This report summarizes the findings of a Social Security Administration (SSA) Office of Inspector General (OIG) audit whose objectives were to (1) determine whether F-1 students worked on- or off-campus or were not employed and (2) assess schools' compliance with F-1 enumeration regulations.

According to the report, OIG made the following findings:

"Although the number of F-1 students who improperly obtain SSNs cannot be quantified, we are concerned that some F-1 students and schools may exploit vulnerabilities in the enumeration process to facilitate SSN attainment. Of the 24,504 F-1 students reviewed, we identified 2,479 (10 percent) who did not have wages posted to their SSA earnings records in 2005 or 20065 indicating they may not have worked on-campus. We also identified 680 (3 percent) who worked off-campus.7 That is, about 13 percent of F-1 students may have obtained SSNs for purposes other than on-campus employment.

We also determined the number of F-1 students who did not have posted wages decreased from 21 percent in 2005 to 10 percent in 2006. As such, we believe some F-1 students may not have started working until months after obtaining their SSNs. In addition, based on our field office discussions, SSA personnel did not always understand and comply with F-1 student enumeration policies and procedures.

To address concerns about SSN integrity, SSA implemented a more restrictive regulation for F-1 students that required evidence of actual or promised general on-campus employment, and we commend the Agency for its efforts. However, we believe SSA should take additional steps to reduce vulnerabilities in the F-1 enumeration process. We question whether assigning SSNs to F-1 students months in advance of planned employment is prudent. Instead, we believe SSA should only assign SSNs to F-1 students who will begin working within 30 days of their SSN application date. Based on our field office discussions, we also believe SSA should reemphasize the importance of understanding and following all policies and procedures when processing SSN applications from F-1 foreign students. In addition, we believe SSA should coordinate with schools and foreign student associations to educate the university community about SSA’s policies and procedures regarding F-1 student enumeration. We believe SSA should focus its efforts on schools that may facilitate F-1 students’ attainment of SSNs by confirming employment—with no real intent to hire the student and those that offer courses of study such as English as a Second Language or other non-degree programs."

SSA modified its procedures in response to this report.