Social Security: Proposed Totalization Agreement with Mexico Presents Unique Challenges
Published: 2003-09-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Totalization agreements foster international commerce, protect benefits for persons who have worked in foreign countries, and eliminate dual social security taxes that employers and their employees pay when they operate and reside in countries with parallel social security systems. Because Mexicans are believed to represent a large share of the millions of unauthorized workers present in the United States, a totalization agreement with Mexico has raised concerns that they would become newly eligible for social security benefits. To shed light on the possible impacts, GAO was asked to (1) describe the Social Security Administration's (SSA) processes for developing the agreement with Mexico, (2) explain how the agreement might affect the payment of benefits to Mexican citizens, and (3) assess the cost estimate for such an agreement.
section_title: What GAO Found
paragraphs: SSA has no written policies or procedures it follows when entering into totalization agreements, and the actions it took to assess the integrity and compatibility of Mexico's social security system were limited and neither transparent nor well-documented. SSA followed the same procedures for the proposed Mexican agreement that it used in all prior agreements. SSA officials told GAO that they briefly toured Mexican facilities, observed how its automated systems functioned, and identified the type of data maintained on Mexican workers. However, SSA provided no information showing that it assessed the reliability of Mexican earnings data and the internal controls used to ensure the integrity of information that SSA will rely on to pay social security benefits. The proposed agreement will likely increase the number of unauthorized Mexican workers and family members eligible for social security benefits. Mexican workers who ordinarily could not receive social security retirement benefits because they lack the required 40 coverage credits for U.S. earnings could qualify for partial social security benefits with as few as 6 coverage credits. In addition, under the proposed agreement, more family members of covered Mexican workers would become newly entitled because the agreements usually waive rules that prevent payments to noncitizens' dependents and survivors living outside the United States. The cost of such an agreement is highly uncertain. In March 2003, the Office of the Chief Actuary estimated that the cost of the Mexican agreement would be $78 million in the first year and would grow to $650 million (in constant 2002 dollars) in 2050. The actuarial cost estimate assumes the initial number of newly eligible Mexican beneficiaries is equivalent to the 50,000 beneficiaries living in Mexico today and would grow sixfold over time. However, this proxy figure does not directly consider the estimated millions of current and former unauthorized workers and family members from Mexico and appears small in comparison with those estimates. The estimate also inherently assumes that the behavior of Mexican citizens would not change and does not recognize that an agreement would create an additional incentive for unauthorized workers to enter the United States to work and maintain documentation to claim their earnings under a false identity. Although the actuarial estimate indicates that the agreement would not generate a measurable long-term impact on the actuarial balance of the trust funds, a subsequent sensitivity analysis performed at GAO's request shows that a measurable impact would occur with an increase of more than 25 percent in the estimate of initial, new beneficiaries. For prior agreements, error rates associated with estimating the expected number of new beneficiaries have frequently exceeded 25 percent, even in cases where uncertainties about the number of unauthorized workers were less prevalent. Because of the significant number of unauthorized Mexican workers in the United States, the estimated cost of the proposed totalization agreement is even more uncertain than in prior agreements.

section_title: Letter
paragraphs: Totalization agreements foster international commerce and protect  benefits for persons who have worked in foreign countries in two ways.  First, the agreements eliminate dual social security taxes that multinational employers and their employees must pay when they operate and reside in countries with parallel social security programs. Second, the  agreements help to fill gaps in benefit protection for persons who have  worked in different countries for portions of their careers. Since 1977, the  United States has entered into 20 totalization agreements.
Over the last year, the United States has been negotiating a totalization  agreement with Mexico that has received considerable attention among  the media and others regarding its potential impacts. Because Mexicans  represent a large share of the millions of unauthorized workers present in  the United States, a totalization agreement with Mexico has raised  concerns that many such workers would become newly eligible for social security benefits at a time when long-term trust fund solvency is  threatened. To shed light on the possible impacts of such an agreement,  you asked us to (1) describe the Social Security Administration’s (SSA)  processes for developing the proposed agreement with Mexico, (2) explain  how the agreement might affect the payment of social security benefits to Mexican citizens, and (3) assess SSA’s cost estimates for such an  agreement.
