Identity Fraud Victim Redress Processes and Systems

Summary

A Pandemic Response Accountability Committee memorandum dated September 7, 2023, from Michael E. Horowitz, Chair of the Pandemic Response Accountability Committee, transmitting the MITRE report Identity Fraud Victim Redress Processes and Systems, Public Release Case Number 23-2843. The memorandum states that the PRAC engaged MITRE to conduct an independent study on the elements necessary for a whole-of-government approach to identity fraud redress, and that MITRE proposes a one-stop, claimant-centric redress model. It lists actions the federal government could take, including data matching, interagency data sharing agreements, common practices through a National Identity Fraud Task Force, and multiple service channels for victims. The attached MITRE report begins with an Executive Summary.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

MEMORANDUM
Following the coronavirus outbreak, Congress created the Pandemic Response Accountability
Committee (PRAC) in March 2020 to support and coordinate independent oversight of what is now
more than $5 trillion in pandemic-related programs and spending. The PRAC, with the support of its
Office of Inspector General (OIG) partners, is charged with examining whether pandemic funds were
used for their intended purpose and the extent of the fraud, waste, and abuse associated with these
relief funds. Through collaborative oversight work, the PRAC and our OIG partners have identified
identity fraud as a critical issue across multiple pandemic programs, such as the Pandemic
Unemployment Assistance program and the Paycheck Protection Program, among others. In
programs like these, federal agencies relied on self-certification and lowered guardrails to disburse
pandemic relief funds at record speed. What millions of Americans saw as relief from the economic
challenges caused by the pandemic, others saw as an opportunity to use stolen identities to exploit
programs and receive benefits to which they were not entitled. The consequences of these fraud
schemes are both stolen relief funds and stolen identities.
Identity fraud is a crime that can result in at least three victims: the person whose identity is used to
steal benefits, the person whose benefits are stolen, and the American taxpayer. Despite the
magnitude of individuals impacted by this crime during the pandemic and the significant toll it takes
on victims to clean up their personal credit scores, address tax consequences, and in some cases
prove their eligibility for rightful benefits, many federal and state benefits agencies struggle to help
victims resolve these complicated issues. Further, at the federal level there is no central entity
responsible for holistically aiding and supporting victims throughout the redress process.
The PRAC’s June 2022 report, Key Insights: Identity Fraud Reduction and Redress in Pandemic
Response Programs, emphasized the need for government information-sharing and data matching to
strengthen fraud prevention on the front end to reduce instances of identity fraud. Following the
report issuance, the PRAC engaged MITRE, a not-for-profit federally funded research and
development center, to conduct an independent study on the elements necessary for the
development of a whole-of-government approach to identity fraud redress. As detailed in the
attached report, MITRE interviewed victims of identity fraud who described the federal government’s
decentralized redress process as “burdensome, messy, confusing, isolating, and frustrating.” As
such, MITRE proposes development of a one-stop, claimant-centric redress model that enables
victims to easily report identity fraud and receive support throughout the redress process. Such a
model would require agencies to assist in a comprehensive manner while reducing the burden on
the victims to resolve the issue themselves.
This report and the PRAC’s June 2022 report provide specific actions the federal government could
take to reduce identity fraud and establish a whole-of-government victim redress approach:

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Conduct data matching to verify identity and eligibility for government programs;
•
Identify opportunities to rely on additional methods of identification and adjust fraud controls
once a gap has been identified to help prevent similar fraud in the future;
•
Establish interagency data sharing agreements consistent with applicable laws and
regulations;
•
Establish common practices and definitions across agencies through a National Identity
Fraud Task Force to provide a consistent redress experience for victims; and
•
Make multiple service channels available to victims of identity theft (e.g., in-person,
telephone, online, and email) where legally permissible.

The PRAC will continue to work with Executive Branch officials and Congress to reduce identity fraud
and improve victim redress processes in federal programs.

Michael E. Horowitz
Chair, Pandemic Response Accountability Committee
Inspector General, U.S. Department of Justice

A-ii

Identity Fraud Victim Redress
Processes and Systems

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Executive Summary
Victims of identity fraud interviewed for this report have called the current redress process,
“burdensome, messy, confusing, isolating, and frustrating.”1 According to the Pandemic
Response Accountability Committee (PRAC), “the decentralized nature of the government’s
identity fraud redress process ultimately places the burden of resolving identity theft and identity
fraud on the victims.”2 Furthermore, the majority of the government employees interviewed for
this assessment have expressed the need for standardization of policies,3 articulated their need for
better data sharing across government,4 and requested better technology to create a seamless
process.5
Discovering that you are a victim of identity theft is a traumatizing experience according to
individuals interviewed for this report.  When asked what adjectives individuals would use to
describe the redress experience from the victim’s perspective, a national victim’s advocate
stated, “I don't have a single word to describe it, but [victims] feel very much that they're not
treated like a crime victim. The onus is on them to demonstrate their innocence and jump
through all these hoops. This person went on to say, “we have a fundamentally different process
for victims of identity crimes, and we make them feel like the criminal and we make them feel
lost and alone, [as if] it's totally up to them to resolve this issue and they have no support.”
Victims of identity theft, advocacy groups, and government officials interviewed for this study
are asking for a true one-stop shop process with dedicated funding, where victims can conduct
the federal redress process from grievance submission to resolution through one central
application.
This report provides the strategic and tactical design elements necessary for this reimagined
process by first framing federal redress as a single enterprise, then using inputs from interviews
with victims of identity fraud, advocacy groups, and federal and state benefits administrators to
develop a set of guiding principles for the design elements (five from the victim’s perspective
and five from the government administrator’s perspective). Those guiding principles informed
the development of a one-stop shop business framework, and a processing platform with detailed
capabilities that shows how stakeholders would engage with this new platform. Though this
report is a conceptual design of a strategic operating model, the report identifies three short-term,
three mid-term, and three long-term considerations for the federal enterprise to consider as it
moves from the proposed concept to implementation.

1 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.
2 Council of the Inspectors General on Integrity and Efficiency. Key Insights: Identity Fraud Reduction and Redress in Pandemic
Response Programs. By Pandemic Response Accountability Committee. Washington, DC: PRAC, 2022.
3 Federal Deputy Inspector General. Videoconference interview by the author. McLean, VA. November 11, 2022.
4 Senior State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.
5 State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.

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The nine considerations are broken into the following three categories:
1. Short-term considerations:
i.
Establishing common thresholds and processes across government in accordance
with the Payment Integrity Information Act (PIIA)6 – Office of Management and
Budget (OMB)
ii.
Establishing inter-agency data sharing agreements – OMB
iii.
Establishing a no wrong door federal policy that allows victims to report identity
fraud to any federal agency using the full suite of service channels available
across the federal enterprise, where permitted by law. – OMB
2. Mid-term considerations:
i.
Conduct a macro-economic benefit-cost analysis to determine the return on
investment of implementation. – OMB
ii.
Develop a whole-of-government redress governance model. –  OMB
iii.
Run communications campaigns to inform the public of the existence of a new
federal redress process. – Federal Trade Commission (FTC)
3. Long-term considerations:
i.
Apply the Federal Integrated Business Framework (FIBF) to identify the granular
requirements of this type of integration. – General Services Administration (GSA)
ii.
Develop a federal fusion center for investigations. – OMB
iii.
Congressional action required for implementation. – U.S. Congress
Incorporating these nine considerations into the identity fraud redress process would help
alleviate the “burdensome, messy, confusing, isolating, and frustrating” 7 nature of the current
decentralized federal redress process. The intent of this report is to provide key observations and
insights that will transition the current federal redress process to a claimant-centric redress model
founded on the principles of due process, which reduces the burdens on the victims of identity
theft, empowers federal agencies to assist victims, and places the claimant at the center of all
business decisions affecting operations across the federal identity theft redress space.

6 Council of the Inspectors General on Integrity and Efficiency. Guidance for Payment Integrity Information Act Compliance Rev
iews. Washington, DC: Council of the Inspectors General on Integrity and Efficiency, 2021. https://www.ignet.gov.
7 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.

