Annual Work Plan
Our Annual Work Plan (Plan) outlines our perspective of the top management challenges facing the Social Security Administration (SSA) and serves as a tool for communicating our priorities to SSA, the Congress, the Office of Management and Budget (OMB), and other interested parties. The activities described address the fundamental goals related to SSA‟s mission to administer Social Security programs and operations effectively and efficiently. Our work is prioritized to focus our resources on those areas that are most vulnerable to fraud, waste and abuse. To ensure we provide a coordinated effort, we work closely with the Offices of Investigations, Chief Counsel to the Inspector General, and Resource Management.
Our Plan is categorized to mirror the top management challenges that cut across the Government, as outlined in the President‟s Management Agenda (PMA) and rated by OMB‟s Scorecard.
The PMA was designed to coordinate agency efforts to “address the most apparent deficiencies and focus resources where the opportunity to improve performance is the greatest.” The PMA‟s goal is to establish a more responsible and responsive Government that is citizen-centered, results-oriented, and market-based. OMB provides each Federal agency a scorecard rating its performance. The scorecard is designed around a simple grading system: green for success, yellow for mixed results, and red for unsatisfactory. Following is the status of SSA‟s efforts, as reported by OMB‟s June 2006 Scorecard.
Subject to budgetary constraints, we plan to complete 105 reviews, begin 97 reviews, and oversee the review of 13 performance indicators in FY 2007 in the following issue areas.
; Social Security Number Protection
; Management of the Disability Process
; Improper Payments and Recovery of Overpayments
; Internal Control Environment and Performance Measures
; Systems Security and Critical Infrastructure Protection
; Service Delivery and Electronic Government
To assist us in this analysis, we cross-walked the PMA, Commissioner Priorities, Social Security Advisory Board, and Government Accountability Office (GAO) high-risk areas to those identified by our prior and ongoing work. The following table demonstrates that our perspective is congruent with other key decisionmakers.
In preparing this Plan, we solicited suggestions from the Agency. We received a number of suggestions for inclusion in our Plan, and we have incorporated as many of them as possible.
We recognize this Plan is dynamic, so we encourage continuous feedback and
additional suggestions. This flexibility enables us to meet emerging and critical issues evolving throughout the upcoming year.
For more information on this Plan, please contact the Office of Audit at (410) 965-9700.
SOCIAL SECURITY NUMBER PROTECTION
Efforts to Protect the Social Security Number
The Social Security number (SSN) has become a key to social, legal, and financial assimilation in this country. Because the SSN is so heavily relied on as an identifier, it is also valuable as an illegal commodity. Criminals improperly obtain SSNs by (1)false documentation; (2) stealing another person‟s SSN; (3)an SSN; (4) using the SSN of a deceased individual; or (5) contriving an SSN by selecting any nine digits. To improve controls in its enumeration process, SSA verifies all immigration documents before assigning SSNs to noncitizens. SSA also requires mandatory interviews for all applicants age 12 or older (lowered from age 18) who request an SSN. In addition, SSA has established Enumeration Centers in Brooklyn and Queens, New York, and Las Vegas, Nevada, that focus exclusively on assigning SSNs and issuing SSN cards—and it has plans to open several more, as resources
permit. Finally, in FY 2005, SSA implemented new systems enhancements by requiring field office use of software called the SS-5 Assistant. This program has
simplified the interpretation of, and compliance with, SSA‟s complex enumeration policies and, unlike the traditional process, will not process an SSN request unless SSA staff obtains and enters all of the applicant‟s required information.
In addition to these improvements, SSA has implemented several enhancements that will better ensure SSN protection. These endeavors were required by the Intelligence Reform and Terrorism Prevention Act of 2004 and include
; restricting the issuance of multiple replacement SSN cards to 3 per year and 10 in a lifetime;
; requiring independent verification of any birth record submitted by a U.S.-born individual to establish eligibility for an SSN, other than for purposes of enumeration at birth;
; coordinating with the Department of Homeland Security (DHS) and other agencies to further improve the security of Social Security cards and numbers; and
; strengthening the standards and requirements for identity and citizenship documents presented with SSN applications to ensure the correct individual obtains the correct SSN.
