Social Security Numbers: Improved SSN Verification and Exchange
of States' Driver Records Would Enhance Identity Verification
(15-SEP-03, GAO-03-920).
Since September 11, 2001, more attention has been focused on the
importance of identifying people who use false identity
information or documents to obtain a driver license. The Social
Security Administration (SSA) offers states a service to verify
social security numbers (SSNs) collected during the driver
licensing process. This report examines states' use of SSA's
verification service, factors that may affect the usefulness of
the service, and other tools states use or need to verify
identity.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-920
ACCNO: A08412
TITLE: Social Security Numbers: Improved SSN Verification and
Exchange of States' Driver Records Would Enhance Identity
Verification
DATE: 09/15/2003
SUBJECT: Federal/state relations
Fraud
Identity verification
Internal controls
Licenses
Social security number
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GAO-03-920
Report to Congressional Requesters
United States General Accounting Office
GAO
September 2003 SOCIAL SECURITY NUMBERS
Improved SSN Verification and Exchange of States* Driver Records Would
Enhance Identity Verification
GAO- 03- 920
GAO found that 25 states have used either one or both of the methods SSA
offers for requesting SSN verification. Over the last several years,
states used the batch and on- line method to submit over 84 million and 13
million
requests, respectively. Although on- line use has been increasing, usage
varied significantly among states, with 5 out of 18 states submitting over
70 percent of all requests. States decide to use SSA*s service based on
various factors, such as costs and state priorities.
Weaknesses in SSA*s design and management of its SSN verification service
have contributed to capacity and performance problems and limited its
usefulness. While SSA recently increased systems capacity and reduced
outages, problems remain. For example:
The level of service cannot be assessed because SSA has not established
key performance measures. States are concerned that the high verification
failure rate adds to their
workloads. Several states noted that some of the failures could be
prevented if SSA disclosed more information to states. States using the
batch method are vulnerable to licensing individuals
using SSNs of deceased persons because SSA does not match requests against
its death files. In fact, GAO obtained licenses using fraudulent documents
and deceased persons* SSNs in 2 states. Driver licensing agencies rely
primarily on visual inspection of documents
such as birth certificates, driver licenses, and U. S. immigration
documents to verify applicants* identity. While states may use safeguards
beyond visual inspection to verify documents, they lack the ability to
systematically exchange identity information on all drivers with other
states. Without a
means to readily share all driver records, states face a greater risk for
identity theft and fraud in the driver licensing process. A recent
Department of Transportation report to Congress identified options that
would provide states a system for exchanging records on all drivers and
could help mitigate identity fraud.
Example of Identity Information That Driver License May Contain DRIVER'S
LICENSE CLASS BIRTH DATE
NAME ADDRESS ADDRESS
RESTR. HEIGHTWEIGHTSEX TYPEDONOR SP0000 ISSUE DATE
EXPIRES ENDORS. IDENTIFICATION NO. ?
Source: GAO. Since September 11, 2001, more attention has been focused on
the
importance of identifying people who use false identity information or
documents to obtain a driver license. The Social Security Administration
(SSA) offers states
a service to verify social security numbers (SSNs) collected during the
driver licensing process. This report examines states* use of SSA*s
verification service, factors that may affect the usefulness of the
service, and other tools states use or need to verify identity.
GAO recommends that SSA develop performance measures to assess the quality
of its service, develop a strategy to decrease the verification failure
rate, and modify its batch method to match requests
against death records. SSA disagreed on developing performance measures
for this purpose but agreed it should develop a strategy for improving the
verification rate and begin
matching batch requests against death records. However, SSA stated that
limits in law and systems priorities could restrict the actions it could
take.
Given the homeland security implications associated with states* inability
to exchange information on all drivers, GAO recommends that the Congress,
in partnership with the states, consider authorizing the development of a
national data sharing system.
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 920. 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. Highlights of GAO- 03- 920, a report to the
Committee on the Judiciary and the Subcommittee on Social Security,
Committee on Ways and Means, House of Representatives
September 2003
SOCIAL SECURITY NUMBERS
Improved SSN Verification and Exchange of States' Driver Records Would
Enhance Identity Verification
Page i GAO- 03- 920 SSNs and Driver Licensing Letter 1 Results in Brief 2
Background 4 Twenty- five States Have Used SSA*s Verification Service 7
Weaknesses in SSA*s Design and Management of the SSN
Verification Service Has Limited Its Usefulness 11 States May Use
Safeguards Beyond Visual Inspection of Identity Documents, but Lack a
Systematic Means to Share All Driver Records 16 Conclusion 22 Matter for
Congressional Consideration 23 Recommendations 23 Agency Comments and Our
Evaluation 24 Appendix I Scope and Methodology 27
Appendix II Comments from the Social Security Administration 29
Appendix III GAO Contacts and Staff Acknowledgments 33 GAO Contacts 33
Staff Acknowledgments 33 Related GAO Products 34
Figures
Figure 1: States Using SSA*s Verification Services through March 2003 8
Figure 2: SSA*s On- line Transactions, Fiscal Years 1998- 2002 9 Figure 3:
Distribution of On- line Verification Requests, Fiscal Years
1998- 2002 10 Contents
Page ii GAO- 03- 920 SSNs and Driver Licensing Abbreviations
AAMVA American Association of Motor Vehicle Administrators CDLIS
Commercial Drivers Licensing Information System DHS Department of Homeland
Security DOT Department of Transportation NDR National Driver Register
NHTSA National Highway Traffic Safety Administration
SSA Social Security Administration SSN social security number
This is a work of the U. S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.
Page 1 GAO- 03- 920 SSNs and Driver Licensing
September 15, 2003 The Honorable F. James Sensenbrenner, Jr. Chairman
Committee on the Judiciary House of Representatives
The Honorable E. Clay Shaw, Jr. Chairman Subcommittee on Social Security
Committee on Ways and Means House of Representatives
The events of September 11, 2001, focused attention on the importance of
identifying people who use false identity information or documents,
particularly in the driver licensing process. Driver licenses are a widely
accepted form of identification that individuals frequently use to obtain
services or benefits from federal and state agencies, open a bank account,
request credit, board an airplane, and carry on other important activities
of daily living. For this reason, driver licensing agencies are points at
which individuals may attempt to fraudulently obtain a license using a
false name, social security number (SSN), or other documents such as birth
certificates to secure this key credential. Accordingly, states face
increasing pressure to verify the identity information of individuals to
whom they issue licenses.
As the agency responsible for issuing SSNs, the Social Security
Administration (SSA) is uniquely positioned to help states verify the
identity information provided by applicants. To this end, SSA has a
verification service in place that allows state driver licensing agencies
to verify the SSN, name, and date of birth of customers with SSA*s master
file of SSN owners. States can transmit requests for SSN verification in
two ways. One is by sending multiple requests together, called the *batch*
method, to which SSA generally responds within 24 to 48 hours. The other
way is to send an individual request on- line, to which SSA responds
immediately.
To shed light on states* practices for verifying the identity information
of driver license applicants, you asked us to examine: (1) the extent to
which states use SSA*s services to verify the SSNs of driver license
applicants, (2) factors that may affect the usefulness of SSA*s
verification service, and
United States General Accounting Office Washington, DC 20548
Page 2 GAO- 03- 920 SSNs and Driver Licensing
(3) other tools states use or need to verify the identity of driver
license applicants. To conduct our work, we reviewed federal requirements
governing SSN use in the driver licensing process, SSA*s policies for
disclosing information to licensing agencies, information on the operation
of SSA*s verification service, and national data on states* use of the
service. We interviewed key SSA headquarters managers and staff
responsible for the design and oversight of the verification service, as
well as American Association of Motor Vehicle Administrators (AAMVA)
officials responsible for co- managing the on- line verification method
with SSA. 1 To develop in- depth information on specific states* identity
verification practices, we obtained data and interviewed officials from
California, Florida, Georgia, Maine, Maryland, Massachusetts, Ohio,
Pennsylvania, and Tennessee. These states represent a range of identity
verification policies and practices. We also telephoned or visited the
states that did not use SSA*s service to obtain general information about
their
identity verification policies and practices. Finally, we analyzed SSA and
state driver licensing agency data to identify instances of potential
identity fraud involving (1) individuals who used the name and SSN of
deceased
persons and (2) individuals who used fraudulent out- of- state licenses.