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Table of Contents
1
Introduction ........................................................................................................................ 1-1
1.1
Purpose and Overview of the Report ............................................................................ 1-2
1.2
Scope ............................................................................................................................. 1-3
1.3
Key Definitions ............................................................................................................. 1-4
1.4
Areas of Consideration ................................................................................................. 1-5
2
Defining the Problem ......................................................................................................... 2-1
2.1
The Victim’s Perspective: Burden on The Claimant .................................................... 2-2
2.1.1
How Does a Victim Seek ID Fraud Redress at the Federal Level? ........................ 2-5
2.2
The State and Federal Perspective ................................................................................ 2-9
2.2.1
Frustrations with the Adjudication Process for Identity Theft Redress ................ 2-10
2.2.2
Fixing Pay and Chase ............................................................................................ 2-12
3
Guiding Principles for A Path Forward ........................................................................... 3-1
4
The Design Elements of a New Redress Process .............................................................. 4-1
4.1
One-Stop Shop Business Framework ........................................................................... 4-1
4.2
Lifecycle Phases............................................................................................................ 4-3
4.3
One-Stop Federal Redress Platform.............................................................................. 4-7
4.4
Redress Process Capability Needs ................................................................................ 4-9
4.5
Past Implementations of One-Stop Platforms Across Government ............................ 4-13
4.5.1
State Government Implementation ....................................................................... 4-13
4.5.2
Federal Government Implementation ................................................................... 4-13
4.6
The Benefits of Utilizing a Common Process Platform.............................................. 4-14
4.6.1
Leveraging Best Practices ..................................................................................... 4-14
4.6.2
Capturing Economies of Scale .............................................................................. 4-15
4.6.3
Shortening Claim Resolution Timeframes ............................................................ 4-15
4.6.4
Alleviating Common Victim Frustrations............................................................. 4-16
4.6.5
Alleviating Common Government Employee Frustrations .................................. 4-17
4.6.6
Meeting the Intent of the Current Administration’s PMA and Executive
Order (EO) 14058 ................................................................................................. 4-17
4.7
Use Cases .................................................................................................................... 4-18
5
Key Considerations ............................................................................................................ 5-1
5.1
Short-Term Considerations ........................................................................................... 5-1
5.1.1
Establish Common Thresholds and Processes ........................................................ 5-1
5.1.2
Establish Inter-Agency Agreements on Data Sharing ............................................ 5-3
5.1.3
Make All Service Channels Available .................................................................... 5-3

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5.2
Mid-Term Considerations ............................................................................................. 5-3
5.2.1
Conduct a Macro Economic Benefit-cost Analysis ................................................ 5-3
5.2.2
Develop a Whole-of-Government Redress Governance Model ............................. 5-4
5.2.3
Run Communication Campaigns ............................................................................ 5-5
5.3
Long-Term Considerations ........................................................................................... 5-6
5.3.1
Apply the Federal Integrated Business Framework (FIBF) .................................... 5-6
5.3.2
Fusion Center for Investigations ............................................................................. 5-7
5.3.3
Congressional Action .............................................................................................. 5-7
Appendix A
Acronyms ...................................................................................................... A-1
Appendix B
Methodology.................................................................................................. B-3
Appendix C
Use Cases ....................................................................................................... C-1
C.1
Initial Contact With Agency ........................................................................................ C-1
C.2
Trauma Care Support ................................................................................................... C-4
C.3
Request Fusion Fraud Fusion Center Investigation ..................................................... C-7

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List of Figures
Figure 2-2. Defining the Problem from a Victim's Perspective ................................................... 2-5
Figure 3-1 Identity Fraud Redress Guiding Principles: An Enterprise Perspective .................... 3-1
Figure 3-2 Guiding Principles: The Victim's Perspective ........................................................... 3-3
Figure 3-3 Guiding Principles: The Government's Perspective ................................................... 3-4
Figure 4-1 One-Stop Shop Business Framework......................................................................... 4-2
Figure 4-2 Federal Redress Lifecycle Phases .............................................................................. 4-6
Figure 4-3 Applicant Population Along the Redress Lifecycle ................................................... 4-7
Figure 4-4 One-Stop Federal Redress Platform ........................................................................... 4-8
Figure 4-5 Distribution of Capability Needs by Stakeholder .................................................... 4-10
Figure 4-6 The Impacts of Automation and Using a Common Business Platform in
Michigan ............................................................................................................ 4-16
Figure B-1 Evaluation Methodology .......................................................................................... B-3

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List of Tables
Table 1-1 Areas of Consideration for Victim Redress Processes and Systems ........................... 1-5
Table 2-1 Demographic Characteristics of Victims of Identity Theft and the U.S.
Residential Population Age 16 or Older, 2018 .................................................... 2-4
Table 3-1 Identity Fraud Victim Redress - Overall Needs by Cohort ......................................... 3-4
Table 4-1 Potential Capability Needs with Description ............................................................ 4-10
Table C-1. Typical Flow of Events for Initial Contact with Agency.......................................... C-2
Table C-2. Typical Flow of Events for Trauma Care Support ................................................... C-5
Table C-3. Typical Flow of Events for Request Fusion Fraud Fusion Center Investigation...... C-8

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1 Introduction
On March 11, 2020, the World Health Organization (WHO) declared that the spread of a novel
coronavirus disease called SARS-CoV-2 (COVID-19) met the criteria for declaring a global
pandemic. Around the same time, the U.S. Centers for Disease Control and Prevention (CDC)
reported 60 cases of COVID-19 across 12 U.S. States.8 In short order, the President of the United
States declared a nationwide emergency that unlocked billions of dollars in federal funding to
contain and combat the disease. The U.S. government focused the early days of the pandemic on
virus containment, but that focus quickly broadened to the adverse economic realities associated
with newly enforced pandemic restrictions.
The onset of COVID-19 left millions of Americans unemployed overwhelming state
employment benefits systems. According to news reports in May 2020, “over 33 million
Americans filed for initial jobless claims as a result of the coronavirus pandemic.”9 An employee
of a state unemployment office interviewed for this report when discussing the volume of claims
their office was processing at the time said, “if another pandemic happens, I will retire because I
can’t go through that again. We were working 16- to 17-hour days for about seven months. Even
on Sundays we were having meetings. It was terrible. I don’t want to ever have to go through
that again.”10
“[During the pandemic] we were working 16- to 17-hour days for about
seven months. Even on Sundays we were having meetings. It was terrible. I
don’t want to ever have to go through that again.”11 – Senior State
Unemployment Office Employee
For the purpose of this analysis – and consistent with previous MITRE research into benefits
delivery – this report defines a benefit program as an intervention intended to “build equity,
opportunity, and resilience for people by providing income or other resources to reduce poverty
and inequality, support investments in human capital, and help insure against shocks and various
risks” such as loss of income from disability or age, economic crisis, natural disaster and climate
change.12 Generally, governments provide benefits in three areas: “social assistance
(noncontributory benefits and social services), social insurance (contribution-based benefits), and
labor (both contributory and noncontributory benefits, as well as employment services).”13 14

8 Centers for Disease Control and Prevention. "CDC Museum COVID-19 Timeline." CDC. Last modified August 16, 2022.
https://www.cdc.gov/museum/timeline/covid19.html (accessed November 18, 2022)
9 NBC News. "Over 76,000 Dead as 33 Million File for Unemployment in U.S." NBC News. Last modified May 8, 2020.
https://www.nbcnews.com/health/health-news/live-blog/2020-05-07-coronavirus-news-n1201801 (accessed November 18,
2022)
10 Senior State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.
11 Ibid.
12 K. Lindert, T. G. Karippacheril, I. R. Caillava, and K. N. Chávez, eds., Sourcebook on the Foundations of Social Protection
Delivery Systems, Washington, DC: World Bank, 2020. doi:10.1596/978-1-4648-1577-5. License: Creative Commons
Attribution CC BY 3.0 IGO at 1.
13 Ibid.
14 Fujita, Megumi K., Josh LeFevre, Samir Salifou, and Joshua I. Schwartz. Integrated Benefits Delivery: An Environmental Scan
of Current Systems in the United States and around the Globe. McLean, VA: MITRE, 2021.

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According to the U.S. Government Accountability Office (GAO), problems such as the
bureaucratic redundancies associated with benefit claims at the state and federal level, and
limited logistical resources to process claims, led to bottlenecks in the delivery capacity of many
benefit programs during the pandemic.15
The Washington Post reported that, “In the face of an unprecedented crisis, federal officials
consistently chose haste over precision, dispatching aid with uncharacteristic speed to save the
economy — even at the risk of costly mistakes.”16
The consequence of these actions was widespread identity fraud and theft that in turn pillaged
unemployment insurance coffers across the country. Though the exact scope of this theft is
unknown, according to press reports, “a top watchdog for the Labor Department estimated there
could have been “at least” $163 billion in unemployment-related “overpayments,” a projection
that includes wrongly paid sums as well as “significant” benefits obtained by malicious actors.”17
The largescale fraud is substantial, but it is critical to recognize the loss and impact suffered by
victims of identity fraud and the challenges they face to restore their financial security and
remedy losses through the vast and complex bureaucratic process available to them.
As detailed in section 4 of this report, this assessment defines a claimant-centric approach as one
where all federal redress interactions with claimants are founded on the principles of due process
while reducing the burdens on the victims of identity theft, placing the claimant at the center of
all business decisions affecting operations across the federal space. A claimant-centric culture
will enhance customer focus and reinforce trust between the public and the federal government.
It will also empower government officials to address a victim’s concerns and process their
application for redress efficiently.
This report begins with a focus on the victims’ perspectives, then addresses the federal
adjudication process by understanding the limitations of current redress processes within certain
federal benefits delivery agencies. Ultimately this assessment will provide an overview of the
guiding principles of a redesigned federal identity theft redress process, as well as the strategic
and tactical alternatives for implementation of a reimagined whole-of-government redress model.
1.1 Purpose and Overview of the Report
The objective of this report is to identify the necessary design elements for a federal identity theft
and identity fraud redress processes related to government benefits programs. The Pandemic
Response Accountability Committee (PRAC), a committee within the Council of the Inspectors
General on Integrity and Efficiency (CIGIE) tasked by Congress to promote transparency and
conduct oversight of the pandemic response,18 contracted with The MITRE Corporation

15 U.S. Government Accountability Office. Lessons Learned When a Pandemic Led to Rapidly Rising Unemploymen
t Claims. Washington, DC: GAO, 2022. Accessed June 19, 2023. https://www.gao.gov/blog/lessons-learned-when-p
andemic-led-rapidly-rising-unemployment-claims.
16 Room, Tony, and Yeganeh Torbati. "'A Magnet for Rip-off Artists': Fraud Siphoned Billions from Pandemic Unemployment
Benefits." The Washington Post (Washington, DC), May 15, 2022., https://www.washingtonpost.com/us-
policy/2022/05/15/unemployment-pandemic-fraud-identity-theft/ (accessed November 18, 2022)
17 Ibid.
18 The PRAC’s oversight of the pandemic response is related to The Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020, The Families First Coronavirus Response Act, Paycheck Protection Program and Health Care
Enhancement Act, The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Continued Assistance Act, and
the American Rescue Plan Act (ARPA).

