CITIZENS
for
Limited Taxation & Government
Post Office Box 408 Peabody, Massachusetts
01960 (508) 384-0100
E-Mail: cltg@cltg.org
Web-page: http://cltg.org
The SSN and enumeration process
of the Social Security Administration (SSA)
Information About the Use of the SSN (Social Security Number) as a Personal IdentifierThe SSA has always taken the position that the SSN is not a personal identifier. When the Social Security law was passed in 1935, the SSN was called the Social Security Account Number and was meant to identify the account, not the person. However, in practice, the SSN has been adopted for numerous identification purposes outside of the Social Security system.
In 1943, President Franklin D. Roosevelt signed an Executive Order requiring Federal agencies to use the SSN as an identifier for any new record systems. The Department of Defense used the SSN as a military identification number during World War II and adopted it officially in 1967 as an Armed Services personnel identifier.
In 1961, the Civil Service Commission adopted the SSN as an official Federal employee identifier, and in 1962 the Internal Revenue Service adopted it as the taxpayer identification number.
In the 1960s, the Treasury Department required buyers of Series H savings bonds to provide their SSNs and again in the 1970s required it for the purchase of Series E savings bonds.
The SSN was selected in the 1960s as the Medicare health insurance number, with an alphabetic character appended to designate the beneficiary’s relationship to the wage earner on whom benefits are based.
In 1970, financial institutions were required by law to obtain SSNs of all their customers.
Although the Privacy Act of 1974 prohibited States from using the SSN without congressional authority, it allowed those already using it to continue.
The Tax Reform Act of 1976 authorized States to use the SSN for State and local tax authorities, welfare systems, driver’s license systems, departments of motor vehicles, and for finding parents who were delinquent in child support payments. Later laws required or permitted States to require SSNs for participation in school lunch programs, Food Stamp programs, and numerous other programs.
Placement of the SSN on State drivers licenses is required by the year 2000 under a 1996 immigration reform provision.
There are few prohibitions against use of the SSN in the private sector
Educational institutions frequently use the SSN as a student identifier, and the National Student Loan Data System has required the SSN of the borrower since 1989.
Many health care providers also use the SSN to identify patients. Many private health plans use the SSN to identify subscribers and, to a lesser extent, dependents.
Individuals are now indexed by their SSN in a number of databases with routine linkages and data exchange among them.
Improvements in the SSA Enumeration Process
The SSA has taken steps to overcome problematic aspects of the SSN that stem from the current system’s lack of both a strategy for systematic assignment to every person and a means to authenticate a person’s identity. The SSA has improved its process to verify the identity of the person receiving an SSN.
Before 1971, the issuance of SSNs was based on information provided by the individual. Starting in 1971, some applicants had to document evidence of age, identity, and alien status.
In 1974, the SSA started recording when a non-work SSN had been issued to an alien and reported this to the Immigration and Naturalization Service.
Beginning on May 15, 1978, applicants for SSNs have had to document (using documents such as birth certificate or driver’s license) age, identity, and citizenship or alien status. If the applicant is at least 18 years old, a personal interview is conducted to determine if the person has had an SSN before. Additional verification is performed, such as contacting the State Bureau of Vital Statistics to verify the existence of a birth certificate, conducting a search for a death certificate or verifying Immigration and Naturalization documents presented by the applicant.
Currently, the verification process is based on a combination of personal data such as name, date and place of birth, sex, mother’s maiden name, and father’s name. These data elements are also used to screen the SSA database for any previous issuance to the person. The SSA reported to Congress in 1997 that its SSN database is highly accurate and allows assignment of an SSN within 24 hours if there are no questions about the data.
Other Needed Improvements
Beginning with tax returns filed January 1, 1998 or later, the SSNs of all dependents claimed by a taxpayer must be included on the tax return. Thus a child could need an SSN during the first year of life. SSA’s “Enumeration at Birth” process allows a parent to apply for an SSN for his/her newborn as part of the State’s birth registration process. The State sends to SSA the data needed to assign an SSN and issue a card.