We conducted our work from July 2002 through May 2003 in accordance with
generally accepted government auditing standards. For additional details
on our audit approach, see appendix I.
Twenty- five states have used the batch or on- line method to verify SSNs
with SSA, and the extent to which they regularly use the service varies.
About three- fourths of the states that rely on SSA*s verification service
used the on- line method or a combination of the on- line and batch
method, while the remaining states used the batch method exclusively. Over
the last several years, states estimated submitting over 84 million SSN
verification requests to SSA using the batch method compared with 13
million requests submitted using the on- line method. States generally use
the batch method for a short- term period to verify SSNs in their existing
records, while states are more likely to use the on- line service on a
continuous basis. States* use of SSA*s on- line service has increased
steadily over the last several years. However, the extent of use has
varied significantly, with 5 states submitting over 70 percent of all on-
line
verification requests and one state submitting about one- third of the
total. 1 AAMVA is an association that represents motor vehicle
administrators in North America and is a recognized leader in driver
credentialing issues. Results in Brief
Page 3 GAO- 03- 920 SSNs and Driver Licensing
States consider various factors in deciding whether to use SSA*s
verification service. For example, some states that did not use SSA*s
service told us they were reluctant to do so based on performance problems
they had heard were encountered by other states, such as frequent outages
and slowness of the on- line system. States* use of SSA*s service is also
driven by internal policies, priorities, and other concerns. For example,
some states may limit their use to certain targeted populations, such as
where fraud is suspected or for initial licenses, but not for renewals of
in- state licenses.
Weaknesses in SSA*s design and management of its SSN on- line verification
service have contributed to capacity and performance problems. SSA
recently took steps to increase system capacity and to give more
management attention to the service; however, problems remain. In
designing the service, SSA used an available infrastructure to set up the
system and encountered capacity problems, which worsened after the pilot
phase. AAMVA*s data show that, in 1999, the on- line system experienced an
average of three major outages per month, increasing to an average of five
per month in 2000. The capacity problems inherent in the
design of the on- line system have affected states* use of SSA*s
verification service. For example, officials in one state told us that
they have been forced to scale back their use of the system because they
were told by SSA that their volume of transactions was overloading the
system. SSA officials
acknowledged problems stemming from the design and management of the on-
line service and have made some necessary improvements. For example, in
April 2003, SSA completed an upgrade to increase capacity and improve
response times. SSA has also designated a project manager to oversee the
day- to- day management of the service. However, at the time of
our review, SSA still had not established key goals for the level of
service it will provide to driver licensing agencies. SSA has also not
addressed problems regarding the high nonmatch rate and some states*
continued vulnerability to fraud associated with the use of SSNs of
deceased individuals by driver license applicants. These issues may affect
states* willingness to use the service and may also expose them to a
higher risk of fraud. Our own investigators were able to obtain licenses
in two states using a counterfeit out- of- state license and other
fraudulent documents and the SSNs of deceased persons.
While states may use safeguards beyond visual inspection to verify
documents, states lack the ability to systematically exchange identity
information on all drivers with other states. Driver licensing agencies
rely primarily on visual inspection of documents such as birth
certificates,
driver licenses, and immigration documents to verify applicants* identity.
Page 4 GAO- 03- 920 SSNs and Driver Licensing
For example, driver licensing employees look for security features or
other characteristics that indicate authenticity. States may employ more
extensive measures to verify identity information. For example, states may
use independent data sources to corroborate applicants* identity
information and computer systems to identify potential instances of
identity fraud within their respective driver records and to prevent
licensing when key identity information is questionable. Despite these
extra measures, however, states remain vulnerable to identity fraud
because they lack a systematic means to exchange information on all
drivers. States* current means to exchange driver information is limited
to records for commercial drivers and individuals who have lost their
driving privileges. Our analysis in one state showed that licensing
agencies might unknowingly accept false out- of- state licenses as valid
identity documents. However, a joint federal and AAMVA study recently
identified options that if implemented would provide states an exchange
system for all driver records and could help mitigate the vulnerabilities
that exist across states.
This report includes recommendations for SSA to improve the management of
its SSN verification service to make it more useful to driver licensing
agencies. SSA generally agreed with our findings regarding its SSN
verification service and commented that recent improvements
have increased states* use of the service. SSA also noted that its service
only confirms individuals* SSN information and is not a means for
verifying their identity. In response to our specific recommendations, SSA
did not agree that it should develop measures for assessing the quality of
its SSN on- line verification service because the agency did not believe
that
it would result in improved identity authentication. SSA agreed with our
recommendations that it develop a strategy for improving the nonmatch rate
and that it modify the batch process to include a match against its death
records. However, the agency said that factors such as legal restrictions
and limited systems resources could restrict the actions it can take. We
are also presenting a matter for congressional consideration that the
Congress, in partnership with the states, authorize the development of a
national data sharing system for all driver records.
Driver licenses have become widely accepted identity documents because
they generally include features that make them difficult to counterfeit or
alter and may contain identifying information such as the licensees* legal
name, photograph, physical description, and signature. Currently, about
188 million drivers are licensed in the United States, and states issue an
Background
Page 5 GAO- 03- 920 SSNs and Driver Licensing
additional 73 million licenses and identification cards each year. 2
Individuals can apply to obtain licenses at about 3,800 locations across
the United States. 3 Authority for designing and administering driver
licensing programs, as
well as for verifying the identity information of licensees, lies with
individual states. Accordingly, driver licensing agencies face the
challenge of determining whether the identity documents individuals
provide (1) are
authentic and contain information that agrees with the issuing agency*s
records and (2) actually belong to the person presenting them. To promote
uniformity among driver licensing programs, AAMVA provides states with
guidance on documents it recommends as acceptable proof of identity, as
well as best practices for verifying the documents. Not surprisingly, the
SSN is key to any verification process because each SSN is unique to its
owner. 4 In February 2002, we reported that 45 states collect SSN
information from driver license applicants. 5 Individuals obtain SSNs by
applying to SSA and providing evidence of their age, identity, and U. S.
citizenship or lawful alien status. 6 As the agency responsible for
assigning SSNs and issuing social security
cards, SSA provides a service to the states to verify those numbers. SSA
provides two methods for driver licensing agencies to verify SSNs: batch
and on- line. States use the batch method to submit an aggregate group of
SSN requests directly to SSA, and SSA generally responds within 24 to 48
hours. Those states using the on- line method submit individual SSN
2 Identification cards are issued for the sole purpose of identifying the
owner and generally contain the same information as driver licenses but
lack information authorizing the owner to drive. Estimates of the number
of licenses and identification cards issued annually were taken from a
2002 survey conducted by the California Department of Motor Vehicles.
3 Estimates of the number of licensing sites nationwide were provided by
AAMVA. 4 SSN verification primarily serves to corroborate the identity
information submitted by driver license applicants. If the identity
document contains a photograph or biometric
information, licensing employees may visually inspect or electronically
read these data as well as use interviewing techniques to determine if the
documents actually belong to the individual presenting them.
5 See U. S. General Accounting Office, Child Support Enforcement: Most
States Collect Drivers* SSNs and Use Them to Enforce Child Support, GAO-
02- 239 (Washington, D. C.: Feb. 15, 2002).
