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Testimony before the Subcommittees on Social Security and on Oversight, 
Committee on Ways and Means, 

House of Representatives: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 10:00 a.m. EST: 

Thursday, February 16, 2006: 

Social Security Numbers: 

Coordinated Approach to SSN Data Could Help Reduce Unauthorized Work: 

Statement of Barbara D. Bovbjerg, Director: 
Education, Workforce, and Income Security Issues: 

GAO-06-458T: 

GAO Highlights: 

Highlights of GAO-06-458T, a report to the Chairmen, Subcommittees on 
Social Security and on Oversight, Committee on Ways and Means, House of 
Representatives: 

Why GAO Did This Study: 

To lawfully work in the United States, individuals must have a valid 
Social Security number (SSN) and, if they are not citizens, 
authorization to work from the Department of Homeland Security (DHS). 
Noncitizens seeking work must provide both an SSN and evidence of work 
authorization to their employer. Yet individuals without these required 
authorizations have gained employment with false information. How these 
instances of unauthorized work can be identified or prevented 
challenges the federal agencies involved. 

The subcommittees asked GAO to discuss how federal agencies can better 
share reported earnings data to identify unauthorized work. 
Specifically, this testimony addresses two issues: (1) the Social 
Security data that could help identify unauthorized employment and (2) 
coordination among certain federal agencies to improve the accuracy and 
usefulness of such data. 

What GAO Found: 

The Social Security Administration (SSA) has two types of data that 
could be useful to reducing unauthorized work—individual Social 
Security records and earnings reports. Individual Social Security 
records, which include name, date of birth, and SSN, are used by SSA to 
provide verification services to employers wishing to assure themselves 
that the names and SSNs of their workers match SSA’s records. SSA also 
uses Social Security records in a work authorization verification 
system developed by DHS called the Basic Pilot that offers electronic 
verification of worker status. These services are voluntary, and none 
are widely used by employers. SSA's earnings records provide additional 
information, which could be used as an enforcement tool to identify 
unauthorized work. Currently, SSA uses such records to produce two 
relevant files based on earnings records, which are the Nonwork Alien 
File and the Earnings Suspense File (ESF). The Nonwork Alien File 
contains earnings information posted to SSNs issued for nonwork 
purposes, suggesting that these individuals are working without 
authorization. The ESF contains earnings reports for which SSA is 
unable to match the name and SSN of the worker, suggesting employer 
error, SSN misuse, or unauthorized work activity. In addition, we have 
reported that the ESF, which contained roughly 250 million records as 
of December 2004, appears to include an increasing number of records 
associated with probable unauthorized work, but because of statutory 
constraints, the ESF is not available to DHS as an enforcement tool. 

Improving the usefulness of SSA data could help identify unauthorized 
work and ensure that limited enforcement resources are targeted 
effectively. Ensuring that the most useful data are available requires 
close coordination among the three federal agencies involved in 
collecting and using the data—SSA, the Internal Revenue Service (IRS), 
and DHS. We have previously recommended that IRS work with DHS and SSA 
as it considers strengthening its employer wage reporting regulations, 
as such action could improve the accuracy of reported wage data, and 
that DHS, with SSA, determine how best to use such wage data to 
identify potential illegal work activity. Efforts to improve data will 
only make a difference, however, if agencies work together to improve 
employer reporting and ensure they can conduct effective worksite 
enforcement programs. 

www.gao.gov/cgi-bin/getrpt?-GAO-06-458T. To view the full product, 
including the scope and methodology, click on the link above. For more 
information, contact Barbara Bovbjerg at (202) 512-7215 or 
bovbjergb@gao.gov. 

[End of section] 

Messrs. Chairmen and Members of the Subcommittees: 

I am pleased to be here today to discuss Social Security numbers (SSNs) 
and their use in preventing and detecting unauthorized work. To 
lawfully work in the United States, individuals must have a valid SSN 
and, if they are not citizens, authorization to work from the 
Department of Homeland Security (DHS). Noncitizens seeking work are 
required to provide both an SSN and evidence of work authorization to 
their employers. Yet individuals without these required authorizations 
can gain employment with false information. How these instances of 
unauthorized work can be identified or prevented challenges the federal 
agencies involved. 