To address these objectives, we reviewed existing totalization agreements and the laws governing them; interviewed and obtained key  documentation from SSA, Department of State, and Mexican Embassy  personnel; and reviewed a range of demographic data and estimates  addressing Mexican immigration. We also examined SSA’s actuarial cost  estimates and supporting documentation for the proposed Mexican  agreement. We conducted our work between January and August 2003, in  accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: SSA administers the Old Age, Survivors, and Disability Insurance programs  under Title II of the Social Security Act. About 96 percent of the nation’s  work force is in social security-covered employment and pays tax on its  annual earnings. When workers pay social security taxes, they earn  coverage credits, and 40 credits—equal to at least 10 years of work—  entitle them to social security benefits when they reach retirement age.
In 1977, the Congress authorized the President to enter into totalization  agreements with other countries. These bilateral agreements are intended  to accomplish three purposes. First, they eliminate dual social security  coverage and taxes that multinational employers and employees  encounter when they operate and their workers temporarily reside and  work for the corporation, usually no more than 5 years, in a foreign  country with its own social security program. Under the agreements, U.S.  employers and their workers sent temporarily abroad would benefit by  paying only U.S. social security taxes, and foreign businesses and their  workers would benefit by paying only social security taxes to their home  country. Second, the agreements provide benefit protection to workers  who have divided their careers between the United States and a foreign  country, but lack enough coverage under either social security system to  qualify for benefits, despite paying taxes into both systems. Totalization  agreements allow such workers to combine (totalize) work credits earned  in both countries to meet minimum benefit qualification requirements.  Third, most totalization agreements improve the portability of social  security benefits by removing rules that suspend benefits to noncitizens  who live outside the benefit-paying country.
By law, proposed agreements are sent to the Congress, which has 60  legislative days to review them. The agreements become effective unless  either House of the Congress adopts a resolution of disapproval. Table 1  shows agreements in effect and the years they became effective.
To qualify for totalized U.S. social security benefits, a worker must have at  least 6 but no more than 39 U.S. coverage credits. Benefit amounts are  based on the portion of time a foreign citizen worked in the United States,  and thus, are almost always lower than full social security benefits. The  average monthly, totalized social security benefit at the end of 2001 was  $162, compared with the average nontotalized monthly social security  benefit of $825. In 2001, SSA paid about $173 million under totalization  agreements to about 89,000 persons, including their dependents.  (Appendix I compares the amount of U.S. totalized benefits for different  coverage credits and earnings levels with a minimum benefit that would be  paid to a worker with 40 credits.)
Under U.S. law, immigrants may not work in the United States unless  specifically authorized. Nevertheless, immigrants often do work without  authorization and pay social security taxes. Under the Social Security Act,  all earnings from covered employment in the United States count towards  earning social security benefits, regardless of the lawful presence of the  worker, his or her citizenship status, or country of residence. Immigrants  become entitled to benefits from unauthorized work if they can prove that  the earnings and related contributions belong to them. However, they  cannot collect such benefits unless they are either legally present in the  United States or living in a country where SSA is authorized to pay them  their benefits. Mexico is such a country.
section_title: SSA’s Process for Developing Agreements Is Not Thorough or Well- Documented
paragraphs: A lack of transparency in SSA’s processes, and the limited nature of its  review of Mexico’s program, cause us to question the extent to which SSA  will be positioned to respond to potential program risks should a  totalization agreement with Mexico take place. SSA officials told us that  the process used to develop the proposed totalization agreement with  Mexico was the same as for prior agreements with other countries. The  process—which is not specified by law or outlined in written policies and  procedures—is informal, and the steps SSA takes when entering into  agreements are neither transparent nor well-documented.
Current law does not prescribe how SSA should select potential  agreement countries. According to SSA, interest in a Mexican agreement  dates back more than 20 years. SSA officials noted that increased business  interaction between the two countries due to the North American Free  Trade Agreement (NAFTA) was a factor in the renewed negotiations. In  addition, because there is a totalization agreement with Canada, our other  NAFTA partner, SSA believed that equity concerns required consideration  of an agreement with Mexico. In February 2002, SSA sought clearance  from the Department of State to begin such negotiations.