6 All U. S. citizens can be assigned SSNs. SSA will also assign SSNs to
noncitizens authorized by the Department of Homeland Security to work in
the United States and to noncitizens legally in the country who have a
valid nonwork reason.
Page 6 GAO- 03- 920 SSNs and Driver Licensing
requests and receive immediate *real time* responses from SSA. On- line
users transmit and receive information to and from SSA through a network
maintained by AAMVA. SSA charges states a fee to cover its costs
(basically system processing and personnel) for providing this service.
Batch users pay $0. 0015 per transaction while on- line users are charged
$0.03 per transaction. For fiscal year 2002, the total billings for batch
and on- line users were about $39,000 and $193,000, respectively. SSA
collects payments directly from the batch users, while it bills and
collects
payments from the on- line users through AAMVA. SSA followed Privacy Act 7
requirements in deciding what information it would disclose to driver
licensing agencies. Under its current disclosure policy, if the SSN, name,
and date of birth submitted to SSA by a driver licensing agency match
SSA*s records, SSA will verify the match to the state driver licensing
agency. If one or more elements do not match, SSA will inform the agency
of the nonmatch but will not disclose further information. match only
establishes that the information agrees with SSA*s records and is not
proof that the individual using the SSN is the person to whom SSA assigned
the number.
Beyond SSA*s verification service, the federal government plays a role in
several other key areas of states* driver licensing programs. For example,
within the Department of Transportation (DOT), the National Highway
Traffic Safety Administration (NHTSA) operates the National Driver
Register (NDR), a national database containing identity information on 39
million problem drivers that states are required to use when making
licensing decisions. 8 Also, to remove unsafe commercial drivers from the
highways, the federal government established the Commercial Drivers
License Information System (CDLIS), a nationwide database of 11 million
records that states must use to exchange information on applicants who may
hold commercial licenses in other states or have driving infractions
7 The Privacy Act regulates federal agencies* collection, use, and
disclosure of individuals* personal information and generally prohibits
disclosure of such information without the individuals* consent. The act
authorizes 12 exceptions under which an agency may disclose
information. One exception, *routine use,* allows an agency to disclose
the information if the agency deems the disclosure to be compatible with
the purpose for which it collected the information, and the agency gives
public notice describing the information it plans to disclose. SSA offers
as many as 14 different verification services, each of which is designed
for various requesters (e. g., social service agencies, employers, etc.)
and may make
different disclosures as a result of the verification. 8 Problem drivers
are individuals whose driving privileges have been suspended, revoked, or
canceled for cause or who have been convicted of certain traffic offenses.
Page 7 GAO- 03- 920 SSNs and Driver Licensing
that make them ineligible for licensing. 9 DOT, the federal agency charged
with establishing the CDLIS database, contracts with AAMVA to operate it.
The federal government also provides grants to help states improve their
highway safety programs. Furthermore, states* receipt of federal funds for
their state child support enforcement programs are contingent on the
collection of individuals* SSNs during the driver licensing process. This
provision enables licensing agencies to assist states in locating and
obtaining child support payments from noncustodial parents. Twenty- five
states have used either the batch or on- line verification
method and the extent to which they regularly use the on- line service
varies. 10 States that used the batch method generally use it for a short
period then switch to the on- line process exclusively. Although states*
use of SSA*s on- line service has increased steadily over the last several
years, 5 states submitted over 70 percent of all on- line verification
requests. Factors such as cost, system performance, and individual state
priorities play a role in determining whether states opt to use SSA*s
verification
service and the frequency in which it is used. As of March 2003, driver
licensing agencies in 25 states have used the batch or on- line method to
verify SSNs with SSA. States generally use the batch method for a short-
term period, but states are more likely to use the on- line service on a
continuous basis. About three- fourths of the states that rely on SSA*s
verification service used the on- line method or a combination of the on-
line and batch method, while the remaining states used the batch method
exclusively. (See fig. 1.) Over the last several years, states estimated
submitting over 84 million requests to SSA using the
batch method. 11 Similarly, states submitted a total of 13 million
requests using the on- line method. Two- thirds of these on- line requests
were submitted in the last 2 fiscal years. 12 9 States issue commercial
driver licenses to individuals involved in interstate, intrastate, or
foreign commerce to operate certain types of vehicles such as large trucks
and buses. 10 This report uses the word *states* to refer to the 50 states
and the District of Columbia. 11 SSA did not provide the actual number of
batch transactions. Batch estimates represent data for 1999* 2003. 12 On-
line verification requests represent data for fiscal years 1998- 2002.
Twenty- five States
Have Used SSA*s Verification Service
Twenty- five States Have Used the Batch or On- line Methods
Page 8 GAO- 03- 920 SSNs and Driver Licensing
Figure 1: States Using SSA*s Verification Services through March 2003
SSA officials told us that the batch method offers advantages in
circumstances where a real- time verification response is unnecessary. For
example, some states have used the batch method to *clean- up* SSNs in
their existing records and address any discrepancies prior to the license
coming due for renewal at a later date. A number of states that have used
the batch method in this manner subsequently used the on- line method
States using SSA's Online Verification Service only (14) States using
SSA's Batch Verification Service only (7) States using both SSA's Online
and Batch Verification Service (4) States not using SSA's Verification
Service (26) Alaska
Source: Social Security Administration. Arizona
Alaska Hawaii
Arkansas California
Georgia Illinois Indiana
Iowa Kansas
Kentucky Louisiana
Maine Michigan Minnesota
Mississippi Montana
New York
North Carolina Oklahoma Oregon
Pennsylvania Texas Utah
Vermont New Hampshire Massachusetts Rhode Island Connecticut New Jersey
Delaware Maryland Washington, D. C. West
Virginia Wisconsin
Colorado New Mexico
Alabama Nevada
South Carolina
Florida Virginia
Tennessee North
Dakota South Dakota
Nebraska Wyoming Washington
Idaho Ohio Missouri
Page 9 GAO- 03- 920 SSNs and Driver Licensing
exclusively. For example, one state that used the batch method in 2001 to
verify over 8.3 million existing records has since used the on- line
method exclusively. SSA officials noted that only one state currently uses
the batch method on a continuous basis to verify SSNs for all of its
customers.
For states that issue permanent licenses on the spot, the on- line service
also offers an advantage, namely, the ability to instantly verify the SSN
and other key information submitted by individuals seeking initial
licenses, as well as those converting out- of- state licenses. Between
fiscal years 1998 and 2002, the number of states participating in SSA*s
on- line service grew by about 3 states each year. As shown in figure 2,
the volume of online verification requests processed by SSA has also
increased significantly from 300,000 in fiscal year 1998 to 5.5 million in
fiscal year 2002.
Figure 2: SSA*s On- line Transactions, Fiscal Years 1998- 2002
Although the volume of on- line requests grew between 1998 and 2002, usage
varied significantly among states and within individual states from year
to year. As shown in figure 3, 5 states accounted for over 70 percent of
the total transactions over a 5- year period, and a single state was
responsible for submitting about one- third of the total transactions. In
addition, in some states, the use of the on- line service varied from year
to Extent of States* Use of
the On- line Verification Method Varied
Number of verification requests in millions 0 1
FY1998 (4 states) FY1999
(7 states) FY2000 (11 states) FY2001
(15 states) FY2002 (18 states) 2
3 4
5 6
Source: GAO analysis of SSA data.
Page 10 GAO- 03- 920 SSNs and Driver Licensing year. For example, one
state sent in about 250,000 requests in 1 year and about half that number
the following year.