In prior GAO work on these issues, we have reported on the use of 
Social Security Administration (SSA) data for identity and employment 
eligibility verification. Although SSA's verification systems have 
improved, use of SSA information in worksite enforcement continues to 
be challenging. Today I will discuss two issues: (1) the Social 
Security data that could help identify some unauthorized employment and 
(2) coordination among SSA, DHS, and the Internal Revenue Service (IRS) 
to improve the accuracy and usefulness of such data. 

My statement is based primarily on prior GAO work on these 
topics.[Footnote 1] We are presently conducting additional work for 
these subcommittees examining the use of SSA data for detecting 
unauthorized work. To determine how SSA and DHS are coordinating to 
improve earnings data, we conducted interviews with officials from SSA, 
the SSA Office of the Inspector General, and DHS. In addition, we 
obtained and reviewed data from SSA on individuals who had reported 
earnings under a nonwork SSN, and we reviewed other documentation 
provided to us by these agencies. We began this review in October 2005 
in accordance with generally accepted government auditing standards, 
and our work is ongoing. 

In summary, SSA has two types of data that could be useful for 
addressing unauthorized work--Social Security records for individuals 
and earnings reports. Individual Social Security records include name, 
date of birth, and SSN, among other things. SSA uses these data to 
provide SSN verification services free of charge to employers wishing 
to assure themselves that the names and SSNs that their workers 
provided match SSA's records. SSA also uses Social Security records in 
a work authorization verification system called the Basic Pilot program 
developed by DHS, which offers electronic verification of worker 
status. These systems are voluntary and not widely used by employers. 
SSA's earnings records provide a different sort of information that 
could be used for identifying unauthorized work. SSA uses such records 
to produce two relevant files. SSA's Nonwork Alien File contains 
earnings reports that are posted to SSNs that were issued for nonwork 
purposes, which suggests individuals are working without DHS work 
authorization. By law, SSA provides nonwork alien information to DHS 
annually, and our ongoing work for you suggests that a number of these 
records are associated with people who became work authorized some time 
after receiving their nonwork SSNs. A second file of interest, the 
Earnings Suspense File (ESF), contains earnings reports in which the 
name and SSN do not match SSA's records.[Footnote 2] We have reported 
that this file, which contained 246 million records as of November 
2004, appears to include an increasing number of records associated 
with unauthorized work.[Footnote 3] 

Improving the usefulness of SSA data could help identify some 
unauthorized work and ensure that limited enforcement resources are 
targeted effectively. Ensuring that the most useful data are available 
requires close coordination among the three federal agencies involved 
in collecting and using the data--SSA, IRS, and DHS. We have previously 
recommended that IRS work with DHS and SSA as it considers 
strengthening its employer wage reporting regulations, as such action 
could improve the accuracy of reported wage data, and that DHS, with 
SSA, determine how best to use such wage data to identify potential 
illegal work activity. 

Background: 

The Social Security Act of 1935 authorized the SSA to establish a 
record-keeping system to help manage the Social Security program and 
resulted in the creation of the SSN. SSA uses the SSN as a means to 
track workers' earnings and eligibility for Social Security benefits. 
Through a process known as enumeration, each eligible person receives a 
unique number, which SSA uses for recording workers' employment history 
and Social Security benefits. SSNs are routinely issued to U.S. 
citizens, and they are also available to noncitizens lawfully admitted 
to the United States with permission to work. Lawfully admitted 
noncitizens who lack DHS work authorization may qualify for an SSN for 
nonwork purposes when a federal, state, or local law requires that they 
have an SSN to obtain a particular welfare benefit or service. In this 
case, the Social Security card notes that the SSN is "Not Valid for 
Employment."[Footnote 4] As of 2003, SSA had assigned slightly more 
than 7 million nonwork SSNs. Over the years, SSA has tightened the 
requirements for assigning nonwork SSNs. 

In 1986, Congress passed the Immigration Reform and Control Act (IRCA), 
which made it illegal for individuals and entities to knowingly hire 
and continue to employ unauthorized workers. The act established a two- 
pronged approach for helping to limit the employment of unauthorized 
workers: (1) an employment verification process through which employers 
are to verify newly hired workers' employment eligibility and (2) a 
sanctions program for fining employers who do not comply with the act. 
Under the employment verification process, workers and employers must 
complete the Employment Eligibility Verification Form (Form I-9) to 
certify that the workers are authorized to work in the United States. 
Those employers who do not follow the verification process can be 
sanctioned. 

