TN 3 (04-10)
RM 10210.405 Evidence of Identity for an SSN Card
The chart below lists quick POMS references for the proof of identity requirements for primary and secondary documents.
NOTE: For documents that contain only a year or state that they are valid for a particular year, it can be assumed, absent evidence to the contrary that the documents are valid only from the 1st day of that year through the last day of that year.
EXAMPLE: A document implying validity for the year 2014 would only be valid January 1, 2014 through December 31, 2014. Since the document is considered expired after December 31, 2014, it cannot be considered as a POI document after that date per the requirement stated in the chart, in RM 10210.405.
A. Why does SSA require proof of identity?
SSA requires each applicant to present documentary evidence of his or her identity
due to the growing problem of identity theft and false identity situations,
to be certain the individual is who he or she claims to be (i.e., that the person existed and continues to exist)
to ensure the applicant for an original card, does not already have a Social Security number.
to establish that the person who is applying for a replacement SSN card is the true number holder (NH) (i.e., the person to whom SSA originally assigned the SSN).
B. What Changes to SSA policy were brought about with the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA)?
Section 7213(a)(1)(B) of Public Law 108-458, The Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA), required SSA to establish minimum standards for the assessment of documents or records submitted by applicants to establish eligibility for original or replacement SSN cards. These instructions apply to applications for SSN cards taken December 17, 2005 and later and to the Enumerations System screens processed December 17, 2005 and later.
1. Acceptable documents as proof of identity
Acceptable documents, as evidence of identity, are based on three factors:
Evidence of identity documents are organized as primary or secondary documents. For a list of these documents, see RM 10210.420.
2. Assessing the probative value of documents
An applicant must submit an identity document with the highest probative value. If the applicant has two identity documents, one of high probative value at home and the other of lower probative value presented during the Field Office interview, ask the applicant to return home to get the document with higher probative value. To provide the best possible service to the public, give the applicant the appropriate public information materials http://mwww.ba.ssa.gov/pubs/10120.html . For a list of acceptable documents based on probative value, see RM 10210.420.
C. What are the rules for evidence of identity?
1. Acceptability of an identity document
Evaluate the acceptability of an identity document on a case-by-case basis. Consider the applicant’s situation, the rank of the document in RM 10210.420, and explore what evidence is available for the person.
2. Who must submit evidence of identity?
The following individuals must submit evidence of identity for enumeration purposes:
NOTE: For the number of documents an applicant must submit to obtain an SSN see RM 10210.020.
3. Issuance and format of identity documents
An evidence of identity document must be:
issued at a later time and for a different purpose than the birth record; and
a current, unexpired document to establish the individual’s continued existence.
Primary U.S. evidence documents are acceptable for up to 10 years from date of issue. For additional requirements for primary U.S. documents see RM 10210.425A.
When determining the age of a document use the latter of the document’s date of issue or date of certification.
EXCEPTION: If the birth record submitted as evidence of age was issued within the last year, the identity document should have been issued/recorded before the date the birth record was issued. This is to detect situations in which the birth record of a deceased person is used to establish a false new identity and obtain identity documents (e.g., driver’s license, medical records) in that identity.
NOTE: This Exception does not apply if the applicant is a child less than a year old.
4. Why a birth record is not evidence of identity
SSA does not accept a birth record as an identity document because it is not adequate evidence to show that the person is still alive.
A birth record:
establishes a fact of birth (i.e., that the person was born)
establishes the legal name at birth
is not sufficient evidence to establish identity for SSA purposes because it does not establish the person’s continued existence.
Therefore, we need evidence that shows the individual continues to exist beyond the date of birth up to the present time.
5. Considering the applicant’s age
Age usually dictates what proof of identity documents are available to an applicant. When the application for an SSN is for a very young child (e.g., newborn), hospital records (other than a souvenir birth certificate issued by the hospital) created at the time of birth should exist. After two weeks of age, most children see a physician routinely for shots and check-ups. In addition to these documents other medical records should exist.