Figure 3: Distribution of On- line Verification Requests, Fiscal Years
1998- 2002
Various factors* such as costs, performance problems, and state
priorities* may affect states* decisions about whether or not to use SSA*s
verification service. The nonverifying states we contacted frequently
cited
cost as a reason why they did not use SSA*s verification service. In
addition to the per- transaction fees that SSA charges, states may incur
additional costs to set up and use SSA*s service, including the cost for
computer programming, equipment, staffing, training, and so forth. State
estimates associated with establishing an on- line SSN verification
process with SSA varied considerably based on factors such as the system
modifications they planned to make. For example, one state we contacted
estimated that it would cost approximately $770,000 to implement the
online service. Another state estimated that using the on- line service
would have a start- up cost of about $230,000.
Many nonverifying states we contacted expressed a reluctance to use SSA*s
verification service based on performance problems they had heard were
encountered by other states. Some states cited concerns about frequent
outages and slowness of the on- line system. Other states mentioned that
the extra time to verify and resolve SSN problems could States Weigh
Considerations in Deciding to Use SSA*s Verification Service
29%
13 states 5 states
34.4%
Tennessee
9.6%
Massachusetts
9.1%
Ohio
9.1%
Missouri
8.6%
Arizona
71%
Source: GAO analysis of SSA data.
Page 11 GAO- 03- 920 SSNs and Driver Licensing increase customer waiting
times because a driver license would not be issued until verification was
complete.
States* decisions about whether to use SSA*s service, or the extent to
which to use it, are also driven by internal policies, priorities, and
other concerns. For example, some of the states we visited have policies
requiring their driving licensing agencies to verify all customers* SSNs.
Officials in one of these states acknowledged that the growing prevalence
of identity theft and the events of September 11, 2001, directly affected
their decision to begin using SSA*s service. Conversely, another state we
visited that had submitted only 51 transactions over a 3- year period told
us that it was delaying full use of SSA*s service until spring 2003 to
coincide with the roll- out of its new driver- license issuance system.
Finally, we
found that states may limit their use of the on- line method to certain
targeted populations. For example, one state reported that its policy was
to use the on- line method only if fraud was suspected, while another used
the service only for initial licenses and out- of- state conversions, but
not for renewals of in- state licenses.
Weaknesses in the design and management of SSA*s on- line verification
service have contributed to capacity and performance problems and
ultimately limited its usefulness. SSA recently took steps to increase
systems capacity and to give more management attention to the service;
however, problems remain. In designing the system, SSA used an available
infrastructure and encountered capacity problems early on. Although the
problems worsened after the pilot phase, SSA did not monitor or modify the
system to improve its performance. Beyond system design problems, SSA*s
day- to- day management of the service has also been problematic. This
lack of management attention to the service is evidenced by the fact that
SSA has failed to bill and collect in a timely fashion more than
$370, 000 from AAMVA over the last several years. SSA officials have taken
some steps to address system capacity problems, but the agency still lacks
key performance goals for the on- line service. Despite an increased focus
on daily management and oversight of the service, SSA still has not
addressed other problem areas such as a high nonmatch rate or states*
vulnerability to fraud associated with individuals who use the SSNs of
deceased individuals to obtain licenses. These issues may affect states*
willingness to use the service and expose them to a higher risk of fraud.
Weaknesses in SSA*s Design and
Management of the SSN Verification Service Has Limited Its Usefulness
Page 12 GAO- 03- 920 SSNs and Driver Licensing Weaknesses in the design
and management of SSA*s on- line system have contributed to capacity and
performance problems. In designing the
system, SSA connected its server to AAMVA*s network, to which driver
licensing agencies across the country were linked. 13 SSA connected the
two systems using a low- speed data communication line. In 1997, SSA
piloted the on- line service with three states participating. A joint SSA
and AAMVA evaluation of the pilot estimated that the on- line service
could verify 43,200 requests in a 12- hour period or 12.5 million per
year. It was
also estimated that states would submit 7.7 million requests in 1998.
While the system experienced some problems during the pilot* such as slow
response times and outages* SSA expressed confidence that its system would
be sufficient to handle all requests. SSA acknowledged that only limited
capacity testing was done. However, SSA planned to monitor the system*s
performance as needed to ensure it could meet states* needs.
Following the pilot phase, problems worsened as more states began using
SSA*s service. AAMVA*s data show that in 1999 the system experienced an
average of three major outages per month, increasing to an average of five
per month in 2000. More recent AAMVA data showed that from August 2002
through March 2003, outages continued to occur frequently and lasted from
about 30 minutes to as long as 1 day. Such outages can affect customer
service because employees in one state told us that when the
service is down, they cannot process customers* transactions. However,
because SSA did not collect or monitor performance data on response times
and outages, SSA did not know the magnitude or specifics of the problem.
The capacity problems inherent in the design of the on- line system have
affected states* use of SSA*s verification service. Officials in one state
told us that they have been forced to scale back their use of the system
because they were told by SSA that the volume of transactions was
overloading the system. In addition, AAMVA representatives told us that
because of concerns about performance and reliability, they have not
allowed new states to use the service since the summer of 2002. At the
time of our review, 10 states had signed agreements with SSA and were
waiting to use the on- line system, and 17 states had received funds from
13 AAMVA*s network serves as the conduit for transmitting verification
requests from individual state driver licensing agencies to SSA, as well
as receiving verification responses from SSA and transmitting them to
individual states. The Design and
Management of the On- line System Contributed to Capacity and Performance
Problems
Page 13 GAO- 03- 920 SSNs and Driver Licensing DOT for the purpose of
verifying SSNs with SSA. 14 It is uncertain how many of the 17 states will
ultimately opt to use SSA*s on- line service.
However, even if they signed agreements with SSA today, they may not be
able to use the service until the backlog of waiting states is addressed.
In addition to design weaknesses, SSA did not sufficiently focus on the
management of its service. In particular, SSA previously lacked a
designated person to oversee the day- to- day operations of the service
and to coordinate with AAMVA on various management issues. As a result,
AAMVA lacked a focal point within SSA to resolve persistent performance
problems that arose with the system. AAMVA officials told us they would
start by calling SSA*s general help desk, as directed by SSA, but would
end up calling several different components within the agency. This
situation impeded the timely and effective resolution of problems
necessary to meet states* verification needs. SSA*s lack of management
attention to the service is also evidenced by the fact that the agency
failed to timely bill and collect fees from AAMVA over the last several
years. Each year SSA is required to reach agreement with AAMVA on the per
transaction cost of its
service. However, for several years SSA and AAMVA have not done this.
Under the agreement, SSA is also required to send AAMVA a final billing
each year based on the number of transactions processed. SSA billed and
collected payments from AAMVA for the first 2 fiscal years* 1997 and 1998.
However, between fiscal years 1999 and 2002, SSA failed to bill and
collect more than $370,000 it calculated as being due from AAMVA.
SSA and AAMVA officials have acknowledged problems stemming from the
design and management of the on- line service and have made some necessary
improvements. For example, according to SSA, in April 2003 the service
began using software that AAMVA recently revised to increase the volume of
transactions states could submit and receive through AAMVA*s network.
About the same time, SSA completed an upgrade of its data communication
line and server to enhance its system capacity and response time. SSA
officials told us these upgrades should reduce outages and enhance
performance. SSA provided us with information showing that in May 2003, 2
states had increased their volume of transmissions and an additional 3
states had begun using the service. SSA plans to add 4 new states that are
currently testing the on- line system. AAMVA estimates that
14 Included in the 10 states that have signed agreements with SSA and the
17 that received DOT funding are 6 batch states. Of the 25 states that
received DOT funding, 17 were not online users.