SSA Individual Records and Earnings Reports Can Identify Some 
Unauthorized Work: 

SSA has two types of data useful to identifying unauthorized work-- 
individual Social Security records and earnings reports. Its individual 
records, which include name, date of birth, and SSN, among other 
things, can be used to verify that a worker is providing the SSN that 
was assigned to a person of that name. These records are used in 
verification services that are available free of charge to employers on 
a voluntary basis. SSA's earnings reports could also be used to 
identify some unauthorized work by reporting noncitizens who may have 
worked without authorization and employers who have a history of 
providing SSN/name combinations that do not match SSA records. 

SSA Records Provide Verification Services to Improve Wage Data: 

SSA uses individual Social Security records in its Employee 
Verification Service (EVS) and the Web-based SSN Verification Service 
(SSNVS), which employers can use to assure themselves that the names 
and SSNs of their workers match SSA's records. The services, designed 
to ensure accurate employer wage reporting, are offered free of charge. 
Employer use is voluntary. Although these systems only confirm whether 
submitted names and SSNs match, they could help employers identify 
workers who provide an SSN with fictitious information. 

Over the years, SSA has developed several different verification 
methods under EVS. For example, employers may submit lists of workers' 
names and SSNs by mail on a variety of media, such as magnetic tapes or 
diskettes. Alternatively, employers may call a toll-free number or 
present a hard-copy list via fax, mail, or hand delivery to a local SSA 
office. SSA verifies the information received from employers by 
comparing it with information in its own records. SSA then advises the 
employer whether worker names and SSNs match. EVS offers the benefit of 
verifying name and SSN combinations for a company's entire payroll. 
However, the system would not be able to detect a worker's misuse of 
another person's name and SSN as long as the name and SSN matched. 
Employers do not widely use this service. 

In an attempt to make verification more attractive to employers, in 
2005, SSA implemented the Web-based SSNVS. It is designed to respond to 
employer requests within 24 hours. Requests of up to 10 worker names 
and SSNs can be verified instantaneously. Larger requests of up to 
250,000 names can be submitted in a batch file, and SSA will provide 
results by the next business day. While this new system is attracting 
more employer interest, it is still not widely used. 

SSA also uses its records in a work eligibility verification system 
developed by DHS called the Basic Pilot, which offers electronic 
verification of work authorization for newly hired workers.[Footnote 5] 
Use of this program by employers is also voluntary, and the service has 
been available nationwide only since December 2004. Employers who agree 
to participate must electronically verify the status of all newly hired 
workers within 3 days of hire, using information that a new hire is 
required to provide. Under this program, an employer electronically 
sends worker data through DHS to SSA to check the validity of the SSN, 
name, date of birth, and citizenship provided by the worker. SSA 
records are used to confirm information on citizens. For noncitizens, 
SSA confirms SSN, name, and date of birth, then refers the request to 
DHS to verify work authorization status against DHS's automated 
records.[Footnote 6] If DHS cannot verify work authorization status for 
the submitted name and SSN electronically, the query is referred to a 
DHS field office for additional research by immigration status 
verifiers. If SSA is unable to verify the SSN, name, and date of birth 
or DHS record searches cannot verify work authorization, a tentative 
nonconfirmation response is transmitted to the employer. After checking 
the accuracy of the information and resubmitting the information, if 
necessary, the employer must advise the worker of the finding and refer 
him or her to either DHS or SSA to correct the problem. During this 
time, employers are not to take any adverse actions against those 
workers related to verification, such as limiting their work 
assignments or pay. When workers do not contest their tentative 
nonconfirmations within the allotted time, the Basic Pilot program 
issues a final nonconfirmation. Employers are required to either 
immediately terminate employment or notify DHS of their continued 
employment. 

