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Statement for the Record on Counterfeiting and Identify Fraud by Edward Sondik, Director
National Center for Health Statistics
Centers for Disease Control and Prevention

Before the House Judiciary Committee, Immigration and Claims Subcommittee
July 22, 1999

I am pleased to have the opportunity to describe the activities of the Department of Health and Human Services (HHS) as they relate to the mandates of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 that deal with fraudulent documents.

First, I would like to address the efforts of the Department to improve the timeliness of death registration, a critical ingredient in reducing the ability to obtain and use fraudulent birth certificates. The activities associated with this effort are taking place within the National Center for Health Statistics (NCHS) which is part of the Centers for Disease Control and Prevention (CDC).

CDC/NCHS is the nation's principal health statistics agency. At CDC/NCHS our primary mission is to provide statistical information that helps identify trends in the population, target health problems, and support both policy and research. We conduct numerous surveys and data systems toward this end. The legislative authorization of CDC/NCHS carefully defines this mission, and the principles that apply to federal statistical agencies take pains to separate these agencies from law enforcement and other nonstatistical activities.

In one of these data systems, the National Vital Statistics System, we have an important relationship with state vital statistics officials (and the association that represents them, the National Association for Public Health Statistics and Information Systems - NAPHSIS) on the collection and use of statistical information that is included on birth and death certificates. These certificates are registered under state authority, but CDC/NCHS and the states work cooperatively to define the content of these certificates and the coding, editing, and processing steps necessary to arrive at a national database that helps us track critical health issues.

Our interest in vital statistics is in assuring that reliable, high quality statistical information is provided as rapidly as possible. Toward this end, we work with NAPHSIS and individual states to assure that the underlying registration system is sound -- that is, that it covers all events and is administered uniformly across states. In this role, the mission of CDC/NCHS touches on the interests of this Subcommittee and on the mandates of the Act. It is important to note that the mission of CDC/NCHS does not involve a direct role in those aspects of the vital registration systems that are purely legal in nature, such as issuance of certified copies of certificates to individuals.

CDC/NCHS and its state counterparts are pursuing an important initiative that will have potential benefits in improving document security. Continuing long-standing efforts to speed the production of statistical information, a great deal of developmental effort is being conducted to establish a fully electronic death registration process. Such a system would record data at the source (e.g., hospitals and funeral homes) and permit rapid registration, editing, and processing. From a security point of view, this is important because it allows the fact of death to be matched back to birth certificates more quickly, thereby preventing new issuances of birth certificates for fraudulent purposes.

To date, CDC/NCHS, NAPHSIS and states have taken the following steps:

  • We have worked with states, other appropriate federal agencies, and other concerned organizations to develop recommended standards for electronic death certificates and to promote the establishment of electronic death registration systems in states.
  • We are working with several states and localities (New York State and New York City, New Hampshire, Iowa, and Minnesota) that are actively involved in developing and implementing electronic death registration systems, and encouraging other jurisdictions that are moving in this direction.
  • We are supporting the efforts of the Social Security Administration which has funding available to help states with implementation of electronic death certificates.

In other steps to improve document security, HHS has been part of an interagency process to designate a lead federal agency, pursuant to section 656 of the Act. This lead federal agency is to promulgate regulations and standards regarding the acceptability of birth certificates by federal agencies. This process has resulted in the designation of the Immigration and Naturalization Service (INS) as the lead federal agency. We are looking forward to working with INS on this effort, consistent with our longstanding interest in the integrity of the National Vital Statistics System.

Section 656(c) requires HHS to submit a report on ways to reduce the fraudulent obtaining and use of birth certificates. We understand that the Department had interpreted section 656(c) as a requirement tied to the designation of a lead federal agency required under section 656(a). However, as a result of the Subcommittee's request regarding the status of the report required under section 656(c), the Department understands that Congress intended that the report be prepared not withstanding the designation of a lead federal agency.

Fortunately, HHS has a basis for beginning this report. The Department's Inspector General's office issued reports on the topic of birth certificate fraud in the late 1980s and early 1990s. The Department has begun a review of these documents and will produce a complete report on the current status of this problem as soon as possible. The Department shares the Subcommittee's concerns about the need to take steps to reduce the availability of fraudulent documents.

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