The law also does not specify which elements of other countries’ social  security systems must be evaluated during totalization agreement  negotiations. SSA officials met with Mexican officials to exchange  narrative information on their respective programs. Senior SSA officials  also visited Mexico for 2 days in August 2002. During their visit, these  officials told us that they toured social security facilities, observed how  Mexico’s automated social security systems functioned, and identified the  type of data maintained on Mexican workers. SSA took no technical staff  on this visit to assess system controls or data integrity processes. In effect,  SSA only briefly observed the operations of the Mexican social security  program. Moreover, SSA did not document its efforts or perform any  additional analyses then, or at a later time, to assess the integrity of  Mexico’s social security data and the controls over that data. In particular,  SSA officials provided no evidence that they examined key elements of  Mexico’ s program, such as its controls over the posting of earnings and its  processes for obtaining key birth and death information for Mexican  citizens. Nor did SSA evaluate how access to Mexican data and records is  controlled and monitored to prevent unauthorized use or whether internal  and external audit functions exist to evaluate operations.
Because all totalization agreements represent a financial commitment with  implications for social security tax revenues and benefit outlays, a  reasonable level of due diligence and analysis is necessary to help federal  managers identify issues that could affect benefit payment accuracy or  expose the nation’s system to undue risk. Our Internal Control  Management and Evaluation Tool provides a risk assessment framework  to help federal managers mitigate fraud, waste, abuse, and  mismanagement in public programs, such as social security. A key  component of this framework is the identification of internal and external  risks that could impede the achievement of objectives at both the entity  and program levels. Identified risks should then be analyzed for their  potential effect and an approach devised to mitigate them.
SSA did not conduct these types of analyses in previous agreements or in  the case of the proposed Mexican agreement, despite documented  concerns among Mexican government officials and others regarding the  integrity of Mexico’s records, such as those for birth, death, and marriage,  as well as its controls over assigning unique identification numbers to  workers for benefit purposes. Such information will likely play a role in  SSA’s ability to accurately determine Mexican workers’ initial and  continuing eligibility for benefits under a totalization agreement.
section_title: Totalization Agreements Will Increase Benefit Payments to Mexican Citizens
paragraphs: A totalization agreement with Mexico will increase the number of Mexican  citizens who will be paid U.S. social security benefits in two ways. First,  the agreement will make it easier for Mexican workers to qualify for  benefits. Second, it will remove some nonpayment restrictions that affect  benefit payments to non-U.S. citizens’ family members residing in another  country, thus providing U.S. social security benefits to more survivors and  dependents of entitled Mexican workers.
Under current law, a worker must earn sufficient coverage credits to  qualify for benefits under the U.S. Social Security program. For example, a  worker who was born in 1929 or later generally needs 40 coverage credits  to be insured for retirement benefits. Credits are based on a worker’s  annual earnings in social security-covered employment. At most, 4 credits  can be earned per year so that it takes at least 10 years of covered earnings  in the United States for a worker to accumulate the necessary 40 credits  and become insured for retirement benefits.
Currently, social security credits are earned by anyone who has worked in  covered employment in the United States. This is true even if the person  was unauthorized to work when he or she earned coverage credits. For  example, noncitizens, including Mexicans, who are at least 62 years old  and lawfully present in the United States, will receive retirement benefits  today as long as they meet the coverage credit threshold. Even Mexican  citizens who are not lawfully present in this country can receive social  security benefits earned through unauthorized employment if they later  return to live in Mexico. Similarly, under current law, noncitizen  dependents and survivors can also receive social security benefits under  some circumstances.
Totalization agreements generally expand benefits to both authorized and  unauthorized workers and create new groups of beneficiaries. This would  be the case for a totalization agreement with Mexico if it follows the same  pattern as all prior totalization agreements. Mexican citizens with fewer  than 40 coverage credits will be permitted to combine their annual  earnings under their home country’s social security program with their  annual earnings under the U.S. Social Security program to meet the 40- credit requirement. In addition, more family members of covered workers  will qualify for dependent and survivor benefits. Totalization agreements  generally override Social Security Act provisions that prohibit benefit  payments to noncitizens’ dependents and survivors who reside outside the  United States for more than 6 months, unless they can prove that they  lived in the United States for 5 years in a close family relationship with the  covered worker. If a totalization agreement with Mexico is structured like  others already in force, the 5-year rule for dependents and survivors will  be waived.