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(MITRE) to conduct this work. As a federally funded research and development center operator
authorized by Federal Acquisition Regulation 35.017, MITRE provides unbiased and conflict-
free advice, guidance, and technical subject matter expertise to government sponsors.
To develop this report, MITRE’s analysis included evaluation of federal and state approaches,
policies, technology, and processes for implementing identity fraud redress programs. The
analysis was conducted through review of federal and state documentation and as well as
interviews with federal and state stakeholders. This analysis seeks to provide the PRAC the
necessary strategic and tactical considerations to implement a whole-of-nation U.S. model for
victim redress from federal benefit programs. This report will identify the guiding principles of
this redesign, as well as provide cogent articulation of a new federal identity theft redress
business process.
1.2 Scope
This report identifies strategic and tactical design elements needed to redesign the federal redress
policies, systems, and systems across federal agencies. Though researchers for this report
interviewed State officials to understand their perspective of the federal process, the intent was to
glean their perspective on how a federal system can best address the States concerns. This report
relied on inputs from an academic environmental scan that The MITRE Corporation conducted
on behalf of the PRAC. The environmental scan consisted of two phases: 1) a review of
academic literature and government publications; and 2) interviews with key stakeholders
representing victim advocacy organizations, administrators and independent inspectors of
government benefit programs, and victims of identity theft and fraud. Furthermore, the
environmental scan focused on six Federal Agencies, notably the Social Security Administration
(SSA), the Small Business Administration (SBA), the Federal Trade Commission (FTC), the
Department of Veteran’s Affairs (VA), the Department of Labor, and the Internal Revenue
Service (IRS). The literature review examined the current perspective of identity fraud and
provides context for what the federal government has done in the past and where future research
should focus.
This report identifies strategic and tactical design elements needed to redesign the federal redress
policies, systems, and systems across federal agencies. Though researchers for this report
interviewed State officials to understand their perspective of the federal process, the intent was to
glean their perspective on how a federal system can best address the States concerns. This report
relied on inputs from an academic environmental scan that The MITRE Corporation conducted
on behalf of the PRAC. The environmental scan consisted of two phases: 1) a review of
academic literature and government publications; and 2) interviews with key stakeholders
representing victim advocacy organizations, administrators and independent inspectors of
government benefit programs, and victims of identity theft and fraud. Furthermore, the
environmental scan focused on six Federal Agencies, notably the Social Security Administration
(SSA), the Small Business Administration (SBA), the Federal Trade Commission (FTC), the
Department of Veteran’s Affairs (VA), the Department of Labor, and the Internal Revenue
Service (IRS). The literature review examined the current perspective of identity fraud and
provides context for what the federal government has done in the past and where future research
should focus.
MITRE and the PRAC identified 33 interviewees from various U.S. federal and state
government organizations, advocacy groups, and international organizations (e.g., Services

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Australia). MITRE defined an evaluative framework of analysis to guide their research and
interview approach. The three categories, advocacy groups, federal and state agencies and
bridging opportunities provide perspectives related to the user experience, redress program
capacity and applicable technologies to facilitate redress respectively.
The PRAC published an announcement on their website announcing the study. The PRAC sent
an introductory email to prospective interviewees along with a calendar of available interview
dates and a sample of interview questions. The mechanics of the interviews included one
member facilitating the discussion and the other member taking notes. MITRE recorded the
interviews and the duration ranged from 45-60 minutes in length. Individual team members
analyzed and summarized interviews for insights related to each redress perspective.
The focus of this report being on the federal redress systems and process, there is little mention
of fraud prevention requirements beyond ensuring that victims of identity fraud are protected
from further victimization. As outline in section 2.2.2 of this report, changing the “pay and
chase” mindset and instituting fraud prevention mechanism in tandem with a new redress process
will help further this goal.  In an effort to rely on evidence-based design, this report uses the
framework of a one-stop shop redress which requires victims to initiate a claim to seek redress.
There are very few examples of a no-stop shop process where governments would proactively
start the redress process without having received a complaint from their constituents. Where
those no-stop shop models exist there is not enough evidence to support a proper comparison of
the benefits of one model over the other.

1.3 Key Definitions
Identity Theft
Identity theft is the criminal act of stealing personal, private, or financial information with the
intent of using it to assume another person’s identity.
Identity Fraud
The use by one person of another person's personal information, without authorization, to
commit a crime or to deceive or defraud that other person or a third person.
Redress
To remedy or set right for a wrong or grievance.
Improper Payments
Government Accountability Office (GAO) Report Number GAO-02-749, August 2002, defines
improper payments as payments that should not have been made or were made for incorrect
amounts. Specifically, this includes inadvertent erroneous payments, such as duplicate payments,
and incorrectly calculated payments (which may include underpayments or overpayments).19
Eligibility Fraud

19 Government Accountability Office. “Improper Payments.” https://www.gao.gov/improper-payments (accessed November 22,
2022)

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Intentional deception to secure unfair or unlawful gain, or to deprive a victim of a legal right as it
relates to providing false or misleading information or omissions regarding eligibility for
federal/state benefit programs; failure to notify the agency of any significant changes that might
affect eligibility or eligibility level, or misuse of public assistance funds or benefits.20
Federal Assistance/Benefit Programs
An intervention intended to “build equity, opportunity, and resilience for people by providing
income or other resources to reduce poverty and inequality, support investments in human
capital, and help insure against shocks and various risks.”21
1.4 Areas of Consideration
Table 1-1, represents a high-level summary of the different areas for consideration elucidated in
this report. Starting at the conceptual level with a strategic perspective that encompasses guiding
principles, a conceptual framework, and a business process, then moving to a tactical perspective
that includes an operational platform, and nine next steps to move toward implementation.
Table 1-1 Areas of Consideration for Victim Redress Processes and Systems
Category
Proposed Consideration
Guiding Principles -
Detailed in Section 3 of
This Report.

Victim’s Perspective:
➢ Create a one-stop-shop.
➢ Provide trauma-informed assistance.
➢ Establish the principles of due process and fairness
throughout the engagement.
➢ Establish equity, inclusivity, accessibility, and security
by offering appropriate service channels.
➢ Keep the victim informed throughout the process.
Administrator’s Perspective:
➢ Establish redress programs and policies that define
clear authorities.
➢ Dedicate funding for redress programs.
➢ Facilitate data sharing across government silos.
➢ Standardize redress thresholds, policies, and language
across government.
➢ Minimize impacts to current operations and budgets.

20 U.S. Citizenship and Immigration. “Chapter 2 - Overview of Fraud and Willful Misrepresentation.”
https://www.uscis.gov/policy-manual/volume-8-part-j-chapter-2 (accessed November 4, 2022)
21 K. Lindert, T. G. Karippacheril, I. R. Caillava, and K. N. Chávez, eds., Sourcebook on the Foundations of Social Protection
Delivery Systems, Washington, DC: World Bank, 2020. doi:10.1596/978-1-4648-1577-5. License: Creative Commons
Attribution CC BY 3.0 IGO at 1.

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Category
Proposed Consideration
Conceptual Framework –
Detailed in Section 3 of
This Report
This report views the future design of the federal identity fraud
redress process as one enterprise that encompasses four key
stages of engagement, as identified in Figure 3-1 below.
Business Process
Framework – Detailed in
Section 4.1 of This Report
The proposed one-stop shop model for federal identity theft
redress would serve as an integrated benefit delivery system.
Specifically, a one-stop shop is “a single point of contact
“where governments can collect data for one or more services
through a single, integrated digital form” and deliver services
and information from different entities.22 The one-stop shop
allows each benefits delivery agency to continue to work
within their lane of authority and exercise their expertise in
their benefits space. Although an applicant may go to one
central location to apply for redress if, for example, a criminal
fraudulently used their identity at IRS and SBA, each agency
would be able to conduct its own investigation into the matter
and provide periodic updates to the applicant while sharing
data with other benefits delivery agencies participating in this
shared framework. This ensures the applicant only goes to one
location to seek relief, while other benefits delivery agencies
can flag that applicant’s personally identifiable information
(PII) to ensure they apply extra scrutiny to any request for
benefits given the pattern of fraud.
Operational Platform –
Detailed in Section 4.3 of
This Report.
Within the context of the enterprise perspective of the redress
process defined in Figure 3-1 below, this platform would serve
as the line of visibility between the applicant and all
participating benefits delivery agencies. Furthermore, this
platform comprises the core design elements that satisfy the
capabilities of this new system. Figure 4-4 depicts the one-stop
federal redress platform and includes a capability list
applicable to all the stakeholders who interact with these
processes.
Next Steps – Detailed in
Section 5 of This Report
Though this report is a conceptual design of a strategic
operating model, the report identifies 3 short-term, 3 mid-term,
and 3 long-term considerations for the federal enterprise to
consider as it moves from the proposed concept to
implementation. Section 5 provides further details of key
considerations for implementation.

