the FEHBP. The  office projected that by the end of 2005 only 3.7 percent of FEHBP  subscribers will have their SSNs on their health insurance cards, as more  insurance companies have signaled their intention to replace the SSN.  Meanwhile, VA is eliminating SSNs from 7 million VA identification cards  and is replacing cards with SSNs or issuing new cards without SSNs from  2004 through 2009, until all such cards have been replaced. In 2004, the  Department of Defense (DoD) began replacing approximately 6 million  health insurance cards that display SSNs with cards that do not display the  bearer’s SSN, but continues to include SSNs on approximately 8 million  military identification cards. In addition, the Centers for Medicare and  Medicaid Services (CMS), with the largest number of cards displaying the  entire nine-digit SSN, does not plan to remove the SSN from Medicare  identification cards. During 2003, CMS’s Office of Financial Management,  Program Integrity Group conducted a study of identity theft issues, during  which they considered the possibility of removing SSNs from Medicare  cards. CMS officials who served on the workgroup told us that the group  had concluded that eliminating SSNs from 40 million Medicare cards  would be cost prohibitive.
The Social Security Administration (SSA), which is the issuer of Social  Security cards (displaying the bearer’s SSN), addresses this vulnerability  differently than the other agencies. SSA recommends that cards be kept in  a safe place and that a person “not carry” it with them unless it is needed  “to show it to an employer or service provider.” In contrast, CMS  instructs Medicare participants to show the card whenever medical care is  provided, and to carry the card when traveling, but to keep the number as  safe as they would a credit card number.
While the Social Security Administration advises individuals to avoid  exposure of their SSN card, we found no federal policy regarding its  display on identity and insurance cards. Specifically, there is no  presidential executive order, federal law, or common federal policy in  effect. Although SSA has authority to issue policies and procedures over  the Social Security cards that it issues, it does not have authority over how  other federal agencies use and display SSNs. While the Office of  Management and Budget has issued guidance for managing federal  information resources and protecting records on individuals, it has not  provided guidance for the display of SSNs on cards. Rather, the Centers  for Medicare and Medicaid Services, the Office of Personnel Management,  VA, and DoD each have their own policies for the cards issued under their  authority.
section_title: Conclusions
paragraphs: Today, the SSN has become a universal identifier; as such, it offers  government as well as the private sector an efficient way to verify the  identity and the qualifications of people for programs or activities ranging  from taxes to health benefits to worker’s compensation payments. As a  single, unique number assigned to one person, the SSN also allows for  tracking that individual through more than one database and comparing  information for a variety of uses, including police work.
In short, SSNs are a lynchpin to other personal information held in a  variety of records. The extent to which they are exposed to public view, of  course, increases the likelihood that they will be misused for inappropriate  mining of personal information, violation of privacy, and identity theft. The  increased use of SSNs in both the public and private sectors means that  SSNs are more widely circulated and more likely to appear in public  records that document common life events and transactions, such as  marriages and home purchases.
The continued visibility of SSNs in public records in virtually every corner  of the country presents continued risk of widespread, albeit small-scale,  identity theft. Since the public usually obtains such records in individual  hard copies, the risk of SSN theft in large volume from public records may  be small. Indeed, a variety of government agencies and oversight bodies  appear to be taking steps to eliminate the open display of SSNs, but there  is no uniform practice or policy at the federal, state, or local level to  protect them. Such initiatives to protect the SSN may slow its misuse, but  the absence of uniform and comprehensive policy is likely to leave many  individuals vulnerable. For example, the 15 to 28 percent of counties that  we estimate post some records with SSNs on the Internet creates a broad  vulnerability that, together with the lack of uniform protections, makes it  difficult for any one individual to mitigate. In one of our previous reports,  we recommended that a representative group of federal, state, and local  officials develop a unified approach to safeguarding SSNs used in all levels  of government and particularly those displayed in public records. We still  believe such an approach would be constructive.
On another front, there is jeopardy in the display of SSNs on identity and  eligibility cards issued under government auspices. The cardholder is  usually required to use his or her card at the point of service—which  means a practical need to carry and display it often—thus increasing the  likelihood for accidental loss, theft, or visual exposure. The risk this poses  has been both recognized and addressed by, among other things,  prohibitions against using SSNs as student identification numbers and  policy changes concerning use of SSNs on drivers’ licenses. While we did  not examine the phenomenon of SSN display on identification cards  across all federal programs, it is clear that the lack of a broad, uniform  policy allows for inconsistent, but persistent exposure.