However, it is important to understand that not all unauthorized Mexican  citizens who have worked in the United States will receive totalization  benefits. Some will have earned at least 40 coverage credits and can  receive social security benefits without a totalization agreement. Still  others may have worked under false identities and may not be able to  prove that they have the necessary coverage credits to be entitled to  benefits. Others still may not accumulate sufficient credits under the  Mexican social security system to totalize with their U.S. social security  coverage.
section_title: Poor Data Undermine the Reliability of SSA’s Cost Estimate
paragraphs: The cost of a totalization agreement with Mexico is highly uncertain. In  March 2003, the Office of the Chief Actuary estimated that the cost of the  Mexican agreement would be $78 million in the first year and would grow  $650 million (in constant 2002 dollars) in 2050. SSA’s actuarial cost  estimate assumes the initial number of newly eligible Mexican  beneficiaries was equivalent to the 50,000 beneficiaries living in Mexico  today and would grow sixfold over time. However, this proxy figure is not  directly related to the estimated millions of current and former  unauthorized workers and their family members from Mexico and appears  small in comparison to those estimates. Furthermore, even if the baseline  estimate is used, a sensitivity analysis performed by OCACT shows that an  increase of more than 25 percent—or 13,000 new beneficiaries—would  produce a measurable impact on the long-range actuarial balance of the  trust funds. Our review of cost estimates for prior totalization agreements  shows that the actual number of beneficiaries has frequently been  underestimated and far exceeded the original actuarial estimates.
subsections: section_title: Actuarial Estimates Are Based on Varied Data Sources
paragraphs: OCACT develops estimates of expected costs of totalization agreements  by analyzing pertinent data from prior agreements, work visas issued,  foreign corporations operating in the United States, and U.S. Census data.  Because of extensive unauthorized immigration from Mexico, OCACT  concluded that U.S. Census data, that would typically be used to estimate  the number of new beneficiaries under an agreement, were not reliable.
Instead, OCACT used the number of fully insured beneficiaries—U.S.  citizens and others living in Mexico—currently receiving U.S. social  security benefits as a proxy for the number of Mexican citizens who would  initially receive totalized benefits. The principal basis for this assumption  was a 1997 study of Mexican immigration patterns conducted by a private  nonprofit organization. This study indicated that the percentage of  Mexican immigrants who returned to Mexico after more than 10 years and,  therefore, could qualify for benefits is roughly equal to the percentage that  returned after staying 2 to 9 years and would not have the required credits.  Thus, OCACT assumed that the potential totalized initial new beneficiaries  would be equivalent to the 50,000 persons currently receiving benefits in  Mexico.
For the proposed Mexican agreement, both a short-term (covering the first  8 years of the agreement) and a long-term (covering 75 years) cost  estimate were developed. The estimated cost to the Social Security Trust  Funds would be about $78 million in the first year of the agreement. For  the long-term cost estimate, OCACT projected that the number of  beneficiaries would ultimately increase sixfold to 300,000 over a 45-year  period after the agreement took effect and equal about $650 million (in  constant 2002 dollars) in 2050. However, the actuarial analysis notes that  the methodology was indirect and involved considerable uncertainty.
As a rough check on the reasonableness of using current beneficiaries in  Mexico for its cost estimate, OCACT analyzed totalized beneficiary data  for Canadian citizens because Canada, like Mexico, is a NAFTA trading  partner and shares a large contiguous border. After determining the ratio  of Canadians receiving totalized versus fully insured benefits, OCACT  applied this ratio to the number of Mexican-born U.S. social security  beneficiaries and found that about 37,000 beneficiaries would be expected  under the agreement initially, if the Canadian experience proves predictive  of the Mexican outcome. According to OCACT, this comparison increased  its confidence that the assumed 50,000 new beneficiaries under the  agreement was within a reasonable range.
Estimated Cost of Mexican  Limited data about unauthorized workers make any estimate of the  Agreement Is Highly  Uncertain  expected costs of a Mexican totalization agreement highly uncertain. A  significant variable of any totalization agreement cost estimate is the  identification of the number of potential beneficiaries. Estimates of the  number of unauthorized Mexican immigrants living in the United States  vary The federal government’s estimate was published in January 2003  and comes from the former Immigration and Naturalization Service (INS)INS estimated that, as of January 2000, about 5 million, or 69 percent of all  unauthorized immigrants in the United States, were from Mexico. INS’s  estimate also indicated that this figure was expected to increase by about  240,000 persons annually.
The INS estimate, however, does not include unauthorized Mexican  workers and family members who no longer live in the United States and  could also conceivably benefit from a totalization agreement. Economic  disparity between the United States and Mexico has fostered longstanding  immigration from Mexico to the United States dating back many decades.  Various studies also show that fewer than a third of Mexican immigrants  stay more than 10 years in the United States, the minimum amount of time  needed to qualify for social security retirement benefits. For cost analysis  purposes, little is known about the population of former immigrants who  have returned to Mexico in terms of their age, work history, dependents,  and social security coverage. These factors increase the inherent  uncertainty of any long-range forecasts with regard to Mexico. It is under  this backdrop that OCACT set about developing an estimate of the costs of  the potential totalization agreement.