About half of the original Social Security cards issued in fiscal years 1993-1994 used the “Enumeration at Birth” process. The addition of California in the process added an estimated 15 percent for fiscal year 1995. All 50 States, as well as New York City, Washington, DC, and Puerto Rico, now participate in this process.
In 1988 and again in 1991, the HHS Office of Inspector General cited major weaknesses in the birth certificate issuance process that hampered the ability of both Federal and State user agencies to rely on birth certificates retrospectively for identity. Among the problems cited were the use of false birth certificates as “breeder documents” to create false identities. The SSA defined breeder documents as those “... that are used to obtain other documents used for identity: for example, a birth certificate is used to obtain a drivers license, which is then used as an identity document.” The HHS Office of Inspector General also cited as problems the many different versions of birth certificate forms that are used, and open access with lax physical security for vital records.
All of the proposals for a health care identifier that depend on the SSN or the SSA would benefit from further improvements in the process for issuing and maintaining both SSNs and birth certificates.
An improved process could begin with a newborn patient in the birth hospital or other health care provider; at once the proper authorities would assign a birth certificate number, assign an SSN, and assign the health identifier.
Such a process would permit the longitudinal patient record to begin at the initial health care encounter. Health care providers that deliver newborns in non-hospital settings would need to have a method to access this system and report to it when necessary.
Improved accuracy in identification and reductions in fraud from a process linking birth registration and SSN issuance would benefit vital records agencies, SSA, and the public. These processes for assigning identifiers at birth would have to be supplemented with procedures to verify identities and issue numbers to individuals (for example, immigrants) whose enumeration would not occur at birth. The legislation that would be necessary to involve the SSA in this process would need to allow for these improvements.
The Costs of Improving SSA Enumeration
In relative terms, building upon an existing system, such as that administered by the SSA, should be less costly than creating an infrastructure to administer an entirely new identifier system. Nevertheless, proposals that require substantial investments by the SSA to improve its processes must address SSA’s costs for those changes. The need to improve the existing SSN system by eliminating duplicate numbers and re-verifying the identities of SSN holders is well established and independent of proposals to use SSA as the trusted authority for issuance of a unique health identifier. The term “trusted authority” as used in this document refers to the authority that will have the responsibility of administering a unique health identifier system.
As noted above, some of the needed improvements began several years ago. The SSNs that were assigned at birth using the enumeration process described earlier would not need to be changed or re-verified, and health identifiers could be issued immediately to people whose SSNs were assigned under the improved processes.
At the request of the Congress, SSA reported recently that, based on fiscal year 1996 data, verifying the identities of all SSN holders and reissuing new cards would have a basic minimum cost of about $3.9 billion. Additional estimates (up to $9.3 billion) were given if the process included new security features in the cards. The report did not attempt to estimate possible related costs, such as special processing for very young and very old number holders, those in rural locations, or those outside the United States.
If the SSA were to undertake the re-validation and re-issuance project in order to overcome the current limitations of the SSN, a unique health identifier issuance and maintenance system could benefit from being part of the process. If the SSA were to incur the cost of re-validation and re-issuance, the additional effort to issue a health identifier could be incorporated into the process at the earliest planning stages, and the costs for this process certainly would be smaller than instituting a new system to issue and administer such identifiers.
Improvements to the SSN and to SSA's enumeration process should yield benefits for other activities such as immigration reform and welfare fraud reform. It might be reasonable, therefore, if the improvements were undertaken in connection with SSA’s role as trusted authority for issuance of a health identifier for individuals, to apportion the cost of the improvements across all the agencies that would benefit from them.
excerpted from:
National Committee on Vital and Health Statistics
SUBCOMMITTEE ON STANDARDS AND SECURITY
July 20-21, 1998
Hearings on the Unique Health Identifier for Individuals
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