To address the overall problem of exposure for the SSN, congressional  lawmakers are considering legislation that would, among other things,  curtail display of SSNs in both the private and public sectors. For its part,  the public sector has already demonstrated that it is possible, for example,  to substitute another number for the SSN on displayable cards, and link it  to actual SSNs in a protected database. Given the size of federal programs,  the lack of such safeguards across all agencies currently leaves millions of  people unprotected.
section_title: Recommendation
paragraphs: To address this potential vulnerability, we recommend that the Director,  Office of Management and Budget, identify all those federal activities that  require or engage in the display of nine-digit SSNs on health insurance,  identification, or any other cards issued to federal government personnel  or program beneficiaries, and devise a governmentwide policy to ensure a  consistent approach to this type of display.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Administrative Office of the  United States Courts, the Centers for Medicare and Medicaid Services, the  Department of Defense, the National Archives and Records  Administration, the Office of Management and Budget, the Office of  Personnel Management, the Social Security Administration, and the  Department of Veterans Affairs for comment. Officials at each agency  confirmed that they had reviewed the draft and generally agreed with its  findings and recommendation. Officials from the Administrative Office of  the United States Courts, the Department of Defense, and the Office of  Personnel Management provided us with technical comments, which we  have incorporated into the report as appropriate. We received formal  comments from officials from the Department of Defense, the Office of  Personnel Management, and the Social Security Administration; those  comments are included in appendixes VI through VIII. We did not receive  formal written comments for this report from the Centers for Medicare  and Medicaid Services, the National Archives and Records Administration,  or the Department of Veterans Affairs, though officials from each  confirmed that they generally agreed. Additionally, OMB did not provide  formal written comments, but officials from OMB’s Office of General  Counsel and Office of Information and Regulatory Affairs confirmed that  they generally agreed with the report and that they would take our  recommendation into consideration for future action.
We are sending copies of this report to the Director of the Administrative  Office of the U.S. Courts, the Administrator of the Centers for Medicare  and Medicaid Services, the Secretary of Defense, the Archivist of the  National Archives and Records Administration, the Director of the Office  of Management and Budget, the Director of the Office of Personnel  Management, the Commissioner of the Social Security Administration, and  the Secretary of Veterans Affairs, and appropriate congressional  committees, and other interested parties. In addition, the report will be  available at no charge on GAO’s Web site at http://www.gao.gov/.
If you have any questions concerning this report, please contact Barbara  Bovbjerg at (202) 512-7215. See appendix IX for other contacts and staff  acknowledgments.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: To complete the objectives for this assignment, we collected original  information at the federal, state, and local government levels. We reviewed  previous GAO reports on Social Security numbers (SSN), identity theft,  data mining, information security, record linkage and privacy, and related  topics. In addition we reveiwed various studies of state SSN use, privacy  laws such as the Information Technology Management Reform Act of 1996  (Clinger-Cohen Act), the Privacy Act of 1974, the Freedom of Information  Act, the Family Educational Rights and Privacy Act of 1974, Health  Insurance Portability and Accountability Act of 1996, the Computer  Matching and Privacy Protection Act of 1988, the Identity Theft and  Assumption Deterrence Act of 1998, several memoranda from the Office of  Management and Budget (OMB), and other related documents. We used  different methods for selecting units of study and for collecting data for  each of the three levels of government reviewed for this engagement. The  methods used in the three studies are detailed in the following sections.
subsections: section_title: Federal Level
paragraphs: We conducted personal interviews with officials of 10 federal agencies: the  Administrative Office of the United States Courts, the Centers for  Medicare and Medicaid Services, the Department of Defense, the National  Archives and Records Administration, the Office of Management and  Budget, the Office of Personnel Management, the President’s Council on  Integrity and Efficiency, the Social Security Administration, the  Department of Agriculture, and the Department of Veterans Affairs. We  selected these agencies because they have responsibility for implementing  the Privacy Act, the Freedom of Information Act, or programs that are  generally known to include SSNs.