We applaud the Agency for these efforts and believe it has made significant strides in providing greater protection for the SSN. Nevertheless, incidences of SSN misuse continue to occur. To further protect SSN integrity, we believe SSA should
; encourage public and private entities to limit use of the SSN as an individual
; continue to address identified weaknesses in its information security
environment to better safeguard SSNs, and
; continue to coordinate with partner agencies to pursue any data sharing
agreements that would increase data integrity.
The Social Security Number and Reported Earnings
Properly posting earnings ensures eligible individuals receive the full retirement, survivor and/or disability benefits due them. If earnings information is reported incorrectly or not reported at all, SSA cannot ensure all individuals entitled to benefits are receiving the correct payment amounts. In addition, SSA‟s programs
depend on earnings information to determine whether an individual is eligible for benefits and calculate the amount of benefit payments.
SSA must use its limited resources to resolve incorrect earnings data reported by employers. The Earnings Suspense File (ESF) is the Agency‟s record of annual wage reports for which wage earners‟ names and SSNs fail to match SSA‟s records. As of October 2005, the ESF had accumulated about $520 billion in wages andmillion wage items for Tax Years (TY) 1937 through 2003. For TY 2003, SSA posted approximately 8.8wage items, representing about $58 billion in wages. While SSA has limited control over the factors that cause erroneous wage reports submitted each year, there are still areas where the Agency can improve its processes. SSA can improve wage reporting by educating employers on reporting criteria, identifying and resolving employer reporting problems, and encouraging greater use of the Agency‟s SSN verification programs. SSA also needs to
coordinate with other Federal agencies with separate, yet related, mandates. For example, the Agency works with the Internal Revenue Service (IRS) to achieve more accurate wage reporting. We have also encouraged greater collaboration with DHS on some of these employer issues.
SSA has taken steps to reduce the size and growth of the ESF. For example, in June, SSA expanded its voluntary Social Security Number Verification Service (SSNVS) to all interested employers nationwide. SSNVS allows employers to verify the names and SSNs of employees before reporting their wages to SSA. SSA also participates in the Basic Pilot program with DHS, which verifies the names and SSNs of employees as well as their citizenship and authorization to work in the U.S. In December 2004, the Basic Pilot program was made available to employers nationwide.
The Agency is modifying the information it shares with employers. Under the Intelligence Reform and Terrorism Prevention Act of 2004, SSA is required to add
both death and fraud indicators to the SSN verification systems for employers, State agencies issuing drivers‟ licenses and identity cards, and other verification routines, as determined appropriate by the Commissioner of Social Security. The Social Security Number and Unauthorized Work
SSA assigns nonwork SSNs to noncitizens who are (1) legally in the United States without authorization to work and are entitled to a State or local general assistance benefit that, by law, requires an SSN or (2) entitled to federally financed benefits that, by law, require an SSN. In either case, the noncitizen must meet all
requirements for the benefit other than having an SSN. SSA tracks earnings reported under a nonwork SSN and reports this information to DHS. Nonetheless, our audits have noted several issues related to nonwork SSNs, including the (1) type of evidence provided to obtain a nonwork SSN, (2) reliability of nonwork SSN information in SSA‟s records, (3) significant volume of wages reported under
nonwork SSNs, and (4) payment of benefits to noncitizens who qualified for their benefits, in part, as a result of unauthorized work in the United States. In March 2004, Congress placed new restrictions on the receipt of SSA benefits by noncitizens who are not authorized to work in the United States. Under the Social
, if a noncitizen worker was first assigned an SSN Security Protection Act of 2004
on or after January, 2004, Title II benefits are precluded based on his/her earnings unless the noncitizen was ever assigned an SSN for work purposes or admitted to the United States as a visitor for business or as an alien crewman. SSA‟s implementation of this new law will require increased coordination with DHS to ensure SSA has the correct work status information in its records. In FY 2007, we plan to complete 16 reviews and begin 9 reviews in this area.