22 Becker, Jorg, Marek Kowalkiewicz, Willem Martens, and Hendrik Scholta. "From One-Stop Shop to No-Stop
Shop: An E Government Stage Model." Government Information Quarterly 36, no. 1 (January 2019): 11-26.
https:// https://www.sciencedirect.com/science/article/pii/S0740624X17304239 (accessed March 24, 2023)

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2 Defining the Problem
Increasing trust in government through effective management of government institutions is a
critical component of the current administration’s Presidential Management Agenda (PMA). In
the PMA, the administration states that the manner in which “the public interacts with
Government programs and benefits influences their level of trust in Government as an institution
[…] delivering results and being accountable for [public sector] actions will steadily rebuild trust
between the public and their government.”23 Seeking redress from the federal government should
be a seamless process where the claimant (the victim of a crime) can request an investigation into
their claim and, if the facts support their claim, be brought to a pre-injury condition; this is what
this report generally refers to as identity fraud redress. In accordance with the aspirations of the
PMA, delivering results to these victims is at the core of rebuilding trust in government
institutions and reinforcing legitimacy in public institutions.
“[A redress process] needs to be conceived on the front end of any type of
program. I don’t think it is an overstatement to say that [our agency]
hadn’t thought of a redress process [until] it was midstream, and millions
of applications had already hit, and the hotlines were exploding. … If you
operate from the mindset of not putting [a process in place] on the front
side, and not contemplating that there’s going to be a loss or theft then I
think you’re going to find yourself behind the Eightball”24 – Federal
Deputy Inspector General
The reality of the current redress process is divorced from this vision of an effective government.
Victims of identity fraud interviewed for this report have called the current redress process,
“burdensome, messy, confusing, isolating, and frustrating.”25 Furthermore, most of the
government employees interviewed for this assessment have expressed the need for
standardization of policies,26 articulated their need for better data sharing across government,27
and requested better technology to create a seamless process.28 A senior state unemployment
official when discussing customer service levels to claimants stated that, “everyone that I worked
with really wanted to help [claimants]. [Applicants] were in dire straits and [state employees]
were really looking for solutions. They were trying more than one avenue. They [would] make
connections with people in other departments to try to help the claimants get benefits. We saw
extraordinary levels of service … [yet] we can always make better use of technology [to support
our staff].”29 Speaking to the need for better policies at the federal level, a federal deputy
inspector general stated that a redress process, “needs to be conceived on the front end of any
type of program. I don’t think it is an overstatement to say that [our agency] hadn’t thought of a
redress process [until] it was midstream, and millions of applications had already hit, and the

23 The President’s Management Council. The Biden-Harris Management Agenda Vision Toward an Equitable, Effective, and
Accountable Government that Delivers Results for All. Washington, DC: Office of Management and Budget, 2021.
24 Federal Deputy Inspector General. Videoconference interview by the author. McLean, VA. November 11, 2022.
25 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.
26 Federal Deputy Inspector General. Videoconference interview by the author. McLean, VA. November 11, 2022.
27 Senior State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.
28 State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.
29 Senior State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.

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hotlines were exploding … If you operate from the mindset of not putting [a process in place] on
the front side, and not contemplating that there’s going to be a loss or theft then I think you’re
going to find yourself behind the Eightball.”30
Ultimately, the current federal process for redress places the burden on the victims of identity
theft to navigate a complex bureaucracy. Current federal policies require the victim to engage
with each benefits-delivery agency in a process that most victims interviewed for this report
characterize as “frustrating and burdensome.”31 Continuing the status quo discounts the trauma
associated with being a victim of identity theft.
2.1 The Victim’s Perspective: Burden on The Claimant
Discovering that you are a victim of identity theft is a traumatizing experience according to
individuals interviewed for this report.32 When asked what adjectives individuals would use to
describe the federal identity theft redress process from the victim’s perspective a national
victim’s advocacy stated, “I don't have a single word to describe it, but [victims] feel very much
that they're not treated like a crime victim. The onus is on them to demonstrate their innocence
and jump through all these hoops. Can you imagine if we did that to victims of sexual assault or
to family members of homicide victims?”33 This person went on to say that, “we have a
fundamentally different process for victims of identity crimes and we make them feel like the
criminal and we make them feel lost and alone, [as if] it's totally up to them to resolve this issue
and they have no support.”34
“I don't have a single word to describe it, but [victims] feel very much that
they're not treated like a crime victim. The onus is on them to demonstrate
their innocence and jump through all these hoops. Can you imagine if we
did that to victims of sexual assault or to family members of homicide
victims? We have a fundamentally different process for victims of identity
crimes, and we make them feel like the criminal and we make them feel lost
and alone, [as if] it's totally up to them to resolve this issue and they have
no support.”35 – National Victim’s Advocate
The victims of identity fraud seeking redress from the federal government have multiple
processes and procedures to navigate to submit claims for redress, assuming the agency has one.
This places a burden on the victims to navigate the different federal bureaucracies.
“I do not see any evidence that any one particular group is broadly targeted
or falls victim more often than any other, however there are cohorts of
people who have attributes that are similar. They're not your standard
demographics, it's about how you engage in the outside world, with few
exceptions. Now, the differently abled, (e.g., the blind, deaf, or hard of

30 Federal Deputy Inspector General. Videoconference interview by the author. McLean, VA. November 11, 2022.
31 Victim of Identity Theft. Videoconference interview by the author. McLean, VA. October 31, 2022.
32 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.
33 Ibid.
34 Ibid.
35 Ibid.

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hearing) [will have] a lot of common vulnerabilities … just because of
those abilities … I am vulnerable to all of these crimes and scams, so are
you, again it’s about how we engage [with] the outside world and making
sure we setup our programs to address [those heightened vulnerabilities].”36
– National Victim’s Advocate
Besides being a general burden for the American public, the current identity fraud redress
process also exposes a question of equity and accessibility for individuals with limited means or
disabilities. While speaking to demographic vulnerabilities associated with identity theft, one
national victim’s advocate said, “I do not see any evidence that any one particular group is
broadly targeted or falls victim more often than any other, however there are cohorts of people
who have attributes that are similar. They're not your standard demographics, it's about how you
engage in the outside world, with few exceptions. Now, the differently abled, (e.g., the blind,
deaf, or hard of hearing) [will have] a lot of common vulnerabilities … just because of those
abilities.” This advocate went on to say, “I am vulnerable to all of these crimes and scams, so are
you, again it’s about how we engage [with] the outside world and making sure we setup our
programs to address [those heightened vulnerabilities].”37
To validate these claims, we reviewed data from the Department of Justice’s (DOJ) Office of
Justice Programs. The Bureau of Justice Statistics (BJS) published data explaining the makeup of
victims of identity theft in 2018. Error! Reference source not found. (please see Error!
Reference source not found.) shows that targets of identity theft are proportional to the
demographic makeup of that population.38 Furthermore, the report states that, “half of all victims
of identity theft (51%) were in households with incomes of $75,000 or more.”39
“Victims of personal information misuse, [which includes unauthorized
use of personal information for fraudulent purposes such as getting a
government benefit] were more likely to experience severe emotional
distress than [other victims].”40 – Dr. Erika Harrell, DOJ

36 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.
37 Ibid
38 Harrell, Erika, Ph.D. Victims of Identity Theft, 2018. Research report no. NCJ 256085. Washington, DC: U.S. Department of
Justice, April 2021.
39 Ibid.
40 Ibid.

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Table 2-1 Demographic Characteristics of Victims of Identity Theft and the U.S. Residential
Population Age 16 or Older, 201841
-
Victims of Identity Theft
U.S. Residential Population
Demographic
Characteristics
Number of
Victims
Percent of US
Residential
Population Age
16 or Oldera
Percent
of All
Victims
Number of
Persons Age
16 or Older
Percent of
Persons Age
16 or Older
Total
23,183,020
9%
100%
258,175,200
100%
Sex
Male*
11,219,660
9%
48.4%
125,188,140
48.5%
Female
11,963,360 †
9%
51.6% †
132,987,070
51.5%
Race/Ethnicity
Whiteb*
16,560,830
10.1%
71.4%
163,585,560
63.4%
Blackb
2,100,740 †
6.8% †
9.1% †
30,846,330
11.9%
Hispanic
2,719,120 †
6.4% †
11.7% †
42,553,730
16.5%
Asianb
1,192,880 †
7.8% †
5.1% †
15,277,670
5.9%
Otherb,c
609,440 †
10.3%
2.6% †
5,911,910
2.3%
Age
16 - 17
99,310 †
1.2% †
0.4% †
7,979,760
3.1%
18 - 24
1,759,310 †
5.9% †
7.6% †
29,916,270
11.6%
25 - 34
4,410,270 †
9.8% †
19% †
44,892,670
17.4%
35 - 49*
6,772,500
11%
29.2%
61,627,990
23.9%
50 - 64
6,478,060
10.3% ‡
27.9%
62,994,100
24.4%
65 or older
3,663,570 †
7.2% †
15.8% †
50,764,410
19.7%
Household income
$24,999 or less
2,847,190 †
6% †
12.3% †
47,499,520
18.4%
$25,000 - $49,999
4,323,590 †
6.5% †
18.6% †
66,365,670
25.7%
$50,000 - $74,999
4,211,840 †
8.8% †
18.2% †
47,790,700
18.5%
$75,000 or more*
11,800,400
12.2%
50.9%
96,519,310
37.4%
Note: Details may not sum to totals due to rounding. Estimates are based on the most recent incident of identity
theft. Missing data for household income were imputed. Excludes persons who reported discovering the most recent
identity-theft incident prior to the reference period (12 months before the Identity Theft Supplement interview).
Includes persons who did not know when they discovered the most recent incident (8% of victims). See appendix
table 4 in the source paper for standard errors.
*Comparison group.
† Difference with comparison group is significant at the 95% confidence level.
‡ Difference with comparison group is significant at the 90% confidence level.
aEstimates are based on the number of persons in each category. For example, the percentage for males is the
number of male victims of identity theft divided by the total number of males age 16 or older multiplied by 100.
bExcludes persons of Hispanic origin (e.g., “white” refers to non-Hispanic whites and “black” refers to non-Hispanic
blacks).