We obtained information from six federal agencies using an interview  guide based on federal privacy laws and OMB’s general and/or agency- specific disclosure criteria. The interview guide also addressed each  agency’s own privacy regulations and practices. Additional queries  dovetailed with questions asked at the state and local levels: public access  to the agencies’ public records that contain SSNs, availability of these  records on the Internet, privacy and protecting records about individuals  and other issues unique to the agency. The interview guide has face  validity and was used as a talking point instrument.
section_title: Survey Development
paragraphs: To gather information about public records that contain SSNs and whether  they are made available to the public at the state and local levels, we  surveyed state and local government officials in program areas that were  determined likely to maintain or collect public records. We developed a  list of questions to be used for both surveys, although the state survey was  Web-based and the county survey was administered by mail.
The survey was designed to address questions about multiple public  records while allowing for analysis on specific types of records. To this  end, we developed a standardized two-page questionnaire, which could be  replicated for various types of public records and could be used at both  the state and the county level. In addition, the survey design allowed for  specific groupings of different types of records to be sent to different  respondents. For instance, court clerks were sent forms concerning types  of records different from those sent to public health officials. The  questionnaire include such items as accessibility of records displaying  SSNs to the public; reasons for collecting or using SSNs in the record;  formats for storing records with SSNs; plans for changing those formats;  methods by which the public can access or view records with SSNs,  including Internet usage and changes the office has made in the past   2 years in the way records with SSNs are displayed to the public.
We selected 35 different types of public records for our review. We  developed the list based on research we conducted on public records, the  results of a prior GAO survey concerning government use of SSNs, expert  reviewers, and pretesting of the survey instrument. These records can be  grouped in the following major categories: court records (e.g., records of  criminal proceedings, child support/child custody, divorce, etc); law  enforcement records (e.g., criminal arrest warrants, prison records);  motor vehicle records; lien and security interest records; vital records  (birth, death, and marriage); health records (immunizations and  communicable diseases); and “other” category which includes  professional licensing, military discharge records, and social service  records among others. Appendix V includes a full list of the 35 record  types.
For the development of both the list of records types and the survey  questions, we obtained assistance from both internal and external expert  reviewers.
section_title: State Level
paragraphs: Data gathering for the state level consisted of a Web-based survey to state  officials in previously identified program areas or functions in all 50 states  and the District of Columbia. These program areas, identified in our  previous work on government use of SSNs as likely to maintain public  records containing SSNs, included: (1) courts/judiciary, (2) law  enforcement, (3) human services, (4) health and vital statistics,   (5) selected professional licensing offices, (6) labor, (7) corrections, and  (8) public safety. Several steps were involved in the preparation of and  conduct of the survey. We obtained the names and e-mail addresses of  state officials in these offices from a list used for our earlier work and  updated names, telephone numbers, and Web addresses using the “Yellow  Book Leadership Directories” provided in our Intranet. Two contractors  made telephone calls to verify the titles and names and to obtain the e-mail  address of each of the entries.
We sent a notification e-mail to each of the department heads of the  selected state agencies informing them about the survey. Within 2 weeks  of the notification, we sent an activation e-mail with the instructions on  how to access and complete the survey, including a survey link, and a  unique username and password to each selected state official.
To increase the response rate, we sent a reminder e-mail after the  activation email to those department heads that had not responded; about  2 weeks later, we sent a second e-mail to nonrespondents. Contractors  followed-up nonrespondents with telephone calls about 2 weeks after the  second reminder e-mail. The survey was available on line from February  23, 2004, to July 31, 2004.
We surveyed 542 officials in the 50 states and the District of Columbia. We  received responses from 338 state agencies out of 542. In 12 states, we  received responses from half or fewer of the agencies surveyed. For three  of the program areas, we received responses from about half or fewer of  the states with agencies serving those functions. The response rates for  three program areas that we believe are most likely to maintain records  with information about large proportions of state residents (though not  necessarily a majority of residents) are: Courts/Judiciary–61 percent;  human services–69 percent; health services and vital statistics–60 percent.  These compare with our overall response rate of 62 percent.
section_title: County Level
paragraphs: We administered a questionnaire by mail to the study population of local  government officials in a two-stage probability sample designed to reflect  the population of U.S. counties. This allowed us to estimate to the entire  population of U.S. counties and to develop population-based estimates.  The program areas were: (1) courts, (2) law enforcement, (3) public  health, (4) recorders, (5) social services, (6) tax assessment, and (7) voter  registration. We developed a list of contact information with addresses for  local government officials using address lists obtained from the National  Association of Counties (NACO) and BRB Publications, Inc., as well as the  Yellowbook leadership directory and information obtained from state and  local government websites. Address collection was done between  November 2003 and February 2004. To identify incumbent government  officials in a sample of counties, we used address lists of county  government officials purchased from BRB Publications and NACO and  supplemented them with the name and address list used in our prior work  and by searching Web sites and making telephone calls.