We have several concerns about OCACT’s estimate of the number of  expected beneficiaries and cost of an agreement with Mexico. First, the  use of the 50,000 fully insured beneficiaries receiving benefits in Mexico as  a proxy for individuals who might initially benefit from an agreement, does  not directly consider the estimated millions of unauthorized Mexican  immigrants in the United States and Mexico who are not fully insured and  might receive totalized benefits. Furthermore, despite the availability of  key data about earnings, work histories, years of employment, and  dependents for the 50,000 fully insured beneficiaries, OCACT did not  analyze this population to determine whether they represented a good  proxy for individuals likely to qualify for totalized benefits. The cost  estimate also inherently assumes that the behavior of Mexican citizens  would not change after a totalization agreement goes into effect. Under  totalization, unauthorized workers would have an additional incentive to  enter the United States to work and to maintain the appropriate  documentation necessary to claim their earnings under a false identity.  Thus, a large number of Mexican citizens have likely earned some social  security coverage credits through both authorized and unauthorized work  to meet the 40-credit threshold requirement and are not directly accounted  for in SSA’s estimate.
Second, SSA’s reasonableness check using Canadian data faces similar  questions. While Mexico and Canada are NAFTA partners and share a  common border with the United States, there is a dramatic difference in  the extent of unauthorized immigration from these two countries and, in  our view, the Canadian experience is not a good predictor of experience  under an agreement with Mexico. Recent INS data show that Mexican  citizens account for about 69 percent of unauthorized U.S. immigrants,  whereas Canadian citizens account for less than 1 percent, and all other  totalization agreement countries combined account for less than 3 percent.  It is this population of unauthorized immigrants that makes estimating the  cost of a totalization agreement with Mexico particularly problematic.
Finally, even though SSA’s actuarial analysis increases the number of  beneficiaries sixfold over time, the expected 300,000 beneficiaries in 2050  represents only about 6 percent of the estimated number of unauthorized  Mexicans in the United States today, and thus appears relatively low.  Although it would be unreasonable to expect all unauthorized Mexicans in  the United States to qualify for totalized benefits, the very large difference  between estimated and potential beneficiaries underscores the uncertainty  of the estimate and the potential costs of an agreement could be higher  than OCACT projects.
Indeed, it would take only a relatively small increase in new beneficiaries  from the original actuarial assumption of 50,000 initial new beneficiaries to  have a measurable impact on the long-range actuarial balance of the trust  funds. OCACT has estimated that the agreement would not generate a  measurable impact on the long-range actuarial balance. However, a  subsequent sensitivity analysis performed at our request shows that a  measurable impact on the long-range actuarial balance of the trust funds  will occur if the baseline figure is underestimated by more than  25 percent—just 13,000 additional beneficiaries above the estimated  50,000 new beneficiaries.
Our analysis of past actuarial estimates of expected beneficiaries under  totalization agreements shows that exceeding the 25 percent threshold has  not been unusual, even in agreements where uncertainty about the number  of unauthorized workers is substantially less. Our review of prior  estimates shows that OCACT frequently either overestimated or  underestimated the number of expected beneficiaries, usually by more  than 25 percent (see table 2). In fact, where underestimates occurred, the  differences were huge, involving several orders of magnitude. However, it  is important to note that the number of estimated beneficiaries for prior  agreements is substantially smaller than for the proposed Mexican  agreement. Therefore, the differences in actual beneficiaries from  estimated beneficiaries have a higher proportional impact. Furthermore,  OCACT has not underestimated the number of expected beneficiaries for  the agreements we analyzed since the 1991 agreement with Austria.  Nevertheless, the numerous uncertainties and data gaps associated with  the Mexican agreement elevate the risks associated with any cost  estimate.
section_title: Conclusions
paragraphs: Totalization agreements between the United States and other countries  often foster enhanced diplomatic relations and provide mutually beneficial  business, tax, and other incentives to employers and employees affected  by these agreements. At the same time, the agreements impose a financial  cost to both countries’ social security programs. SSA’s processes for  entering into these agreements have been informal and have not included  specific steps to assess and mitigate potential risks. Regardless of the  country under consideration, sound management practices dictate that  SSA managers have a risk management process in place to ensure that the  interests of the United States and the Social Security Trust Funds are  protected.