41 Ibid.

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cIncludes Native Hawaiians, Other Pacific Islanders, American Indians, Alaska Natives, and persons of two or more
races.
Source: Bureau of Justice Statistics, National Crime Victimization Survey, Identity Theft Supplement, 2018.
This report further highlights that “victims of personal information misuse, [which includes
unauthorized use of personal information for fraudulent purposes such as getting a government
benefit] were more likely to experience severe emotional distress than [other victims].”42
2.1.1
How Does a Victim Seek ID Fraud Redress at the Federal Level?
For the purposes of this report, we have developed a use case of an individual who had their
identity stolen and used for fraudulent purposes. As identified in Figure 2-2, in this example, a
criminal used the victim’s social security number (SSN) to apply for federal benefits such as the
Paycheck Protection Program (PPP) loan through SBA. The criminal using this person’s SSN
also applied for unemployment benefits under the Pandemic Emergency Unemployment
Compensation Programs (PEUC). This use case will focus on 3 critical categories that relate to
the claimant’s perspective: awareness, available service channels, and ease of communication.

Figure 2-1. Defining the Problem from a Victim's Perspective
2.1.1.1
Awareness
In this scenario the victim of identity theft would have to proactively engage with each federal
agency where they think criminals may have used their identity leading to numerous potential
phone calls to disparate agencies who each have their own rules around the redress process. This
brings up two questions related to awareness:
1. When does a victim first realize that criminals have fraudulently used their identity?

42 Ibid.

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2. How does a victim learn about remedy available to them through the federal government?
2.1.1.1.1
When and How Do Individuals Learn they are Victims of Identity Theft?
According to a senior state unemployment official, in some cases victims aren’t aware until they
get a “benefits card for unemployment benefits and didn’t ask for it.”43 This would only occur if
the “fraudster went in, filed the claim, and didn’t change the address for whatever reason.”44 This
official went on to say, “then we get calls from employers asking why [a current employee] is
getting unemployment benefits.”45 In this case this official acknowledged that unless the
fraudulent actor makes a mistake, the citizen won’t know their identity was stolen until they get
their tax filings at the end of the year.46
Victim notification needs to be part of any eventual solution, whether that requires a reimagining
of how the American public tracks its benefit programs, or a focus on the use of technology to
send push notifications to the American public anytime a person accesses a benefit program.
2.1.1.1.2
How do Victims Learn About Remedy Options Through the Federal Government?
One of the concerns consistently articulated by victims and government officials interviewed for
this assessment, is that individuals don’t know where to start when they have their identity
stolen. One senior state official stated, “It gets very frustrating very quickly […] and I'm not the
most sophisticated person, but obviously I was a professional [senior state official] for years and
know how to do analysis. I could just imagine my brother [who is] a blue-collar worker going
through this. He'd be calling me [asking] what […] am I supposed to do here?”47 Another
national victim’s advocate stated that there “is the need for one place for people to start [the
redress process] without exception and not [multiple places]. You need one central place for
people to start and we can argue about everything in the middle.”48
“[There] is the need for one place for people to start [the redress process]
without exception and not [multiple places]. You need one central place for
people to start and we can argue about everything in the middle.”49 –
National Victim’s Advocate
A previous PRAC report identifies this concern by stating the following:
The victim redress process highlights a significant equity issue because
individuals may not be equipped to complete these steps if they have limited
understanding of the process or limited resources. While they can work with non-
governmental agencies such as the Identity Theft Resource Center, the
government resources in this area are not robust. The decentralized nature of the
government’s identity fraud redress process ultimately places the burden of

43 Senior State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.
44 Ibid.
45 Ibid.
46 Ibid.
47 Victim of Identity Theft. Videoconference interview by the author. McLean, VA. October 31, 2022.
48 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.
49 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.

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resolving identity theft and identity fraud on the victims. Currently, the victim
redress process largely relies on victims of identity fraud to take the necessary
actions to seek recovery and to be the drivers of the process.50
2.1.1.2
Available Service Channels
Once the victim in our use case is aware of the fraud, they will attempt to contact each of the
organizations where the criminal fraudulently used their identity, and other organizations where
they think their identity may have been used (e.g., credit reporting agencies and banks). When
asked which service channels they would prefer to use when contacting government, respondents
to a Pew Research survey stated:
1. Telephonic communications – preferred by 40-percent of respondents51
2. Website visits – preferred by 29-percent of Americans52
3. In person visits – preferred by 20-percent of Americans53
4. Email communication – preferred by 11-percent of Americans54
5. Smart phone apps – which are not currently widely available to the public.
“You go [to] that identitytheft.gov, and maybe it's because I'm not as tech
savvy, [but] I didn't see a chat [function where] I could chat with
somebody. Could I call somebody? Can I e-mail someone? It's just like,
here's an automated system … You're not talking to a human being, you're
talking to AI […], and AI is great in certain circumstances, but when I'm a
victim and I'm frustrated and I'm feeling like, oh, my God, my credit is
ruined, I can never unfreeze my credit if I ever apply for a loan again … to
not be able to talk to a human being is frustrating.”55 – Victim of Identity
Theft
Each federal agency has different ways that claimants can interact with them. The varying
available service channels provide our victim a very different experience with each organization.
Some agencies do not provide victims the ability to communicate with a live person. During
conversations with a national victim’s advocate group, one senior official said, “a lot of people
prefer the phone [because] they want to talk to a real live human being, and a lot of times it's not
just the advice that we give them, it's how it's presented. And because this is a traumatic
experience, they need that trauma informed care.”56 When speaking directly to a victim of
identity theft they told us, “You go [to] that identitytheft.gov and maybe it's because I'm not as
tech savvy, [but] I didn't see a chat [function where] I could chat with somebody. Could I call
somebody? Can I e-mail someone? It's just like, here's an automated system … You're not

50 Executive Council of the Inspectors General on Integrity and Efficiency. Key Insights: Identity Fraud Reduction and Redress
in Pandemic Response Programs. By Pandemic Response Accountability Committee. Washington, DC: PRAC, 2022.
51 Pew Research Center. "How Americans Get in Touch with Government." Pew Research Center. Last modified May 24, 2004.
Accessed November 18, 2022. https://www.pewresearch.org/internet/2004/05/24/how-americans-get-in-touch-with-
government/.
52 Ibid.
53 Ibid.
54 Ibid.
55 Victim of Identity Theft. Videoconference interview by the author. McLean, VA. October 31, 2022.
56 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.

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talking to a human being, you're talking to [artificial intelligence] (AI) […], and AI is great in
certain circumstances, but when I'm a victim and I'm frustrated and I'm feeling like, oh, my God,
my credit is ruined, I can never unfreeze my credit if I ever apply for a loan again … to not be
able to talk to a human being is frustrating.”
2.1.1.2.1
Equity and Accessibility
Having multiple service channels available to victims of identity theft also helps with the
concern of equity and accessibility for individuals with disabilities, and individuals who do not
speak English as their primary language or have limited English proficiency. A senior SSA
official when addressing this issue stated, “because many of our customers cannot use online
services, they visit our offices, or they call us. Those are the folks [for whom] English is not their
first language, they have severe mental impairments, they’re elderly, there are just any number of
barriers that our customers face. That's why we put so much effort into authenticating the
customer when they are in front of us when we have them with us, and we do a lot, we spend a
lot of time with them explaining because our programs are so complex.”57
The number of service channels proposed in any government-wide redress model needs to ensure
victims of identity theft have access to the appropriate avenues that consider the traumatic nature
of the harm inflicted on them (e.g., trauma informed advisors). Furthermore, the redress process
should ensure ease of accessibility to individuals with disabilities, and other demographics that
have aggravating conditions (e.g., individuals with limited English proficiency, or a person under
supervised care). Ultimately these service channels need to be compliant with federal civil rights
statues and executive orders (EO) to ensure agencies are providing their services in a manner that
is accessible for individuals with disabilities and those who have limited English proficiency.
EO 13985, titled “Advancing Racial Equity and Support for Underserved Communities Through
the Federal Government,” explicitly requires that federal agencies also ensure their programs
reach underserved communities.58
2.1.1.3
Ease of Communication
After identifying the proper service channel, our use case victim will submit a claim for redress
at the different federal agencies that oversee the benefit programs that were fraudulently
accessed. Some federal agencies such as SSA, SBA, and the IRS will refer victims seeking
redress in identity theft cases to a U.S. Federal Trade Commission (FTC) operated website called
identitytheft.gov. Victims of identity theft, when talking about identitytheft.gov, have stated, “it
was very frustrating to get emails and not be able to talk to a human being. Then to go into that
system and basically be told things I already know [wasn’t] helpful to me. I went in, did the
checklist, and by the time I got to the end of it, it's like […] You’re not telling me anything I
don't know. It was just [saying] freeze your credit, monitor your credit, and that's about it.”59 A
national victim’s advocate stated that, “time is of the essence when they're trying to begin this
process, and they can't do it for days, weeks, sometimes months, if [the FTC] keeps pointing
them at different jurisdictions.”60 The inability to get regular updates on an application status or

57 Senior Social Security Administration Official. Videoconference interview by the author. McLean, VA. November 15, 2022.
58 Exec. Order No. 13985, 86 Fed. Reg. 7009 (Jan. 25, 2021). https://www.federalregister.gov/d/2021-01753/page-7009
(accessed December 7, 2022)
59 Victim of Identity Theft. Videoconference interview by the author. McLean, VA. October 31, 2022.
60 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.