Like SSA's verification services, the Basic Pilot is voluntary and is 
not widely utilized. As of January 2006, about 5,500 businesses 
nationwide had registered to participate, although a significantly 
smaller number of these are active users.[Footnote 7] Active 
participants have made about 4.7 million initial verification requests 
over a 5-year period (981,000 requests were made in fiscal year 2005). 
DHS reported on actions taken to address weaknesses in the program that 
had been identified during the early years of the program. They 
included delays in updating immigration records, erroneous 
nonconfirmations, and program software that was not user friendly. We 
subsequently reported on additional challenges, specifically, the 
capacity constraints of the system, its inability to detect identity 
fraud, and the fact that the program is limited to verifying work 
authorization of newly hired workers.[Footnote 8] 

SSA Earnings Data May Be Used to Identify Some Unauthorized Work: 

SSA's earnings records can also provide information on unauthorized 
work. There are two sets of data that are relevant to unauthorized 
work. The first set, the Nonwork Alien File, contains earnings reports 
for SSNs that were issued for nonwork purposes. The second set, the 
Earnings Suspense File, contains earnings reports in which the name and 
SSN do not match. Both could help identify some unauthorized work. 

SSA's Nonwork Alien File: 

SSA is required by law to provide its Nonwork Alien File to DHS since 
it suggests a group of people who are in the United States legally but 
may be working without authorization.[Footnote 9] Since 1998, SSA has 
provided DHS annual data on over half a million persons with earnings 
listed under nonwork SSNs. The file includes annual earnings amounts, 
worker names and addresses, and employer names and addresses as well. 

DHS has found this file to be of little use to enforcement activities, 
however. According to DHS officials, the file is currently not an 
effective tool for worksite enforcement due in part to inaccuracies in 
the data and the absence of some information that would help the 
department efficiently target its enforcement.[Footnote 10] 

In fact, because SSA only updates work authorization status at the 
request of the SSN holder, individuals in the file may now be U.S. 
citizens or otherwise legal workers who simply have not updated their 
status with SSA. Our ongoing work in this area suggests that a number 
of these records are indeed associated with people who later obtained 
permission to work from DHS. SSA policy is to update work authorization 
status when the SSN holder informs the agency of the status change and 
provides supporting documentation.[Footnote 11] Unless the individual 
informs SSA directly of the status change, SSA's enumeration records 
will continue to show the person as unauthorized to work and will 
record his or her earnings to the Nonwork Alien File. Currently, the 
extent to which such noncitizens are included in the file is unknown, 
but SSA and DHS officials have both acknowledged that the file may 
include a number of people who are currently authorized to work. 

DHS officials said that the file would be of greater value if it 
contained DHS's identifying numbers--referred to as alien registration 
numbers. According to DHS officials, because persons in the file do not 
have an identifier in common use by both agencies, they cannot 
automatically be matched with DHS records. As a result, DHS officials 
told us that they use names and birth dates to match the records, which 
can result in mismatches because names can change and numbers in birth 
dates may be transposed. SSA officials have said that generally they do 
not collect alien registration numbers from noncitizens. Collecting the 
alien registration number and providing it in the Nonwork Alien File is 
possible, they stated, but would require modifications to SSA's 
information systems and procedures. They also noted that SSA would only 
be able to collect the alien registration number when noncitizens are 
assigned an SSN or when such an individual updates his or her record. 
As part of its procedures, SSA is required to verify the immigration 
status of noncitizens before assigning them an SSN, which requires 
using alien registration numbers.[Footnote 12] However, some 
noncitizens, such as those who have temporary visas, (e.g. students) 
may not have an alien registration number. In these cases, SSA would 
not be able to include the number in the Nonwork Alien File. 

The time it takes SSA to validate earnings reports and convey the 
Nonwork Alien File to DHS also makes the file less effective for 
worksite enforcement. When SSA finishes its various processes to ensure 
that the file includes the appropriate data, the reported earnings can 
be up to 2 years old. By that time, many of the noncitizens included in 
the file may have changed employers, relocated, or changed their 
immigration status, resulting in out-of-date data on individuals or 
ineffective leads for DHS agents.[Footnote 13] 

A DHS official told us that if the Nonwork Alien File were to contain 
industry codes for the reporting employers, DHS could target those in 
industries considered critical for homeland security purposes, which 
would be consistent with DHS's mission and enforcement priorities. 
Having information about the industries the employers are in would help 
them better link the data to areas of high enforcement priority, such 
as airports, power plants, and military bases. 

Earnings Suspense File: 

Another SSA earnings file, referred to as the Earnings Suspense File, 
contains earnings reports in which the name and SSN do not match SSA's 
records, suggesting employer or worker error or, potentially, identity 
theft and unauthorized work. We have reported that this file, which 
contained 246 million records as of November 2004, appears to include 
an increasing number of records associated with unauthorized work. 
SSA's Office of the Inspector General has used the ESF to identify 
employers who have a history of providing names and SSNs that do not 
match. 