We plan to complete the following reviews in FY 2007
Assigning Social Security Numbers to Fiancé Visa Nonimmigrants Congressional Response Report: Accuracy of the Social Security Administration‟s Numident File
Congressional Response Report: Employer Feedback on the Social Security Administration‟s Verification Programs
Effectiveness of Educational Correspondence to Employers
F-1 Students‟ Use of Social Security Numbers
Original Social Security Numbers Assigned to Individuals Age 12 or Older Social Security Numbers Assigned to Citizens of Compact of Free Association Countries
Social Security Numbers Assigned to Exchange Visitors
State and Local Governments‟ Collection, Use, and Disclosure of Social Security Numbers
The Social Security Administration‟s Compliance with SS-5 Assistant Policies and
The Social Security Administration‟s Employee Verification Programs
The Social Security Administration‟s Las Vegas Social Security Card Center
The Social Security Administration‟s Single Select Edit Routine
The Social Security Statement in Correcting Earnings Records The Validity of Earnings Posted to the Social Security Administration‟s Master
Earnings File for Children Ages 7 Through 13
Unauthorized Redisclosure of Social Security Administration Information to State Agencies in Region VII
We plan to begin the following reviews in FY 2007
Earnings Records with Multiple Employers Effectiveness of Blanket Adjustments of Earnings
Follow-up: The Enumeration at Entry Process
Follow-up: The Social Security Administration‟s Internal Use of Employee Social Security Numbers
Individuals Applying for Replacement Social Security Cards Using Different Places of Birth
Medicare‟s Use of Social Security Numbers on Cards Issued to Participants
Non-program Social Security Number Verification Requests from Third Parties Social Security Administration/Internal Revenue Service Wage Reconciliation Process
The Office of Quality Performance‟s New Earnings Suspense File Edits and the Impact on Earnings Integrity
Assigning Social Security Numbers to Fiancé Visa Nonimmigrants
To (1) evaluate SSA‟s compliance in assigning SSNs to fiancé visa nonimmigrants and (2) determine whether vulnerabilities exist in this process that may allow noncitizen fiance‟s whose immigration status has expired to remain in the United States and improperly use their SSNs.
U.S. citizens who are engaged to a foreign national may petition the State Department for a fiancé classification. The marriage must take place within 90 days of the fiancé entering the United States. If the marriage does not take place within 90 days, the State Department requires that the fiancé leave the United States.
SSA policies and procedures state that fiancé visa holders are eligible to receive an SSN upon producing evidence of age, identity and a valid, unexpired U.S. Citizenship and Immigration Services Form I-94, Arrival-Departure Record, which
contains the appropriate certification from DHS that entry to the United States has been permitted with a fiancé visa classification. SSA assigns about 14,000 original SSNs annually to individuals who have fiancé visas. SSA field office personnel have expressed concern that the Agency assigns SSNs to fiancé visa holders whose legal duration of stay in the United States may only be 90 days. An SSN card makes it easier for individuals who do not marry to remain in the United States.
Congressional Response Report: Accuracy of the Social Security Administration’s Numident File
To assess the accuracy of SSA‟s Numident file information relied on in employment verification services.
SSA provides employers and third-party submitters several verification programs and services that allow them to match their employees‟ names and SSNs with
SSA‟s records. The Basic Pilot, one of these verification programs, is a joint effort between SSA and DHS to assist employers in verifying newly hired employees‟ authorization to work in the United States.
On April 7, 2006, the Chairman of the House Committee on Ways and Means, Subcommittee on Social Security, requested that we assist the Subcommittee in obtaining information on the reliability of the data SSA and DHS use to verify employee information submitted by employers. The Chairman asked that we assess the accuracy of the SSN Numident fields on which the Basic Pilot relies. Additionally, the Chairman requested that we provide information for each of the
following populations of numberholders:
(1) native-born U.S. citizens,
(2) foreign-born U.S. citizens, and
(3) non-U.S. citizens.
Congressional Response Report: Employer Feedback on the Social Security Administration’s Verification Programs
To assess employers‟ satisfaction with SSA‟s verification programs.
In April 2006, the Chairman of the House Committee on Ways and Means, Subcommittee on Social Security, requested information on the experiences of employers who have used one of SSA‟s three verification programs, including:
1. SSNVS—an on-line program available to employers to ensure their employees‟
names and SSNs are valid before submitting their Form W-2 to SSA. It was
rolled out nationwide in June 2005.
2. Basic Pilot—a joint effort between SSA and DHS to assist employers with
verifying newly hired employees‟ authorization to work in the United States.
Effectiveness of Educational Correspondence to Employers
To assess the effectiveness of Educational Correspondence (EDCOR) in communicating wage reporting problems to employers and reducing the size of the ESF.