Page 14 GAO- 03- 920 SSNs and Driver Licensing 2003 verification requests
may increase to 28 million, more than five times the number received in
2002. Despite this projection, however, at the time
of our review, SSA still had not established key goals for the level of
service it will provide driver licensing agencies. SSA officials told us
they are currently monitoring the volume of transactions and response
times as new states are added. However, until SSA establishes key goals,
the quality and effectiveness of SSA*s on- line service cannot be fully
assessed. More recently, SSA also designated a project manager responsible
for overseeing the day- to- day operation of its service, as well as an
individual responsible for the billing and collection of AAMVA payments.
At the time
of our review, SSA had collected $330,000 from AAMVA for fiscal years
1999- 2002. 15 SSA officials told us that they are in the process of
updating the cost estimates and payments for fiscal year 2003.
Despite SSA*s recent efforts to focus more management attention on its
verification service, problems regarding the high nonmatch rate and
states* continued vulnerability to fraud associated with the use of SSNs
of deceased individuals by driver license applicants remain. These
problems pose a concern for states because of the additional workloads
associated with resolving discrepancies between SSA and states* driver
records as well as the potential for identity theft. SSA*s data over the
last 5 years show that an average of 11 percent of all transactions
submitted by states failed to verify with SSA*s records. Some states have
experienced nonmatch rates as high as 30 percent. In fiscal year 2002,
about 800,000 records failed verification. Generally, about one- half of
these failed because the name submitted with the SSN did not match the
name in SSA*s records. Such mismatches may occur, for example, if a
person*s SSN record lists a maiden name, but the person is applying for a
license under a married name. The states and AAMVA have voiced their
concerns to SSA about the need for additional disclosure of information.
In a May
2001 letter to one state, SSA*s Acting Deputy Commissioner specified the
agency*s disclosure policy for driver licensing agencies and stated that
SSA closely scrutinizes requests involving SSN use for purposes not
related to the Social Security program. In doing so, SSA has decided to
provide its verification service in a limited manner by informing driver
licensing agencies which data elements match or do not match. 15 According
to AAMVA, in May 2003 it paid SSA the remaining amount owed. SSA Has Not
Focused on
Other Key Weaknesses in the Service It Provides States
Page 15 GAO- 03- 920 SSNs and Driver Licensing State concerns about the
potential workloads associated with resolving nonmatch issues may affect
their willingness to fully use SSA*s service.
Officials in one state told us that a planned start up of the on- line
service may be delayed due to concerns about the high nonmatch rate they
have experienced using SSA*s batch service. Officials in another state
indicated
that they have not done a batch clean up of their existing databases
because they are unable to devote the additional funding and staff
resources to address nonverification issues. SSA officials told us that
they are aware of states* concerns and have recently begun discussions to
address disclosure issues with the states.
In reviewing SSA*s verification service, we also identified a key weakness
in the batch method that exposes states to a higher risk of fraud by
allowing them to inadvertently issue licenses to individuals using the
SSNs of deceased individuals. Unlike the on- line service, SSA does not
match batch requests against its death records. As a result, the batch
method will not identify and prevent the issuance of a license in cases
where an SSN of a deceased individual is being used. SSA officials told us
that they initially developed the batch method several years ago, and they
did not design the
system to match SSNs against its death files. However, a death match was
built into the on- line system. At the time of our review, SSA
acknowledged that it had not explicitly informed states about the
limitation of the batch service.
Our own analysis of 1 month of SSN transactions submitted to SSA by one
state using the batch method identified at least 44 cases in which
individuals used the SSN, name, and date of birth of persons listed as
deceased in SSA*s records to obtain a license or an identification card.
16 We forwarded this information to state investigators who quickly
confirmed that licenses or identification cards had been issued in 41
cases and were continuing to investigate the others. To further assess
states* vulnerability in this area, our own investigators, working in an
undercover capacity, were able to obtain licenses in two batch states
using a counterfeit out- of- state license and other fraudulent documents
and the SSNs of deceased persons. In both states, driver licensing
employees accepted the documents we submitted as valid. Our investigators
completed the transactions in one state and left with the new valid
16 SSA*s death records may contain inaccuracies because SSA records all
reports of death but only verifies those involving benefit payments.
Page 16 GAO- 03- 920 SSNs and Driver Licensing license. 17 In the second
state, the new permanent license arrived by mail within weeks. The ease in
which they were able to obtain these licenses
confirmed states* vulnerability to accepting fraudulent documents, and for
those states that use SSA*s batch process, to issuing licenses to
individuals using SSNs of deceased individuals. SSA officials have told us
that the agency has not made a decision about whether the current batch
system will be modified to include a death match.
Our field work shows that licensing officials in states that use or have
used the batch process were often unaware that SSA did not match SSNs
against its death records. As a result, these states lacked information
that they could have used to make more informed decisions in choosing
either the batch or on- line method or to seek alternative strategies to
avoid issuing licenses to individuals using SSNs of deceased persons.
Moreover, states that have used the batch method in prior years to clean
up their records and to verify the SSNs of millions of driver license
holders, may have also unwittingly left themselves open to identity theft
and fraud.
States may use tools beyond visual inspection to verify documents, but
lack the ability to systematically exchange identity information on all
drivers with other states. Although driver licensing agencies rely
primarily on visual inspection of documents to verify applicants* identity
information, states may employ more extensive measures such as using
independent sources to corroborate applicants* identity information.
Despite the extra measures, states remain vulnerable to identity fraud
because they lack a systematic means to exchange information on all
drivers. As a result, states may unknowingly accept false out- of- state
licenses as valid identity documents or license individuals who use the
identity information of others.
In the states we visited, driver- licensing agencies rely primarily on
visual inspection to determine the authenticity of documents provided by
applicants. As proof of identity, applicants must present one or more
stateapproved documents that are generally inspected by staff. Applicants
may present a variety of documents, such as a social security card, a U.
S. birth
17 This state does not use SSA*s batch verification process for initial
licenses, but only for license renewals. Therefore, the use of the
deceased person*s SSN will not be caught when the state ultimately
verifies it using the batch method. States May Use
Safeguards Beyond Visual Inspection of Identity Documents, but Lack a
Systematic Means to Share All Driver Records
Visual Inspection of Documents Is a Primary Practice for Verifying
Identity
Page 17 GAO- 03- 920 SSNs and Driver Licensing certificate, a driver
license from another state, or passport. For noncitizen applicants, staff
also review a myriad of passports and U. S. immigration
documents. In reviewing identity documents, staff look for security
features such as watermarks and raised seals that are difficult to
counterfeit and are designed to reveal evidence of tampering. They also
inspect documents for other indications of authenticity such as signs of
appropriate aging. If employees are unsure if a particular document is
authentic or if it actually belongs to the applicant, they may use
interviewing techniques to ensure that the individual can corroborate key
information.
In the states we visited, staff responsible for processing driver license
applications generally received some training and basic assistance to
support the visual inspection. For example, all of the states provided
training to help employees distinguish between authentic and fraudulent
documents. This generally occurred once or twice a year and was sometimes
presented as part of a larger training module covering other policies and
procedures of the agencies. In addition to training, office managers and
supervisors with more experience in detecting false documents were
available on site to help with the visual inspection if needed. In several
states, supervisors and office managers told us that they have directly
contacted issuing agencies to determine whether documents, such as birth
certificates, were valid. However, this was not routinely done because it
can be a time- consuming and labor- intensive process. Nearly every state
we visited provided staff with some basic tools to help with the visual
inspection, such as reference manuals describing the security features
included in various state and federal government issued identity
documents. Other tools such as black lights and magnifying glasses were
also commonly available to help staff view the security features embedded
in certain documents. However, we found that the extent to which staff
actually used these tools varied.