Most totalization agreements have been with countries that are  geographically distant to the United States, have developed economies,  and represent only a fraction of the estimated unauthorized immigrants in  the United States. Still, all agreements include some level of uncertainty  and require due diligence on SSA’s part to alleviate those uncertainties. An  agreement with Mexico, however, presents unique and difficult challenges  for SSA because so little is known about the size, work history, earnings,  and dependents of the unauthorized Mexican population. Furthermore, a  common border and economic disparity between the United States and  Mexico have fostered significant and longstanding unauthorized  immigration into the United States, making an agreement with Mexico  potentially far more costly than any other. Thus, for the Mexican  agreement, additional analyses to assess risks and costs may be called for.
A revised approach for entering into totalization agreements with all  countries would enhance the quality of information provided to the  Congress, which is tasked with reviewing these vital long-term  commitments. A more thorough prospective analysis will also provide a  better basis for determining whether agreements under consideration  meet the mutual economic and business needs of all parties. Finally,  current solvency issues require the Congress to think carefully about  future trust fund commitments resulting from totalization agreements.  Having more timely and complete information on the benefits, costs, and  risks associated with each agreement can only serve to better inform their  decisions.
section_title: Recommendations
paragraphs: In light of the potential impact of totalization agreements on the Social  Security Trust Funds, we recommend that the Commissioner of Social  Security establish a formal process to identify and assess the major risks associated  with entering into agreements with other countries. Such a process should  include mechanisms to assess the integrity of a country’s retirement data  and records, as well as a means for documenting the range of analyses  conducted by SSA; enhance future reports to the Congress for proposed totalization  agreements with other countries by making them more consistent and  informative. Such reports should include consistent time periods for  estimating both the short- and long-term effects on the trust fund and, as  appropriate, include data on how alternative assumptions or sensitivity  analyses could affect costs and potential beneficiaries; and work with the Office of the Chief Actuary to establish a regular process  that examines original projected costs and beneficiaries affected versus  what actually transpired over time and use this information, as  appropriate, to adjust future estimating methods for totalization  agreements.
section_title: Agency Comments and Our Evaluation
paragraphs: We obtained written comments on a draft of this report from the  Commissioner of SSA, as well as OCACT. The full texts of these comments  are reproduced in appendix II. We made limited changes to the report as  appropriate. The State Department was also provided a copy of the draft  report for review and advised us that it had no comments.
SSA said that the report did not sufficiently discuss the benefits of  totalization agreements to U.S. workers and employers and disagreed with  our recommendation that the agency establish a formal process to identify  and assess the major risks associated with entering into agreements with  other countries. The agency noted that its current informal process for  evaluating whether to enter into negotiations for totalization agreements  was sufficient to identify and assess risks.
Regarding the potential benefits of totalization agreements, our report  specifically notes that such agreements foster international commerce,  protect benefits for persons who have worked in foreign countries, and  eliminate dual social security taxes for multinational employers and  employees. Our concluding remarks also note that totalization agreements  often foster enhanced diplomatic relations between participating  countries. However, these agreements also have costs to the U.S. social  security system, and we continue to believe that SSA should take steps to  assess and mitigate risk during the negotiation process rather than after an  agreement is signed.
SSA also noted that it has specific criteria it follows when deciding  whether to enter into totalization agreements with other countries and that  the agency received detailed information on Mexico’s social security  system during its 2-day visit to Mexico City. In reviewing SSA’s criteria, we  could find no specific reference to data reliability and program integrity as  a factor in negotiations. Further, our review of the activities surrounding  SSA’s visit to Mexico and the limited documentation SSA received from  Mexican social security officials shows that data integrity issues and  systems controls were not sufficiently examined. In its comments, SSA  notes that it is currently in the process of scheduling additional visits to  Mexican facilities outside of Mexico City and will utilize SSA technical  staff to further examine Mexico’s social security system. We are hopeful  that—prior to submitting a proposed agreement with Mexico—SSA will  take additional steps to assess key data it will rely on to determine  Mexican worker’s initial and continuing eligibility for U.S. totalized  benefits and that it will sufficiently document its efforts. Enhancing its due  diligence efforts and formalizing this process to include all future  totalization agreements would further improve SSA’s risk assessment  efforts.