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speak to a person that can provide situational clarity into the process is a frustration that current
victims of identity fraud face.
2.2 The State and Federal Perspective
All the state and federal government officials interviewed for this report had one common trait.
They were all dedicated public servants who work tirelessly to support the citizens of their
respective jurisdictions. One state employee agreed with the statement that “on average most
federal and state employees want to do right by the citizens they serve.”61 Employees at the
different federal benefits delivery agencies included in this scan take identity theft and identity
fraud seriously. For the most part, these organizations have invested heavily in technology to
authenticate individuals applying for benefits, to include facial recognition technology, two-step
authentication, and in some cases the use of algorithms and filters to identify suspicious
behavior. This is on top of the manual processes instituted to authenticate applicants, which
include mandatory in-person visits to offices, and manual reviews of application patterns to
identify application inconsistencies. These measures focus on prevention of fraud. One senior
IRS official said, “The majority of [our work] is identity theft filtering … We do this in a multi-
prong approach. The first piece is we have models and filters in two different systems that act
differently, and this is our return review program and our dependent database. We also utilize a
manual fraud detection where we're looking for link analysis [through] various patterns and
trends that might not be picked up by our filters. So, we've got that manual component and we
apply resources to those analytics.”62 When asked if this particular component works primarily
on the prevention side versus the redress side of identity fraud, this official said, “yes that is
correct … We started introducing pre refund filters and the creation of the Taxpayer Protection
program that allowed an interaction with the taxpayer very early in the process before the refund
is paid so that taxpayer interacting with the IRS will confirm who they say they are, and then the
IRS will just release that refund.”63
“We've had a lot of success in in our fraud prevention activities. […] We
have been able to prevent millions, 10s of millions of dollars in benefits
from being paid because we've caught them before the claim was actually
paid. […] We are successful in preventing fraud, but in terms of the identity
theft redress, I don't know of any sort of KPIs that we have.”64 Senior SSA
Official
One senior SSA employee said, “We've had a lot of success in in our fraud prevention activities.
We have a number of things that we're doing [such as] fraud prevention units that look at
potentially fraudulent cases. We have a workload support unit that looks at anomalous claims
and we've been able to identify what could be potentially fraudulent activity. […] We've been
able to prevent payment of benefits by identifying those anomalous claims. So that's one
indication for us if we can catch them before benefits are paid. We have these cooperative

61 Senior State Unemployment Official. Videoconference interview by the author. Mclean, VA. November 8, 2022.

62 Senior Internal Revenue Service Official. Videoconference interview by the author. McLean, VA. November 07, 2022.
63 Ibid.
64 Senior Social Security Administration Official. Videoconference interview by the author. McLean, VA. November 15, 2022.

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disability investigation units, which are these units that we have representing all of our states and
territories. It's a collaborative effort with operations, OIG, and our state Disability Determination
Services. What they do is they look at potentially fraudulent claims that are filed and they
investigate those claims. [Those claims are] referred to these units and we have been able to
prevent millions, 10s of millions, of dollars in benefits from being paid because we've caught
them before the claim was actually paid. So those are some indicators that we use to show that
we are successful in preventing fraud, but in terms of the identity theft redress, I don't know of
any sort of key performance indicators (KPI) that we have.”65
These preventive measures against identity fraud have proven to be effective at mitigating
fraudulent benefits payments and reducing the caseload for identity fraud redress. Inevitably
there will be instances where preventive measures will fail, and agencies will pay fraudulent
benefits claims. This was apparent during the COVID-19 pandemic where, according to press
reports, “a top watchdog for the Labor Department estimated there could have been “at least”
$163 billion in unemployment-related “overpayments,” a projection that includes wrongly paid
sums as well as “significant” benefits obtained by malicious actors.”66
The federal and state employee perspective identified in this report centers on two main themes:
1. Frustration with the current identity fraud redress process, which includes a need to:
a. Establish redress policies and establish clear authorities.
b. Standardize thresholds and policies across the government.
c. Dedicate funding for redress programs.
2. The need to fix the “pay and chase” mentality around benefits delivery.
2.2.1
Frustrations with the Adjudication Process for Identity Theft
Redress
Federal and state employees who assist victims navigate the federal identity theft redress process
have expressed frustration with redress processes, or the lack thereof. Undoubtedly this cohort of
stakeholders on average are dedicated to assisting their constituents within the bounds of their
statutory and/or regulatory authority. During the COVID-19 pandemic these employees found
themselves working long hours to assist victims navigate the federal process. An employee of a
state unemployment office interviewed for this report when discussing the volume of claims their
office was processing at the time said, “[during the pandemic] we were working 16- to 17-hour
days for about seven months. Even on Sundays we were having meetings. It was terrible. I don’t
want to ever have to go through that again.” The gaps in the current federal redress process, are
not because of a lack of willingness to serve the victims of identity theft and fraud, rather we
consistently heard state and federal employees are frustrated with the following three elements of
the identity theft redress process:
1. The lack of established identity theft redress processes within certain institutions.

65 Ibid.
66 Romm, Tom, and Yeganeh Torbati. "'A Magnet for Rip-off Artists': Fraud Siphoned Billions from Pandemic Unemployment
Benefits." The Washington Post (Washington, DC), May 15, 2022. Accessed November 18, 2022,
https://www.washingtonpost.com/us-policy/2022/05/15/unemployment-pandemic-fraud-identity-theft/.

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2. The lack of standardization of thresholds and policies when those policies exist.
3. The need for dedicated funding for redress programs to ensure prioritization.
“There needs to be dedicated funding for [a redress process] because that is
how priorities are set. Whether it's at the Congressional level or [at the
Executive level], it needs to be funded because that to me indicates it's a
priority. But to ask agencies to take this on as an unfunded need, I think
that's where you're going to have difficulty [implementing an effective
redress process] … [especially since across government] we're facing a
historic staffing and attrition crisis in our agencies. I cannot keep my
frontline employees and I know other agencies are in the same place. So,
for this to be a priority within SSA, it really would have to be funded. It
could not just be something that I could absorb.”67 – Senior Social Security
Administration Official
2.2.1.1
Need to Establish Redress Policies and Establish Clear Authorities
This report finds that only IRS, the VA and SBA of the six agencies of interest for this report
have an existing identity theft and identity fraud redress process. The other three agencies neither
have an existing policy, internal investigation processes, or provide an official remedy to victims
of identity theft. All six agencies have invested heavily in identity theft and identity fraud
prevention.
In one case, prior to the influx of identity fraud claims due to COVID-19, a federal agency did
not have a redress policy in place until millions of applicants had submitted their claims.68
Thankfully this agency had the ability to quickly establish a process for their constituents to seek
redress. One federal deputy inspector general in an interview for this report identified that no
matter the level of defenses in place some fraud will come through and you need to have a
redress process in place to assist the victims of identity fraud.69
This sentiment was consistent across interviews with state and federal employees. One state
employee speaking to the lack of policies that facilitate coordination between the states and the
federal government stated, “it was a frustration, and back in 2009 I actually spoke at a forum in
DC and [told them] you are so focused on agencies and the Beltway, you don't even realize
what's happening out at the local level or at the state level. You've got to get your head outside
[the Beltway]. [There needs to be a] focus on working with States because the money's coming
to the State and then it's passing through to the locals.  [I went on to tell them], if you're focused
on the federal agencies and the District of Columbia (D.C.), you're missing 90% of the issue.”70
2.2.1.2
Standardization of Thresholds and Policies
Where federal agencies have existing redress policies in place (for the purposes of this report
these agencies are the SBA and the IRS), there is a lack of standardization of thresholds for what
constitutes identity theft, and those agencies conceived existing redress policies within

67 Senior Social Security Administration Official. Videoconference interview by the author. McLean, VA. November 15, 2022.
68 Federal Deputy Inspector General. Videoconference interview by the author. McLean, VA. November 11, 2022
69 Ibid.
70 Former Senior California State Official. Videoconference interview by the author. McLean, VA. October 31, 2022.