Despite the training and other measures to aid visual inspection, these
approaches are often not enough for employees to make a definitive
determination of a document*s authenticity. Staff and managers we
interviewed frequently expressed concern that the variety of valid state
birth certificates, social security cards, out- of- state licenses and
immigration documents, made it extremely difficult to catch those that are
Page 18 GAO- 03- 920 SSNs and Driver Licensing forged, short of them being
obvious fakes. 18 They also frequently expressed a need for better access
to automated means of verifying these documents.
Because of the vulnerabilities associated with the visual inspection of
documents, states employ more extensive safeguards to better deter and
detect identity theft and fraud. These include seeking out independent
third- party data sources to corroborate identity information and
documents provided by driver license applicants, utilizing computer
systems to strengthen the integrity of their licensing process, and using
other innovative tools to better verify applicants* identity information
and deter fraud. At the time of our review, a number of states we visited
were either using or pursuing the use of other tools to electronically
verify identity
information with issuing agencies and other independent third parties.
Officials in several states we visited told us that they wanted access to
the Department of Homeland Security (DHS) 19 immigration information to
verify the identity documents of noncitizen applicants. Further, a state
with a large immigrant and noncitizen population had contracted with DHS
to routinely authenticate immigration documents and other information
relevant to a person*s citizenship and immigration status. 20 A second
state was in the process of negotiating access to these records. Statewide
birth and death information was also viewed by state administrators as key
to the identity verification process. Accordingly, several of the states
we visited have periodically used electronic queries or data matches to
access birth or death records.
Three of the nine states we visited were pilot- testing or considering the
use of private vendors to strengthen their identity verification and fraud
detection procedures. These private vendors typically access various
information sources, including civil and criminal records, credit
18 SSA has issued 53 versions of the social security card. Those issued
before 1983 lack counterfeit- resistance and tamper proof security
features. When issuing new versions of the social security card, SSA
allows prior versions to remain valid because issuing new cards to all
number holders would be costly. U. S. birth certificates, issued by each
of the 50 states and the District of Columbia and in some cases by local
government units within
the state, vary according to the provisions of the issuing government
unit. 19 The former Immigration and Naturalization Service has been
transferred to DHS. 20 In some states, noncitizens must document that they
have a legal presence in the United States, as well as proof of their
identity, as a condition for receiving a license. States Employ Additional
Safeguards to Verify Identity and Prevent Fraud
Page 19 GAO- 03- 920 SSNs and Driver Licensing information, address
information, state driver records, and state birth and death data to help
driver licensing agencies corroborate information
provided by applicants and correctly issue licenses. At the time of our
review, one state was pilot- testing on- line access to a private vendor
in a limited number of sites. AAMVA officials did not have national data
on the extent to which other states are using innovative third- party
verification tools to strengthen the integrity of their licensing
procedures. However, they generally noted that such practices are not
routinely used to supplement states* primary practice of visually
inspecting documents.
Several states we visited made extensive use of computer systems to
prevent identity theft and fraud. Several states have computer systems
capable of screening for multiple individuals in their state with the same
or similar identity information. For example, one state*s computer system
automatically cross- matches first- time applicants* personal information
against existing driver records in the database to search for such
situations. When states do not have the capability to routinely perform
such cross- matches, employees may inadvertently issue licenses to
individuals who may be using the identity information of someone the state
has previously licensed.
Some states* computer systems are designed to prevent the issuance of a
license in certain high- risk situations. For example, one state*s system
terminates the processing of a transaction if identity information does
not verify with SSA, or if staff attempt to by- pass this verification
step. Staff are also prevented from overriding the system and issuing the
license unless an authorized person* generally a higher- level official*
intervenes. Similarly, some states had systems that could prevent issuance
of a license if an individual*s personal information already existed in
the states* driver records, or DHS information failed to verify. Further,
in cases where fraud
is suspected, most states* systems* although not all* are capable of
flagging the transaction and automatically transmitting this information
to other offices within the state to prevent persons from *shopping* sites
once they were denied at the first location. Officials in one state that
lacked this protection told us that in cases of suspected fraud, staff
relied on manual processes such as telephone calls and e- mails to alert
other offices about suspicious individuals and false documents.
Finally, to varying degrees, the states we visited have instituted
additional controls to better address identity theft and fraud issues. Due
to concerns about the quality and integrity of other state licensing
systems, three states prohibit or limit the acceptance of out- of- state
licenses as a sole or primary identity document. Officials from another
state told us that they
Page 20 GAO- 03- 920 SSNs and Driver Licensing would not accept such
documents from 20 states that they have determined to have less stringent
verification processes. A few other
states have also instituted policies requiring that two employees review
or sign- off on the authenticity of documents provided by applicants
before a license can be issued. This separation of responsibilities
provides for additional scrutiny of documents and may act as a further
check against employee fraud. Another common practice among several states
was to
copy all identity documents if during the application process, fraud was
suspected. This provides the licensing agency with key information for
investigating the individual*s alleged identity. An official in one state
told us that staff are trained to collect and copy identity documents
upfront regardless of whether fraud is suspected at the time.
All nine states we visited also store and transmit information such as
digital photographs and signatures for verification purposes. Two states
also captured fingerprints at the time of application, but only one of
them used biometric technology to electronically verify this identity
information for individuals renewing licenses. Another safeguard used by
two states is the issuance of temporary licenses when identity information
has not been corroborated at the time of application. Such licenses lack
photographs
and security features common to permanent licenses or clearly state that
they are not valid for identity verification purposes. However, a third
state*s temporary license looks the same and includes identical
information as its permanent license. As a result, this license could
continue to be presented as an identity document by individuals even if
the circumstances under which it was issued are ultimately determined to
be fraudulent. Despite the additional safeguards taken by some states,
licensing agencies lack a systematic means to exchange information on all
drivers nationwide, limiting their ability to deter identity theft and
fraud. Currently, states have automated access and are required to use the
NDR, which is a DOT database of 39 million problem drivers. With this
system, licensing agencies have the ability to simultaneously query all 50
states to determine whether an applicant*s name appears in the database.
For commercial drivers, states obtain information on their licensing,
identification, and disqualification from the CDLIS database of 11 million
records. States are required to input driver information into CDLIS and to
use the system to verify commercial driver record information during the
licensing process. States Lack a Systematic
Means to Exchange Records on All Drivers
Page 21 GAO- 03- 920 SSNs and Driver Licensing Because the NDR and CDLIS
target specific driver populations and do not include the records and
identity information of the approximately
188 million drivers operating in the United States, state driver licensing
agencies lack a single inquiry process to determine whether or not a
person has ever been issued a license. Numerous officials in the states we
visited told us that having a more efficient means of electronic
interstate communications, that included the electronic transfer of
identity information such as digital photographs and signatures, would
improve the integrity of their licensing process. Officials in the states
we visited were particularly concerned about individuals using licenses
issued by other states as identity documents and their inability to
quickly query all states* databases to corroborate key information. As a
result, states are limited in their ability to determine whether other
states* identity documents are authentic or to identify multiple
individuals using the same personal identifying information in other
states.
Our analysis of one state*s data demonstrates the potential
vulnerabilities driver licensing agencies currently face when accepting
out- of- state licenses as proof of identity. We examined data from one
state*s internal state cross- match of its existing driving records and
identified numerous instances where the same out- of- state license number
had been used by multiple individuals with different names and dates of
birth to apply for
and obtain a new license. We forwarded about 100 of these license numbers
to the alleged issuing state and asked them to provide us with key
information on the owner of record. We found 96 cases of potential
identity fraud involving 52 of the driver licenses numbers. For example,
states reported some license numbers as invalid or as being issued to
someone other than the persons that had used them. One state reported back
that the license number we submitted to them was actually a zip code,
rather than a genuine state- issued license number. Another license was
reported by the issuing state to be a valid number that had been
counterfeited and used in several states.