OCACT generally agreed with our recommendations that cost estimates  for future totalization agreements should be more consistent and  informative and that such agreements should be regularly analyzed to  examine the differences between original projections and actual  experience as an aid to making better estimates. OCACT noted that,  consistent with the U.S./Mexican totalization agreement, all future  potential agreements would include both long-range (75 year) and short- range (10 year) cost projections. OCACT also noted that regularly  examining the differences between original projections and actual  experience for future totalization agreements made sense and was  consistent with current practice. Although we could find no evidence  during our review that such analyses had occurred on a systematic basis,  we are pleased to hear that such analyses are now being done and are  hopeful that OCACT will both complete them in the future and document  and make available the results.
Both SSA and OCACT disagreed with our analysis and conclusions  regarding the estimates of the potential cost of a totalization agreement  with Mexico, as well as our statement that any difference between  estimated and actual costs will be on the high side. OCACT noted that,  given the relative uncertainty of the data, this outcome is possible, but that  our statement inaccurately implied that there was evidence that OCACT  estimates are more likely to be understated than overstated. OCACT went  on to note that a number of factors suggest that OCACT’s estimate of  50,000 new beneficiaries, which will increase sixfold to 300,000 by 2050,  could indeed be too high.
Our intent was not to imply that OCACT’s estimate was biased. Thus, we  have revised our report to state that, given the large disparity between the  estimated beneficiaries and the large number of undocumented Mexican  workers, the potential cost of an agreement could be higher than OCACT  projects. However, we continue to believe that a totalization agreement  with Mexico is both qualitatively and quantitatively different than any  other agreement signed to date, especially regarding estimating the  potential impact of millions of unauthorized workers and their families.  Thus, in assessing the risks of a totalization agreement with Mexico, we  believe it is important to discuss the potentially significant impact that any  underestimate of beneficiaries could have on the Social Security Trust  Funds. As table 2 shows, error rates associated with SSA’s estimates of  potential beneficiaries under prior agreements have often been  substantial, even in cases where uncertainties about the number of  unauthorized workers were less prevalent. OCACT’s comment that “taken  as a whole” its estimate of initial beneficiaries differs from actual initial  beneficiaries by only 3 percent is misleading because it nets overestimates  against underestimates. OCACT prepares estimates of initial beneficiaries  for each proposed agreement with an individual country. Thus, any  comparison of estimated to actual initial beneficiaries should be on a  country-by-country basis, rather than by aggregating the error rates for all  agreements.
Finally, in response to our concern that the OCACT’s original baseline  estimate of 50,000 first-year totalization beneficiaries did not directly  consider millions of current and former unauthorized Mexican workers,  OCACT said that this estimate was based on the best available data.  OCACT’s comments also included excerpted text from the original  estimate in order to illustrate the analyses and assumptions that supported  using the 50,000 individuals already receiving Old-Age, Survivors, and  Disability Insurance benefits in Mexico as a proxy for potential totalization  beneficiaries. We acknowledge the data limitations facing OCACT as well  as its good faith effort to reasonably estimate the costs of a totalization  agreement with Mexico. However, based on our audit work—which  involved a thorough review of the full text of the actuarial estimate,  numerous in-depth interviews with OCACT officials to discuss issues of  concern, and regular consultation with our own Chief Actuary—it seems  reasonable to examine all sources of data and address the estimates of  unauthorized Mexican immigrants directly to provide a more complete  picture of possible outcomes from an agreement with Mexico. We  continue to believe that, given the magnitude of the proposed Mexican  agreement relative to other totalization agreements, it is not unreasonable  to expect that OCACT should develop and use a variety of approaches to  estimate potential costs and perhaps develop a range of cost estimates  based on those data sources and alternative assumptions. Such efforts  would better serve the information needs of the Congress in the event that  an agreement is ultimately submitted for its review.
We are sending copies of this report to the House and Senate committees  with oversight responsibilities for the Social Security Administration. We  will also make copies available to other interested parties upon request. In  addition, the report will be available at no charge on GAO’s Web site at  http://www.gao.gov. If you or your offices have any questions concerning  this report, please call me or Daniel Bertoni, Assistant Director, on  (202) 512-7215. Other major contributors to this report are Patrick  Dibattista, Gerard Grant, Daniel Schwimer, William Staab, and Paul  Wright.
section_title: Appendix II: Comments from the Social Security Administration