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institutional silos. This ultimately means that the victim of identity fraud will consistently have a
different experience as they seek redress from different federal agencies unless there is
collaboration across silos to establish best practices through standardization of processes where
permissible by statute and regulation.
One senior SSA official speaking to the concern of standardization stated that, “every agency has
unique processes and would need information in order to verify identity theft. It's starting at a
threshold matter. We are working [internally] with the agency on what qualifies as an identity
theft event. […] How are you going to vet this? Does there have to be a financial loss? What
thresholds would you use?71
2.2.1.3
Dedicated Funding for Redress Programs
Having dedicated funding for a program initiative has a dual effect. It first ensures that you have
the proper resources to address the problem (e.g., personnel and tools), and second it is a
signaling mechanism to administrators that the program is essential. Dedicated funding also
comes with specific KPIs. A senior SSA official interviewed for this report stated, “there needs
to be dedicated funding for [a redress process] because that is how priorities are set. Whether it's
at the Congressional level or [at the Executive level], it needs to be funded because that to me
indicates it's a priority. But to ask agencies to take this on as an unfunded need, I think that's
where you're going to have difficulty [implementing an effective redress process] … [especially
since across government] we're facing a historic staffing and attrition crisis in our agencies. I
cannot keep my frontline employees and I know other agencies are in the same place. So, for this
to be a priority within SSA, it really would have to be funded. It could not just be something that
I could absorb.”
2.2.2
Fixing Pay and Chase
The Washington Post reported that, “In the face of an unprecedented crisis, federal officials
consistently chose haste over precision, dispatching aid with uncharacteristic speed to save the
economy — even at the risk of costly mistakes.”72 Though the exact scope of this theft is
unknown, according to press reports, “a top watchdog for the Labor Department estimated there
could have been ‘at least’ $163 billion in unemployment-related ‘overpayments,’ a projection
that includes wrongly paid sums as well as ‘significant’ benefits obtained by malicious actors.”73
It is important to understand the economic reality Americans faced in the throes of this
pandemic.  According to news reports in May 2020, “over 33 million Americans filed for initial
jobless claims as a result of the coronavirus pandemic, which routed some industries to
Depression-era levels.”74 Beyond the health emergency, COVID-19 had also engendered an
economic crisis for the American people.

71 Senior Social Security Administration Official. Videoconference interview by the author. McLean, VA. November 04, 2022.
72 Romm, Tom, and Yeganeh Torbati. "'A Magnet for Rip-off Artists': Fraud Siphoned Billions from Pandemic Unemployment
Benefits." The Washington Post (Washington, DC), May 15, 2022. https://www.washingtonpost.com/us-
policy/2022/05/15/unemployment-pandemic-fraud-identity-theft/ (accessed November 18, 2022)
73 Ibid.
74 NBC News. "Over 76,000 Dead as 33 Million File for Unemployment in U.S." NBC News. Last modified May 8, 2020,
https://www.nbcnews.com/health/health-news/live-blog/2020-05-07-coronavirus-news-n1201801 (accessed November 18,
2022)

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Federal and state employees interviewed for this report sympathized with the economic reality at
the time but stated that a situation where an agency pays the total amount allowable under statute
and seeks reimbursement from a third party is ineffective because it is very difficult to collect on
those funds; this situation is colloquially known as “pay and chase.” One federal deputy
inspector general stated that prevention on the front end “will cut down the volume for redress on
the backend […] if you don’t have a process in place to verify eligibility in a meaningful way,
this is what you see. I don’t believe the problem is redress. You can’t pay and chase.”75
Research for this environment scan and the interviews with federal officials have led to one key
observation that prevention and redress policies must be instituted in tandem with one another. It
is difficult to separate these two processes because a lack of preventative measures will
overwhelm any redress system in place.

75 Federal Deputy Inspector General. Videoconference interview by the author. McLean, VA. November 11, 2022

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3 Guiding Principles for A Path Forward
Prior to developing a detailed whole-of-government redress process and identifying the design
elements required to support it, this report develops the precepts that place the claimant at the
center of the federal redress process and empowers agencies to provide a remedy to the victims
of identity fraud. These guiding principles should stay constant irrespective of changes in
strategies, goals, or leadership. To this end, this report enumerates these guiding principles based
on the interactions with victims of identity theft, government employees (both state and federal)
who interface with these victims and have oversight over the redress process, and identity fraud
victim’s advocates groups.

Figure 3-1 Identity Fraud Redress Guiding Principles: An Enterprise Perspective
With the understanding that guiding principles set a standard for how an organization operates,
this report starts by viewing the future design of the federal identity fraud redress process as one
enterprise that encompasses four key stages of engagement, as identified in Figure 3-1:
1. Service channels that would serve as the line of interaction for the public, and account for
the need for trauma-informed care, and accessibility as identified in Section 4.1 of this
report.
2. The front stage of the core business, which in this case would be the central customer
facing process. Here the public would have a common feel when engaging in the redress
process across government.
3. The backstage of the core business where back-end interconnected systems and processes
would operate by facilitating the investigation and adjudication process. A line of
visibility separates this stage of the engagement from the front stage, which this report
identifies in Section 4.3 as the one-stop redress platform. This will allow each benefits

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delivery agency to continue to work within their lane of authority and exercise their
expertise in their benefits space.
4. The key system enablers such as the IT capabilities and the digital ecosystem that
supports data collection, transmission, storage, and security.
Each stage of the enterprise engages two central stakeholders:
1. The victims of identity fraud who are submitting a claim to seek redress, and
2. The government officials who process redress claims.
Figure 3-2 provides a graphical representation of the guiding principles associated with the
victim’s perspective. These guiding principles include:
1. The federal redress process should be viewed from an enterprise perspective where
claims are processed via a one-stop shop to ease the burden on the victim.
2. The process should acknowledge the distress associated with being a victim of identity
theft by providing trauma-informed care and advocacy.
3. Victim interactions with the federal redress enterprise should be founded on the
principles of due process and fairness.
4. The federal redress process should increase equity, inclusivity, accessibility, and security
through the appropriate service channels because identity theft cuts across all
demographics, including individuals with limited English proficiency and individuals
with disabilities.
5. Keep the victims of identity theft informed throughout the redress process.

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Figure 3-2 Guiding Principles: The Victim's Perspective

Figure 3-3 provides a graphical representation of the guiding principles associated with the
federal benefits administrator’s perspective. These guiding principles include:
1. Establish an identity fraud redress process with clear policies that delineate authorities
and responsibilities.
2. Provide dedicated funding for redress programs.
3. Facilitate data sharing across government silos.
4. Standardize redress thresholds, policies, and language across government.
5. Minimize impacts on current operations and budgets.

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Figure 3-3 Guiding Principles: The Government's Perspective

These ten guiding principles, summarized in Error! Reference source not found., have
informed the design elements identified in Section 4 of this report.
Table 3-1 Identity Fraud Victim Redress - Overall Needs by Cohort
Needs
Victim Needs
State and Federal Needs
1
Create a one-stop-shop.
Establish redress programs and policies
that define clear authorities.
2
Provide trauma-informed assistance.
Dedicate funding for redress programs.
3
Establish the principles of due process
and fairness throughout the engagement.
Facilitate data sharing across
government silos.
4
Establish equity, inclusivity,
accessibility, and security by offering
appropriate service channels.
Standardize redress thresholds, policies,
and language across government.
5
Keep the victim informed throughout the
process.
Minimize impacts to current operations
and budgets.

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4 The Design Elements of a New Redress Process
Addressing the problems identified in Section 2, while incorporating the themes from the guiding
principles in Section 3, requires the federal government to adopt a digital transformation and
embrace a streamlined one-stop shop claimant-centric approach. This will revolutionize the way
victims of identity fraud interact with federal benefits-delivery agencies. The model provides
claimants the ability to login into one central platform and have access to all the benefits delivery
agencies participating in this framework, as opposed to having to seek redress from each
individual agency.
This section will start by developing a business framework for the redesigned redress process,
then define the lifecycle phases of this new framework. The report will then pivot to a detailed
explanation of the design elements of the platform needed to make the business framework
operational. Lastly this section will develop a hypothesis of analysis based on available
authoritative research pertaining to integrated benefits delivery both in the US and overseas. This
research takes a comparative view of why, and how, government institutions have integrated
their benefits delivery system and is based on findings from organizations such as MITRE, the
World Bank, Code for America, The Center for Budget and Policy Priorities (CBPP), and other
peer-reviewed journal articles.
4.1 One-Stop Shop Business Framework
The proposed one-stop shop model for federal identity theft redress would serve as an integrated
benefit delivery system. This report defines an integrated benefit system as “the mechanism by
which the different government stakeholders in the benefits space interconnect systems,
processes, and platforms to create a system that ensures the ease of service delivery by serving
the public quickly, securely, and equitably.”76 Specifically, a one-stop shop is “a single point of
contact “where governments can collect data for one or more services through a single,
integrated digital form” and deliver services and information from different entities.77 The one-
stop shop is defined by the following features: integrated data collection without proactive or
predictive benefits delivery.78 It is a centralized platform for delivering e-government services.79
In a one-stop shop, the interface, or front office, is designed such that the benefit seekers use one
interface to request services from the various government departments.80 The one-stop shop
“requires that all public authorities are interconnected and that the [benefits seeker] is able to
access public services at a single point even if these services are provided by different public
authorities or private service providers.”81 In sum, the centrality of the services should be

76 Fujita, Megumi K., Josh LeFevre, Samir Salifou, and Joshua I. Schwartz. Integrated Benefits Delivery: An
Environmental Scan of Current Systems in the United States and around the Globe. McLean, VA: MITRE, 2021.
77 Becker, Jorg, Marek Kowalkiewicz, Willem Martens, and Hendrik Scholta. "From One-Stop Shop to No-Stop
Shop: An E Government Stage Model." Government Information Quarterly 36, no. 1 (January 2019): 11-26.
https:// https://www.sciencedirect.com/science/article/pii/S0740624X17304239 (accessed March 24, 2023)
78 Ibid.
79 Ibid.
80 Ibid.
81 Wimmer, Maria A. "A European Perspective Towards Online One-Stop Government: The eGOV Project."
Electronic Commerce Research and Applications 1, no. 1 (Spring 2002): 92-103.