A July 2001 report to the Congress prepared by DOT in cooperation with
AAMVA, identified alternatives to improving state data exchanges and
discussed various options for change. 21 The specialized nature of NDR and
CDLIS does not allow states to verify licenses for all drivers* a means to
21 U. S. Department of Transportation, NHTSA in conjunction with Federal
Motor Carrier Safety Administration and American Association of Motor
Vehicle Administrators, Report to Congress: Evaluation of Driver Licensing
Information Programs and Assessment of Technologies. (July 2001).
Page 22 GAO- 03- 920 SSNs and Driver Licensing identify potential identity
fraud. However, the report concluded that an alternative system
encompassing all driver records could operate
efficiently using existing programs developed for CDLIS and on hardware
that is currently in use. However, the report also concluded that before
such a system could be developed, several potential obstacles should be
addressed. These include agreeing on the use of a unique identifier by
which to query all state driving records, ensuring that all states
participate, defining the role of the federal government, and funding the
costs of developing and converting to an all- driver system. The report
also acknowledged that state resources for development and implementation
would be necessary to cover projected costs, which AAMVA has estimated to
be about $78 million over 3 years. However, the report concluded that,
once operational, user fees similar to those imposed for CDLIS could be
levied by states to cover operational expenses.
The driver license is a key identity document that can be used by
individuals to obtain a range of public and private services nationwide.
Accordingly, state driver license agencies face a daunting task in
ensuring that the identity information of those to whom they issue
licenses is verified. However, states* effectiveness in this area is often
dependent on several factors, including the receipt of timely and accurate
identity
information from SSA, the extent to which they implement additional
identity verification and fraud detection tools, and their ability to
quickly and systematically share key driving record information with other
state licensing systems. Deficiencies in any of these areas may weaken
states* efforts to ensure the integrity of their licensing decisions.
Unfortunately, design and management weaknesses associated with SSA*s
verification service have limited its effectiveness. States that are
unable to take full advantage of the service and others that are waiting
for the
opportunity to use it remain vulnerable to identity theft and fraud. SSA*s
recent efforts to refocus management attention on improving its service
represents a positive step and may be key to moving more state licensing
agencies away from processes that rely heavily on fraud- prone visual
inspections of identity documents, to one in which information such as an
individual*s SSN, name, and date of birth can be quickly and independently
corroborated. However, sustained attention to improving its service is
needed. Furthermore, states that continue to rely primarily or partly on
SSA*s batch verification service still risk issuing licenses to
individuals using the SSNs and other identity information of deceased
individuals. This remains a critical flaw in SSA*s service and states*
efforts to strengthen the integrity of the driver license. Conclusion
Page 23 GAO- 03- 920 SSNs and Driver Licensing Since September 11th, more
state driver licensing agencies have begun to reassess their prior view
that driver licenses are simply an authorization to operate a motor
vehicle and have taken aggressive actions to strengthen
the integrity of this important identity document. However, licensing
programs remain state- administered and may vary considerably in the tools
provided to front- line staff to verify identity information, such as
access to automated independent third- party data sources. This has
potentially serious consequences for the numerous public and private
sector service providers who rely on the driver license as an identity
document, but may be unaware that not all states* licenses are equal in
terms of the integrity of the identifying information included on them.
Beyond the actions taken by individual states, coordination and data
sharing is key to addressing many of the factors that allow identity theft
and fraud to continue in the driver licensing process. No single state has
overarching authority to require information sharing nationwide, define
minimum standards for proof of identity, or mandate the development of a
systematic means for interstate communication. However, cooperative
efforts between the federal government, the states, and AAMVA have
identified and facilitated technological options for improving the
exchange of driver record data among all states. We recognize that
potential barriers related to system*s design, funding, privacy rights,
and states* willingness to use such a tool have yet to be fully resolved.
However, given the potential economic and national security implications
associated with identity theft at the point of driver licensing, sustained
leadership at the federal level could be the catalyst for needed change.
In light of the homeland security implications associated with states*
inability to systematically exchange driver license identity information
and the need for sustained leadership in this area, the Congress, in
partnership with the states, should consider authorizing the development
of a national data sharing system for driver records.
Considering the significant increase in the number of on- line requests
that SSA anticipates receiving from states, as well as the weaknesses that
we identified in SSA*s service that may increase states* vulnerability to
identity fraud, we recommend that the Commissioner of Social Security take
the following actions:
Develop performance measures essential to assessing the quality of the
service provided. Matter for
Congressional Consideration
Recommendations
Page 24 GAO- 03- 920 SSNs and Driver Licensing Develop a strategy for
improving the nonmatch rate for SSA*s verification service. This should
include identifying additional information it can
reasonably and legally disclose to state driver- licensing agencies as
well as actions states can take to prevent nonmatches.
Modify SSA*s batch verification method to include a match against its
nationwide death records.
We obtained written comments on a draft of this report from the
Commissioner of SSA. SSA*s comments are reproduced in appendix II. SSA
also provided additional technical comments, which we incorporated in the
report as appropriate. We also requested that AAMVA officials
review the technical accuracy of our discussion of AAMVA*s role in the SSN
verification process, as well as our characterization of states* identity
verification and fraud prevention activities. We incorporated AAMVA*s
comments in the report as appropriate. SSA generally agreed with our
findings regarding its SSN verification service and said that recent
improvements have increased states* use of the service. The agency noted
that it is continuing to investigate the sequence of events surrounding
our ability to obtain driver licenses with counterfeit documents and the
SSNs of deceased individuals. SSA also said that its service only offers
confirmation that SSNs and other identity information provided by driver
license applicants are consistent with its records and should not be
perceived as a means for verifying identity. Also, SSA said that any
attempts to reduce the nonmatch rate for its service by relaxing the match
criteria would be inconsistent with the need for *tighter match
requirements* and increased security in the post 9/ 11 era. We agree that
SSA*s service does not allow states to definitively determine the identity
of driver license applicants and have made small changes to ensure that
our report will not be misinterpreted. However, we continue to believe
that the verification service, in combination with other verification
tools used by the states, is key to corroborating the identity information
presented by driver license applicants. We also are not suggesting that
SSA compromise the integrity of its verification service in order to
reduce the nonmatch rate. However, our report shows that about half of all
verification failures are for name mismatches. Such mismatches are thought
to commonly occur due to changes in marital status. We continue to believe
that opportunities exist for SSA to work with the states to explore
options for addressing this issue and to ultimately improve the overall
quality of its service. Agency Comments
and Our Evaluation
Page 25 GAO- 03- 920 SSNs and Driver Licensing In response to our specific
recommendations, SSA disagreed that it should develop measures for
assessing the quality of its SSN on- line verification
service. Instead, SSA said that it plans to develop a performance baseline
for enumeration accuracy to measure whether applicants were entitled to
receive an SSN based on supporting documentation. SSA did not believe
that developing performance measures specifically for its verification
service would result in improved identity authentication. However, we
continue to believe that the verification service, in combination with
other tools used by the states, is key to corroborating driver license
applicants* identity information. As our report notes, performance
concerns and
issues often affected the extent to which states used SSA*s verification
service, or whether they opted to use the service at all. Thus, some
states lacked a key tool for corroborating the identity information of
driver license applicants. We continue to believe that SSA should develop
measures for its service to monitor and assess systems availability,
outages, response times and other key aspects of performance. Without such
measures, SSA lacks a means to identify performance problems and take
corrective actions when needed.
SSA agreed with our recommendations that it develop a strategy for
improving the nonmatch rate for its service and that it modify the batch
process to include a match against its death records. However, the agency
said that factors such as legal restrictions on the information it may
disclose to states and limited systems resources could restrict the
actions it can take. Indeed, we encourage SSA to work within the existing
law to develop policies to reduce nonmatches and to better assist states
when they occur. Also, in view of states* vulnerability to licensing
individuals using deceased persons* SSN information and the volume of
batch verification requests submitted to SSA by the states, we believe
immediate action is needed.