SSA sends an employer an EDCOR letter when more than 10 Wage and Tax
(Forms W-2) in the employer‟s wage report do not match SSA‟s Statements
records, and these mismatches exceed 0.5 percent of the total number of W-2s in the report. The EDCOR letter notes the importance of accurate names and SSNs and encourages employers to provide SSA corrected information so the wages can be posted to the appropriate earners‟ accounts. SSA mailed approximately 128,000 EDCOR notices to employers in TY 2005.
F-1 Students’ Use of Social Security Numbers
To assess (1) F-1 students‟ use of SSNs to determine whether they work on- or off-campus or are unemployed and (2) schools‟ compliance with governing policies.
Approximately 600,000 foreign students were enrolled in educational institutions in the United States during the 2004-2005 academic year. The F-1 classification, one of three nonimmigrant classifications for foreign students, is unique in that it is assigned to students who are eligible to work on-campus without obtaining specific approval from DHS. Instead, DHS requires that the school ensure the F-1 student is attending classes full-time and in good academic standing. If so, the student is eligible to work on-campus up to 20 hours per week.
In October 2004, SSA began requiring that F-1 students who do not have an Employment Authorization Document or authorization for curricular practical training provide evidence of on-campus work authorization and verification they had secured employment or a promise of employment before SSA assigned an SSN.
Original Social Security Numbers Assigned to Individuals Age 12 or Older Objective
To determine whether SSA complied with established policies when assigning original SSNs to U.S. citizens age 12 or older.
When a U.S. citizen age 12 or older requests an original SSN or a new (different) SSN, an in-person interview must be conducted to ensure the validity of the request. The interview is conducted to assist the individual in recalling possible instances when an SSN may have been needed (such as when the applicant attended school or applied for admission; registered to vote; held a job; or had a savings account) and to prevent the assignment of an SSN to an individual who is assuming a false identity.
Social Security Numbers Assigned to Citizens of Compact of Free Association Countries
To (1) determine whether SSA is following procedures when issuing SSNs to individuals from Compact of Free Association countries and (2) identify any vulnerabilities in the process.
Individuals who are citizens of Compact of Free Association countries (the Federated States of Micronesia, Republic of the Marshall Islands, and Republic of Palau) may enter, reside in, and work in the United States without regard to immigration laws.
SSA instructions state that a citizen of a Compact of Free Association country in the United States is treated as an alien lawfully admitted for permanent residence.
Their SSN card application should be processed without a legend. However, if the Compact of Free Association applicant resides outside the United States, he/she must provide a valid nonwork reason for an SSN. If the nonwork need is valid, the application is to be processed for a nonwork card.
The evidence required for issuing an SSN is DHS‟ I-94. The I-94 bears an entry date
but no expiration date. Some citizens of Compact of Free Association countries entered the United States before DHS began issuing I-94s for permanent nonimmigrants.
Social Security Numbers Assigned to Exchange Visitors
To (1) assess SSA‟s compliance in assigning SSNs to exchange students and (2)
determine whether vulnerabilities exist in this process that may allow exchange visitors whose immigration status has expired to remain in the United States and improperly continue using their SSNs.
Exchange visitors who enter the United States to take part in an Exchange Visitor program designated by the Department of State are given special immigration status. These exchange visitors usually study; teach; receive training; or, as in the case of the Summer Student Travel/Work program, obtain general employment while being sponsored by an approved organization. Some categories of exchange visitors are automatically authorized to work while others require permission from their sponsors.
SSA policy provides that certain categories of exchange visitors are presumed to have employment authorization, including camp counselors and individuals performing summer work and travel. For the 6-week period ended September 30, 2005, SSA assigned over 31,000 SSNs to individuals who had Exchange Student visas.
State and Local Governments’ Collection, Use, and Disclosure of Social Security Numbers
To assess State, city, and county governments‟ (including K-12 schools) collection,
use, and disclosure of SSNs and any potential risks associated with these practices. Background
SSNs are widely used by Federal, State, and local agencies to provide services and benefits to the public. These agencies use SSNs to manage their records and facilitate data sharing with others. They share SSNs and other personal information to verify eligibility for benefits, collect debts owed the government, and conduct and/or support research and evaluation. In addition to using SSNs