When SSA encounters earnings reports with names and SSNs that do not 
match, it makes various attempts to correct them using over twenty 
automated processes. However, about 4 percent of all earnings reports 
still remain unmatched and are electronically placed in the ESF, where 
SSA uses additional automated and manual processes to continue to 
identify valid records. Forty-three percent of employers associated 
with earnings reports in the ESF are from only 5 of the 83 broad 
industry categories, with eating and drinking establishments and 
construction being the top categories. A small portion of employers 
also account for a disproportionate number of ESF reports. For example, 
only about 8,900 employers--0.2 percent of all employers with reports 
recorded in the ESF for tax years 1985-2000--submitted over 30 percent 
of the reports we analyzed.[Footnote 14] 

Our past work has documented that individuals who worked prior to 
obtaining work authorization are a growing source of the unmatched 
earnings reports in the ESF that are later reinstated to a worker's 
account. Once workers obtain a valid SSN, they can provide SSA evidence 
of prior earnings reports representing unauthorized employment prior to 
receiving their SSN. Such earnings reports can then be used to 
determine a worker's eligibility for benefits.[Footnote 15] 

DHS officials believe that the ESF could be useful for targeting its 
limited worksite enforcement resources. For example, they could use the 
ESF to identify employers who provide large numbers of invalid SSNs or 
names and SSNs that do not match. They told us that these employers may 
knowingly hire unauthorized workers with no SSN or fraudulent SSNs and 
that employers who are knowingly reporting incorrect information about 
their workers might also be involved in illegal activities involving 
unauthorized workers. 

However, it is not clear that the ESF, which is much larger than the 
Nonwork Alien File, would be manageable or allow for targeted 
enforcement. The ESF contains hundreds of millions of records, many 
unrelated to unauthorized work, making it difficult to use for 
targeting limited resources. While the ESF may help identify some of 
the most egregious employers of unauthorized workers, in terms of poor 
earnings reporting, its focus is not on unauthorized workers. Our work 
has shown that most of the reinstatements from the file belong to U.S.- 
born citizens, not to unauthorized workers.[Footnote 16] In addition, 
because the ESF contains privileged taxpayer data, SSA cannot share 
this information with DHS without specific legislative 
authorization.[Footnote 17] SSA's Office of the Inspector General has 
recommended that SSA seek legislative authority to share this data with 
DHS, but SSA responded that it is beyond the agency's purview to 
advance legislation to amend the Internal Revenue Code in order to 
allow DHS access to tax return information.[Footnote 18] IRS officials 
have also expressed concern that sharing this data could decrease tax 
collections and compliance.[Footnote 19] We are examining the 
usefulness of SSA data to DHS for these subcommittees, and will 
consider ESF issues as part of this work. 

Closer Coordination by SSA, IRS, and DHS Could Improve Usefulness of 
SSA Earnings Data: 

Improving the usefulness of the data could help ensure that limited 
enforcement resources are targeted effectively. SSA data could help 
identify areas of unauthorized work, but closer collaboration among 
SSA, IRS, and DHS can help to ensure that the most useful data are 
available in a form that can be used efficiently for enforcement. 

Under the current data-sharing arrangement, DHS officials believe the 
agency would have to invest significant resources to determine whether 
employers it targets are really hiring persons who are not work 
authorized. DHS has stated that determining which nonwork SSN holders 
are now authorized to work may not be cost-effective and would pull 
resources from other national security-related initiatives.[Footnote 
20] Neither SSA nor DHS is able to easily and quickly update work 
status because they lack a common identifier for their records. 
Updating status without a common identifier may not be practical 
because different spellings or name variations confound large-scale 
matching efforts. For example, an August 2005 report from the SSA's 
Office of the Inspector General highlights a substantial proportion of 
cases in which names were inconsistent between SSA and DHS.[Footnote 
21] In at least six reports in recent years, SSA's Office of the 
Inspector General has recommended or mentioned prior recommendations 
that SSA work with DHS to update information about work 
authorization.[Footnote 22] SSA officials maintain that it is their 
policy to make changes to the Social Security record only if the SSN 
holder initiates the changes and provides evidentiary documents from 
DHS. SSA further states that a "resolution of the discrepant 
information between DHS and SSA would require more than a simple 
verification."[Footnote 23] 