We are sending copies of this report to the Commissioner of SSA and other
interested parties. Copies will also be made available to others upon
request. In addition, the report will be available at no charge on GAO*s
Web site at http:// www. gao. gov. If you have any questions concerning
this
Page 26 GAO- 03- 920 SSNs and Driver Licensing report, please call me on
(202) 512- 7215. The major contributors to this report are listed in
appendix III.
Barbara D. Bovbjerg Director, Education, Workforce,
and Income Security Issues
Appendix I: Scope and Methodology Page 27 GAO- 03- 920 SSNs and Driver
Licensing This appendix provides additional details about our analysis of
the Social Security Administration*s (SSA) verification services and
states* practices for verifying the identity of driver license applicants.
To attain our
objectives, we obtained and reviewed various reports related to the issue
of identity verification from state auditors, SSA*s Office of Inspector
General, and the American Association of Motor Vehicle Administrators
(AAMVA). We reviewed federal requirements governing social security number
(SSN) use in the driver licensing process, SSA*s policies for disclosing
identity information to licensing agencies, and numerous verification
agreements between SSA and the states. We analyzed nationwide data on
states* use of SSA*s verification service, including the volume of records
submitted, trends in usage, and the rate at which SSNs failed to verify
between October 1997 through May 2003. 1 We interviewed SSA officials
responsible for the SSN verification data with regard to the reliability
of the data, and determined the data to be sufficiently reliable for our
reporting purposes. We telephoned or visited states that were not using
SSA*s service to obtain general information about their identity
verification practices, as well as their plans for using SSA*s service in
the future.
To obtain more specific information on the design and management of SSA*s
batch and on- line verification service, we interviewed key SSA line and
management officials as well as AAMVA officials responsible for comanaging
the on- line service. We also reviewed an SSA/ AAMVA evaluation of a pilot
of the on- line method. 2 To determine batch service states*
vulnerability to individuals who may use deceased persons* SSNs to obtain
a license, we matched approximately 500,000 batch verification requests
submitted by one state for the month of December 2002 against SSA*s Master
Death file. 3 We identified 44 instances in which SSA verified an SSN
submitted by the state that matched an SSN in the death record where the
death occurred before December 2002. In order to determine whether these
individuals actually received a license or identity card, we submitted
1 *States* for the purposes of this report is defined as the 50 states
plus the District of Columbia. 2 Evaluation of the Social Security Number
Online Verification System for the American Association of Motor Vehicle
Administrators, Social Security Administration (Jan. 1998). 3 These
transactions include any transaction where an SSN was collected from an
applicant
(i. e., issuance of licenses, IDs, motor vehicle registration, etc.). SSA
maintains a death master file containing about 70 million records of
persons who have been reported to the agency as being deceased. SSA only
verifies the deaths of persons if it needs to make
benefit decisions. The Master Death File for this review was current as of
January 31, 2003. Appendix I: Scope and Methodology
Appendix I: Scope and Methodology Page 28 GAO- 03- 920 SSNs and Driver
Licensing the 44 cases to the state licensing agency for its review. The
state officials confirmed that licenses or identification cards had been
issued in 41 cases
and are currently reviewing the remaining cases. Because we selected a
judgmental sample of cases to review, our findings are not generalizable
to the entire state over time or to any other state.
To gain more in- depth information on specific challenges states may
encounter in their efforts to verify applicant identity documents, as well
as their policies and procedures for doing so, we conducted field work in
California, Florida, Georgia, Maine, Maryland, Massachusetts, Ohio,
Pennsylvania, and Tennessee. At these locations we interviewed key
management and line staff and obtained data and documents relative to
their verification processes and tools. We selected states that were
geographically dispersed to obtain a mix that (1) did, and did not, issue
temporary licenses before issuing permanent licenses, and (2) have, and
have not, used one or both of SSA*s verification services. We also chose
some states that had large immigrant populations or were identified as
using innovative practices to verify identity. We also interviewed and
obtained information from representatives of private businesses that offer
commercial services to assist driver licensing agencies in verifying
identity information.
Finally, to assess states* vulnerability to accepting fraudulent out- of-
state driving licenses as an identity document, we used one state*s
listing representing numerous instances where the same out- of- state
license number was used multiple times to obtain a license in another
state. We selected about 100 cases where the name and date of birth of the
individual were clearly different from one record to the next and
submitted about 100 of them to the original issuing states. We obtained
information from the states identifying the name and date of birth of the
owner of the driver license to determine whether there was possible
identification fraud. We conducted internal reliability checks for data
received from state driver licensing agencies. Because we selected a
judgmental sample of cases to review, our findings are not generalizable.
We conducted our work from July 2002 through May 2003 in accordance with
generally accepted government auditing standards.
Appendix II: Comments from the Social Security Administration Page 29 GAO-
03- 920 SSNs and Driver Licensing Appendix II: Comments from the Social
Security Administration
Appendix II: Comments from the Social Security Administration Page 30 GAO-
03- 920 SSNs and Driver Licensing
Appendix II: Comments from the Social Security Administration Page 31 GAO-
03- 920 SSNs and Driver Licensing
Appendix II: Comments from the Social Security Administration Page 32 GAO-
03- 920 SSNs and Driver Licensing
Appendix III: GAO Contacts and Staff Acknowledgments
Page 33 GAO- 03- 920 SSNs and Driver Licensing Barbara Bovbjerg, Director,
(202) 512- 7215 Daniel Bertoni, Assistant Director, (202) 512- 5988
Jacquelyn Stewart, Analyst- in- Charge, (202) 512- 7232
In addition to those named above, the following team members contributed
to this report throughout all aspects of its development: Raun Lazier,
Caterina Pisciotta, and Dorothy Yee. In addition, Daniel Schwimer, Mary
Dorsey, Shana Wallace, Raymond Wessmiller, and Corrina Nicolaou made
contributions. Appendix III: GAO Contacts and Staff
Acknowledgments GAO Contacts Staff Acknowledgments
Related GAO Products Page 34 GAO- 03- 920 SSNs and Driver Licensing Social
Security Numbers: Ensuring the Integrity of the SSN. GAO- 03- 941T.
Washington, D. C.: July 10, 2003.
Social Security Numbers: Government Benefits from SSN Use but Could
Provide Better Safeguards. GAO- 02- 352. Washington, D. C.: May 31, 2002.
Social Security Numbers: SSNs Are Widely Used by Government and Could Be
Better Protected. GAO- 02- 691T. Washington, D. C.: April 29, 2002. Child
Support Enforcement: Most States Collect Drivers* SSNs and Use
Them to Enforce Child Support. GAO- 02- 239. Washington, D. C.: February
15, 2002.
Responses to Questions From May 18th Hearing on Uses of Social Security
Numbers. HEHS/ AIMD- 00- 289R. Washington, D. C.: August 21, 2000.
Social Security Numbers: Subcommittee Questions Concerning the Use of the
Number for Purposes Not Related to Social Security. HEHS/ AIMD- 00- 253R.
Washington, D. C.: July 7, 2000.
Social Security: Government and Other Uses of the Social Security Number
are Widespread. GAO/ T- HEHS- 00- 120. Washington, D. C.: May 18, 2000.
Social Security: Use of the Social Security Number is Widespread. GAO/ T-
HEHS- 00- 111. Washington, D. C.: May 9, 2000.
Social Security: Government and Commercial Use of the Social Security
Number Is Widespread. GAO/ HEHS- 99- 28. Washington, D. C.: February 16,
1999. Related GAO Products
(130178)
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