We sent out packets of questionnaires to 1996 officials in 200 counties  (including minor civil divisions in 24 counties). The number or type of  records mailed to each official depended on the research team’s judgment  of the type of records each official would be likely to maintain given his or  her function. For example, we sent immunization and communicable  disease questionnaires to public health directors. We provided for an  “Other” type of record that respondents could fill out for records they  maintained and for which we did not supply a questionnaire.
A few weeks after the initial survey was mailed, we sent a reminder letter  without replacement questionnaires. A week after the first reminder letter,  we began sending a second wave of reminder letters with replacement  questionnaires. While we received a completed survey from at least one  program area in each county, the response rates within each county varied  from 1 program area in a county to all program areas. The overall response  rate for the county survey was 81 percent. Response rates for each  program area were courts (79 percent), health departments (79 percent),  law enforcement (80 percent), recording officials (88 percent), social  services (79 percent), tax assessors (85 percent), and voter registrars   (86 percent).
section_title: Local Government Sample Design
paragraphs: We developed a U.S. county sample that would reflect the U.S. population  and allow making estimates related to persons. The probability sample of  200 counties included 35 counties with the largest populations with  certainty and the remaining counties selected using probability  proportional to size of the population. The measure of size used for  sampling was the square root of the 2002 estimated population; use of the  square root function dampens some of the variability in county-level  population sizes (from ~100 to ~ 10,000,000). To avoid having a sparsely  populated county having large influence on population-related estimates,  two counties with 2002 estimated populations less than 150 are combined  with neighboring counties, using geographic information from the U.S.  Bureau of the Census’s TIGER system; this is the one situation where  sampling units are not individual counties.
We determined that for the sampled counties in some states (24 total:  Connecticut (2), Maine (2), Massachusetts (2), Michigan (9), New  Hampshire (1), New Jersey (3), Wisconsin (5)), it was appropriate to  survey local government officials within subcounty units called “Minor  Civil Divisions” (MCD) because either county governments do not exist  (e.g., Connecticut and Massachusetts) or the MCD governments perform  many functions that usually are performed by county governments in  other areas. This second stage probability sample consisted of 59 MCDs  from the specified set of counties, consisting of the 11 MCDs that have  2002 estimated populations of 100,000 or more, and 48 MCDs (2 from each  of the 24 counties), selected using probability proportional to the size of  the population.
During the implementation of the survey, we identified respondents who  were not in the target population. Table 6 provides a summary of the  reasons for these out of sample respondents.
In implementing our survey, we also had many respondents who  completed surveys on behalf of several offices. For instance, in some  counties and states where courts are centrally administered, we received  just one completed survey on behalf of all courts in a county or in a state.  In addition, in some states certain functions, such as social services, are  state government programs, but are administered by local or regional  offices. In some of these cases, we received one completed survey from a  state official on behalf of some or all local or regional program offices.
section_title: Estimation and Sampling Error
paragraphs: The results of the county survey were weighted to make the results  generalizable to the entire population of U.S. counties. For each stratum,  we formed estimates by weighting the data by the reciprocal of the  selection probability. The margins of error for the county survey results  varied because we made estimates for different subpopulations. For all the  estimates shown here, we are 95 percent confident that when sampling  error is considered, the results are within +/- 7 percentage points unless  otherwise indicated. All population estimates based on the survey of local  government officials are for the target population defined as local  government officials in 7 program areas and courts within a sample of   200 U.S. counties.
The survey of local government officials is subject to sampling error.  There was no sampling error for the census survey of state officials. The  effects of sampling errors, due to the selection of a sample from a larger  population, can be expressed as confidence intervals based on statistical  theory. Sampling errors occur because we use a sample to draw  conclusions about a larger population. As a result, the sample was only  one of a large number of samples of counties that might have been drawn.  If different samples had been taken, the results might have been different.  To recognize the possibility that other samples might have yielded other  results, we express our confidence in the precision of our particular  sample’s results as a 95 percent confidence interval.