Despite the many problems with the data, there are steps that could be 
taken to improve them. For example, the employers who submit the most 
earnings reports for nonwork SSNs might be good candidates for outreach 
and education about verifying work eligibility. SSA's Office of the 
Inspector General officials suggested that DHS send letters to 
employers of persons with nonwork SSNs. These letters could encourage 
persons listed as having nonwork SSNs, who are now authorized to work, 
to update their records. The ESF also has the potential to provide 
useful information to DHS, but this information has protected tax 
status. Although some of the same difficulties that pertain to the 
Nonwork Alien File could also affect the usefulness of the ESF to DHS 
enforcement efforts, if these challenges could be overcome, authorizing 
transmittal of at least some of the ESF information to DHS might be 
warranted. 

Producing accurate, useful data will require substantial continued 
effort on the part of SSA, DHS, and the IRS: these efforts will be of 
little value, however, if the data are not used for enforcement and to 
stimulate changes in employer and employee behavior. We have reported 
previously that the IRS program of employer penalties is weak, because 
of limited requirements on employers to verify and report accurate 
worker names and SSNs; we have recommended that IRS consider 
strengthening employer requirements, a course that could over time 
improve the accuracy of wage data reported to SSA.[Footnote 24] We have 
also reported that, consistent with DHS's primary mission in the post- 
September 11 environment, DHS enforcement resources have focused mainly 
on critical infrastructure industries in preference to general worksite 
enforcement.[Footnote 25] In such circumstances, coordination to 
leverage usable and useful SSA data is essential to ensure that limited 
DHS worksite enforcement resources are targeted effectively. Concluding 
Observations: 

The federal government likely can make use of information it already 
has to better support enforcement of immigration, work authorization 
and tax laws. The Earnings Suspense and the Nonwork Alien files have 
potential, but even the best information will not make a difference if 
the relevant federal agencies do not have credible enforcement 
programs. In fact, sharing earnings data to identify potential 
unauthorized workers could unnecessarily disclose sensitive taxpayer 
information if the data are not utilized by enforcement programs. To 
address unauthorized work more meaningfully, IRS, DHS and SSA need to 
work together to improve employer reporting, develop more usable and 
useful data sets for suspicious earnings reports, and better target 
limited enforcement resources. We look forward to contributing to this 
endeavor as we continue to conduct our work on using SSA data to help 
reduce unauthorized work. 

This concludes my prepared statement. I will be happy to answer any 
questions you may have. 

Contacts and Acknowledgments: 

For questions regarding this testimony, please call Barbara Bovbjerg at 
(202) 512-7215. Other key contributors to this statement were Blake 
Ainsworth, Assistant Director; Lara Laufer, Analyst-in-Charge; Beverly 
Crawford; Susan Bernstein; Michael Brostek; Rebecca Gambler; Jason 
Holsclaw; Daniel Schwimer; Richard Stana; Vanessa Taylor; Walter Vance; 
and Paul Wright. 

(130559): 

FOOTNOTES 

[1] GAO, Social Security: Better Coordination among Federal Agencies 
Could Reduce Unidentified Earnings Reports, GAO-05-154 (Washington, 
D.C.: February 2005); GAO, Immigration Enforcement: Weaknesses Hinder 
Employment Verification and Worksite Enforcement Efforts, GAO-05-813 
(Washington, D.C.: August 2005); and GAO, Tax Administration: IRS Needs 
to Consider Options for Revising Regulations to Increase the Accuracy 
of Social Security Numbers on Wage Statements, GAO-04-712 (Washington, 
D.C: August 2004) 

[2] SSA receives tax records of employee earnings from employers via 
the IRS's Form W-2 (Wage and Tax Statement). 

[3] GAO-05-154 

[4] Cards issued prior to 1982 do not contain this notation. 

[5] The Basic Pilot program was authorized in 1996 through the Illegal 
Immigration Reform and Immigrant Responsibility Act (IIRIRA), which 
required that the Attorney General, (now DHS) develop and test three 
pilot programs to assist employers in verifying workers' identity and 
work eligibility. The Basic Pilot program was developed and made 
available to employers in six states starting in 1997. In 2003, 
Congress required DHS to expand the verification service to all 50 
states by December 2004, and DHS met that requirement. To improve its 
effectiveness and increase participation, DHS converted the program to 
a Web-based system in July 2004. 