A child (birth through age 17) should be able to provide an identity document issued or recorded within the past 4 years. If an evidence of identity document does not show an expiration date, the date issued must be within the last 4 years.
Exception: Certified child care facility records, preschool records, school records, transcripts, or report cards must be from current or prior school year.
An adult (age 18 to age 69) in most cases, should be able to provide a current identity document such as an unexpired driver’s license or State-issued non-driver identity card. For documents that do not show an expiration date, the date issued should be within the last two years.
An older adult (age 70 and older) particularly one who is less active or in a nursing home, may not have a current identity document, but may have an expired driver’s license issued several years ago that may be acceptable with other evidence readily available (e.g., medical records).
An evidence of identity document that does not contain a date of issue or date of expiration is not acceptable unless it has a photo with which the applicant can be easily and properly identified by comparing the picture on the document (i.e. the photo appears taken within the past 5 years) to the applicant. If you cannot easily and properly identify the applicant, request another document from the priority lists in RM 10210.420.
6. What is preferred evidence of identity?
Where the applicant lives determines the preferred evidence. Consider the following situations and examples.
a. Applicant applying at SSA office in the U.S.
The preferred evidence of identity is an identity document issued in the U.S.
EXCEPTION: U.S. Citizens living in Canada or Mexico visiting an SSA FO may use an approved Canadian or Mexican document listed in the Enumeration System as proof of identity. An alien, who recently arrived in the U.S, will generally have a U.S. lawful alien document and a foreign passport. A proper applicant filing on behalf of someone else may use both U.S. documents and the approved “OIO DOC” (Office of International Operations Documents) documents listed in the Enumeration System as proof of identity. See RM 10210.410B for information that is required to be on an identity document.
b. Applicant applying outside the U.S. at FSP or VARO
For an applicant (either U.S. citizen or foreign national) applying at a Foreign Service Post (FSP) or Veterans Affairs Regional Office (VARO) office outside the U.S., a foreign issued identity document may be acceptable.
Documents evaluated and approved by the Foreign Evidence Workgroup as acceptable evidence of identity are placed in the National Identity Document Database (NIDD) at http://nynet.ny.ssa.gov/identitydocument/ and in the Enumeration System. These documents appear in a drop down box with the header “OIO DOC”.
NOTE: Before accepting a foreign identity document, review the document description in the NIDD at http://nynet.ny.ssa.gov/identitydocument/ to determine the acceptability of the document or if there are any limitations affecting the acceptance of the document. Those foreign identity documents that have limitations may be used to the extent of the limitation. Documents with no limitations may be used without further approval.
EXAMPLE: If an applicant residing in Germany is entitled to Title II benefits applies for an SSN and presents a German driver’s license as evidence of identity, the interviewer may accept the German driver’s license if :
If the NIDD at http://nynet.ny.ssa.gov/identitydocument/ lists any limitations, the German driver’s license may only be used to the extent of the limitation(s).
When evaluating whether evidence issued outside the U.S. is reliable consult GN 00307.000.
D. Use the proper name to issue an SSN card
It is very important to issue an SSN card in an individual’s proper name. Along with the name, other data elements, such as date of birth or age, gender, and parents’ names help establish the applicant’s identity. For more information about names and legal names on the SSN card see RM 10212.001.
GN 00307.000 Reliability of a Country’s Documents
RM 10210.020 Policy for Number of Documents Required for an SSN Card
RM 10210.200 General Information on Reviewing and Verifying Evidence for an SSN Card
RM 10210.210 Reviewing Age, Identity, Citizenship and Lawful Alien Status Evidence for an SSN Card
RM 10210.405C What are the Rules for Evidence of Identity
RM 10210.410 How do You Examine, Evaluate and Assess Documents Submitted as Evidence of Identity
RM 10210.410B Biographical Information
RM 10210.420 List of Documents in Priority of Acceptability for use as Evidence of Identity
RM 10210.425 What are the Procedures for Specific Document Situations Documents
RM 10210.430B.2. Adding Documents to the NIDD at http://nynet.ny.ssa.gov/identitydocument/
RM 10212.001 Defining the Legal Name for an SSN