The 95 percent confidence intervals are expected to include the actual  results for 95 percent of samples of this type. We calculated confidence  intervals for this sample using methods that are appropriate for the sample  design used. For local government survey estimates in this report, we are  95 percent confident that when sampling error is considered, the results  we obtained are within +/- 7 percentage points of what we would have  obtained if we had surveyed officials in all of the entire study population,  unless otherwise noted.
section_title: Nonsampling Error
paragraphs: In addition to sampling error, other potential sources of errors associated  with surveys, such as question misinterpretation, may be present.  Nonresponse may also be a source of nonsampling error. We took several  steps to reduce these other sources of error. We conducted pretests of the  questionnaire using a paper version with 11 incumbents of the  functions/roles selected for our review in four different counties in three  states to account for differing local government structures and to ensure  the questionnaire: (1) was clear and unambiguous, (2) did not place undue  burden on individuals completing it, and (3) was independent and  unbiased. In addition, we conducted seven pretests with state officials in   2 states. The first six were conducted using a paper version of the  questionnaire and the final test was conducted using the Web version to  test for functionality.
After pre-testing we modified the questionnaire as needed for clarity,  respondent comprehension, and objectivity. Most of the items in the  questionnaire were closed-ended but provided for multiple responses to  each question as well as possibility for respondent comments regarding  public access to records with SSNs.
We performed our work in Washington, D.C., from March 2003 through  September 2004 in accordance with generally accepted government  auditing standards.
section_title: Appendix II: State and Local Government Survey Questions
subsections: section_title: The survey of state agencies asked the same questions with one addition: "How does your office transfer <record type> with full SSNs to third parties." As discussed in appendix I, it was administered over the Web. Unlike the county survey, we did not make any determinations about the specific record types each agency might be responsible for collecting and storing. The survey instrument included forms for each record type included in our study. Respondents were first asked to check the record types applicable to their agency then scroll down through the instrument to complete the forms for those record types.
paragraphs: The overall response rate for the state survey was 62 percent. We received  responses from at least one agency in every state. In 37 states and D.C., we  received responses from more than half of the agencies surveyed. With  regard to the specific functions we surveyed, we received responses from  about half or fewer of the states in three functions: law enforcement,  cosmetology licensing, and notary public licensing. For 8 of the   12 functions, we received responses from 60 percent or more of the states.
section_title: Appendix IV: Extent of SSN Availability in State Public Records
section_title: Appendix V: Types of Public Records Held by Local Government Offices
paragraphs: Because of variation in local governments, each type of record is not  always maintained by the same type of office across all counties.  Furthermore, program areas that are separate in some counties are  combined in others. For instance, in many counties the clerk or recorder  performs functions such as voter registration or tax assessment, which  operate independently in other counties.  Due to these variations, it is not  always possible to pinpoint which office within a county maintains a  particular type of record.
Unless we had specific information indicating what records are  maintained in a specific office within a specific county, in administering  our survey to local government officials, we sent the same set of forms  (each with the same set of questions, but for a specific type of record) to  officials within each program area or function. For example, we sent  immunization and communicable disease questionnaires to public health  directors. We also provided an “Other” record form that all respondents  could fill out for records they maintained and for which we did not supply  a questionnaire. Table 9 shows the types of forms that were sent to each  program area.
Due to the variations mentioned above, we received responses about some  types of records from more than one program area.  Survey responses  concerning the following types of records were most often returned by  recording officials, but not infrequently by courts: mortgage and real  property transfer records, property ownership records, records of  property liens and other judgments, Uniform Commercial Code (UCC)  filings, divorce records, marriage licenses or applications, hunting and  fishing licenses, military discharge and induction records, business or  professional licenses, public utility usage records, notary commissions,  and vehicle or vessel registrations.
section_title: Appendix VI: Comments from the Department of Defense
section_title: Appendix VII: Comments from the Office of Personnel Management
section_title: Appendix VIII: Comments from the Social Security Administration
section_title: Appendix IX: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: The following team members contributed to all aspects of this report:  Dennis Gehley, Ron La Due Lake, Joel Marus, Nila Garces Osorio, and  John Trubey. In addition, Margaret Armen, Susan Bernstein, Carolyn  Boyce, Richard Burkard, Stefanie Bzdusek, Melissa Hinton, Catherine  Hurley, Chris Moriarity, and Caroline Sallee made contributions to this  report.