[6] The DHS data are maintained by the U.S. Citizenship and Immigration 
Service, (USCIS). 

[7] This indicates the number of businesses that have signed 
memorandums of understanding with DHS and is not indicative of the 
number of active participants. 

[8] GAO-05-813. 

[9] IIRIRA, Section 414. 

[10] In prior years, DHS officials cited an inability to access the 
file, because SSA sent the data to them via a computer mainframe 
cartridge that was incompatible with DHS's systems. SSA now supplies 
the file in a format that is accessible to DHS agents. 

[11] Individuals are not required to update such changes with SSA, 
although since 2002 the agency has encouraged them to do so. SSA will 
remove the nonwork notation from the SSN and reissue a card to 
individuals who were originally assigned a nonwork SSN if the 
individual provides SSA documentation of a change in the individual's 
work status by DHS. 

[12] To do this, SSA field office staff use the alien registration 
number, in part, to query DHS's records, through DHS's Systematic Alien 
Verification for Entitlements (SAVE) program, which provides certain 
DHS data online regarding aliens with such numbers. In addition, SSA 
field office staff is instructed to ask noncitizens to present their 
immigration and identity documents, which contain their alien 
registration numbers for verification. 

[13] Under the current process, SSA receives wage information from 
employers annually. Once the earnings reports are received, SSA will 
ensure the validity of the reported information before sending it to 
DHS. As a result, DHS receives the data 1 to 2 years after the earnings 
occur. For example, SSA officials told us that they SSA received 
earnings from employers based on tax year 2004 in early 2005. After 
receipt, SSA electronically validated such information throughout the 
summer and fall of that year, and sent all reported earnings associated 
with a nonwork SSN to DHS in January 2006. 

[14] GAO-05-154. 

[15] GAO-05-154. 

[16] GAO-05-154. 

[17] Internal Revenue Code Section 6103 provides that tax returns and 
return information are confidential and may not be disclosed by IRS and 
others having access to the information, with certain specific 
exceptions. Because the confidentiality of tax data is considered 
crucial to voluntary compliance, if agencies want to establish new 
efforts to use taxpayer information, executive branch policy calls for 
a business case to support sharing tax data. 

[18] Social Security Administration, Office of the Inspector General, 
Social Security Number Misuse in the Service, Restaurant, and 
Agriculture Industries, A-O8-05-25023 (Baltimore, Maryland: April 
2005); and Obstacles to Reducing Social Security Number Misuse in the 
Agriculture Industry, A-08-99-41004 (Baltimore, Maryland: January 
2001). 

[19] GAO-05-154. 

[20] GAO-05-154. 

[21] Social Security Administration, Office of the Inspector General, 
Reported Earnings Prior to the Issuance of a Social Security Number, A- 
03-04-14037 (Baltimore, Maryland: August 2005). 

[22] Social Security Administration, Office of the Inspector General, 
Social Security Administration Benefits Related to Unauthorized Work, A-
03-03-23053 (Baltimore, Maryland: March 2003); Profile of the Social 
Security Administration's Non-Work Alien File, A-14-03-23071 
(Baltimore, Maryland: September 2003); Reported Earnings Prior to the 
Issuance of a Social Security Number, A-03-04-14037 (Baltimore, 
Maryland: August 2005); Unauthorized Work Social Security Numbers at 
the Department of Defense, A-03-05-25127 (Baltimore, Maryland: 
September 2005); Impact of Nonimmigrants Who Continue Working after 
Their Immigration Status Expires, A-08-05-15073 (Baltimore, Maryland: 
September 2005); and Work Activity for Social Security Numbers Assigned 
for Nonwork Purposes in the State of Utah, A-14-01-11048 (Baltimore, 
Maryland: March 2002). 

[23] SSA, OIG, A-03-04-14037; A-03-05-25127. 

[24] GAO-04-712. 

[25] GAO-05-813 and GAO, Immigration Enforcement: Challenges to 
Implementing the INS Interior Enforcement Strategy, GAO-02-861T. 
(Washington, D.C.: June 19, 2002)