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apparent to the applicant, since they have only one centralized location to request benefits that
cut across government.”82
Notably the one-stop shop allows each benefits delivery agency to continue to work within their
lane of authority and exercise their expertise in their benefits space. Although an applicant may
go to one central location to apply for redress if, for example, a criminal fraudulently used their
identity at IRS and SBA, each agency would be able to conduct its own investigation into the
matter and provide periodic updates to the applicant while sharing data with other benefits
delivery agencies participating in this shared framework. This ensures the applicant only goes to
one location to seek relief, while other benefits delivery agencies can flag that applicant’s
personally identifiable information (PII) to ensure they apply extra scrutiny to any request for
benefits given the pattern of fraud.

Figure 4-1 One-Stop Shop Business Framework
The business process illustrated in Figure 4-1 serves as a basis for the one-stop federal redress
platform outlined in Section 4.3 below. This new business process would allow an applicant to
pick one of five service channels to submit a redress claim to all benefits delivery agencies who
participate in the redress platform. Those service channels include:
1. In-person at local offices
2. Telephonic customer support
3. Online application and submission with secure data sharing

https://www.sciencedirect.com/science/article/pii/S156742230200008X?viewFullText=true (accessed March 9,
2023)
82 Fujita, Megumi K., Josh LeFevre, Samir Salifou, and Joshua I. Schwartz. Integrated Benefits Delivery: An
Environmental Scan of Current Systems in the United States and around the Globe. McLean, VA: MITRE, 2021.

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4. iOS and Android Applications
5. Mail
Once the claimant submits this application, the system would route information to the relevant
agency where there is known fraudulent data and share the applicant’s data across participating
agencies (where it is not explicitly prohibited by statute) to prevent further fraud associated with
the claimant’s PII.  The agencies would also be able to share data and request data from the
applicant via the applicant’s service channel of choice. Finally, this integrated platform would be
able to aggregate reporting and accounting data for federal and congressional oversight. Though
this high-level one-stop shop business framework outlines the general process, the one-stop
federal redress platform outlined in Section 4.3 will provide further details.
4.2 Lifecycle Phases
For the purpose of this analysis – and consistent with previous MITRE research into benefits
delivery – this report defines a benefit program as an “intervention intended to ‘build equity,
opportunity, and resilience for people by providing income or other resources to reduce poverty
and inequality, support investments in human capital, and help insure against shocks and various
risks’ such as loss of income from disability or age, economic crisis, natural disaster and climate
change.”83 84 To this end, seeking redress from the federal government is intrinsically a benefits
seeking activity because an individual is attempting to mitigate a risk, and needs to actively
request that the government investigate, adjudicate, and remedy the alleged wrong.
In 2020, the World Bank published a report titled Sourcebook on the Foundation of Social
Protection Delivery Systems. The World Bank report is an assessment of benefits delivery
systems through an international comparative analysis and identifies nine common phases of the
benefits delivery process. In this study, we use the findings of the World Bank report to inform
our description of the federal redress lifecycle. Seeking redress for the fraudulent use of one’s
identity requires a victim to submit an application that an institution needs to process as they
would any other benefit determination.
Below, this analysis provides an in-depth description of the redress lifecycle phases.
1. Outreach and Education: This is a requirement to convey the existence of the redress
process to the public. Benefits delivery agencies must educate the potential registrant of
the availability of that program’s benefit. Whether done proactively or passively, there is
a requirement to communicate the availability of the redress processes to the public.
Inputs for this business requirement include messages, communication tools, and active

83 K. Lindert, T. G. Karippacheril, I. R. Caillava, and K. N. Chávez, eds., Sourcebook on the Foundations of Social Protection
Delivery Systems, Washington, DC: World Bank, 2020. doi:10.1596/978-1-4648-1577-5. License: Creative Commons
Attribution CC BY 3.0 IGO at 1.
84 Fujita, Megumi K., Josh LeFevre, Samir Salifou, and Joshua I. Schwartz. Integrated Benefits Delivery: An Environmental Scan
of Current Systems in the United States and around the Globe. McLean, VA: MITRE, 2021.

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searches.85 Outputs for this phase of the lifecycle include identifying the intended
population groups and ensuring they understand the program.86
2. Applicant Intake and Registration: This is how individuals apply for assistance and
engage with the redress programs. Intake is the process of gathering information, while
registration is the process of recording and verifying that information.87 Benefits agencies
must intake applicant information or they cannot process claims. This is the phase where
the five service channels described in section 4.1 will play a central role as the line of
interaction for the public, and account for the need for trauma-informed care, inclusivity,
and accessibility. The primary input for this requirement is people applying for benefits.88
“The primary output for [this phase of the lifecycle] is having complete information on
the applicant that is verified and validated for use as an input to the assessment of needs
and conditions.”89
3. Assessment of Needs and Conditions: This requirement is part of the adjudication
process. It constitutes the due diligence requirements of each program to validate the
information provided during the application intake. Furthermore, it is consistent with the
guiding principle of having a redress process that is founded on the principles of due
process and fairness. This phase is also an initial assessment for the level of restitution
that the applicant is due based on their specific conditions. The input for this requirement
is complete, validated and verified information. The output produced is a completed
profile of the applicant.90
4. Eligibility and Enrollment: With a completed profile of the registrant, the benefits
agencies would then compare the registrant’s profile to the eligibility criteria derived by
that program’s statutes or regulations to determine eligibility and make a decision on the
applicant’s claim. The output of this requirement is a rules-based determination.91 This
fact-based determination could be anything from freezing the victim’s benefits to avoid
any further damage, to referring the applicant’s case to the US Department of Justice.
5. Determination of Benefits and Services: Once the benefits agency has made a rules-
based decision on the applicant’s eligibility they must decide how much restitution the
victim should receive based on the facts of the claim.92
6. Notification and Onboarding: The benefits programs would then notify all parties to the
claim of the eligibility decision and the determination of benefits. The agencies would
also onboard that claimant by explaining the rules and conditions of their eligibility, and
how they can better protect their identity and use their benefit.93

85 K. Lindert, T. G. Karippacheril, I. R. Caillava, and K. N. Chávez, eds., Sourcebook on the Foundations of Social
Protection Delivery Systems, Washington, DC: World Bank, 2020. doi:10.1596/978-1-4648-1577-5. License:
Creative Commons Attribution CC BY 3.0 IGO.
86 Ibid.
87 Ibid.
88 Ibid.
89 Ibid.
90 Ibid.
91 Ibid.
92 Ibid.
93 Ibid.

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7. Provision of Benefits and Services: Benefits agencies must ensure restitution is funded
in accordance with the eligibility decision and the determination of benefits and services
sent to the parties of the claim. Inputs for this phase of the process includes the
applicant’s account information (if a disbursement of funds is necessary). Output includes
the payment of benefits to the claimant.
8. Benefits Compliance, Updating, and Grievances: Benefits agencies must be able to
comply with statutory and regulatory stipulations of their programs that call for oversight.
This includes maintaining a system of record for audits and oversight management. The
benefits agencies must conduct beneficiary operations management to ensure the
beneficiary’s continuity of eligibility (e.g., the IRS Pin Program). Agencies can do this
through periodic reassessments. Agencies must also ensure that applicants can file
grievances and appeals through the management of some grievance redress mechanisms
(GRM).94
9. Exit Decision, Notification and Case Outcomes: The agencies would notify
beneficiaries who are no longer eligible, or who have been fully compensated for the
benefit to which they are entitled, that they will be exiting the program. As a part of
compliance efforts to the public overseers of benefits agencies, the benefits delivery
agencies must capture and store metadata on the case outcomes and explain how the
agency’s financial intervention affected the cohort of interest.
Figure 4-2 provides an overview of the inputs and outputs of the lifecycle phases defined above,
as well as a flow of how requirements depend on one another along the benefits delivery chain.
Figure 4-3 provides a view of the registrant and applicant pool as they move along the benefits
delivery chain up to the provision of benefits requirement. As this delivery chain progresses,
through each step, the population shrinks.

94 Ibid.

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Figure 4-2 Federal Redress Lifecycle Phases95

95 Ibid.

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Figure 4-3 Applicant Population Along the Redress Lifecycle96
4.3 One-Stop Federal Redress Platform
The one-stop shop business process identified in Figure 4-1 informed the development of the
one-stop federal redress platform below in Figure 4-4. Whereas the guiding principles elucidated
in Section 3 provides high-level precepts for two key stakeholders (i.e., the victim and the
government staff), this platform provides a detailed review of the many stakeholders who
support and oversee the redress process. Within the context of the enterprise perspective of the
redress process defined in Figure 3-1 above, this platform would serve as the line of visibility
between the applicant and all participating benefits delivery agencies. Furthermore, this platform
comprises the core design elements that satisfy the capabilities of this new system. Figure 4-4
depicts the one-stop federal redress platform and includes a capability list applicable to all the
stakeholders who interact with these processes. There are six categories of stakeholders:

96 Ibid.

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1. Government Staff: These are the government officials who process the redress claims at
the various participating agencies. This would require a workflow state, data analytics
capabilities, and a secure login into the database.
2. Claimant: These are the individuals who seek redress for an incident of identity fraud.
3. Call Center: These are the individuals who receive calls through that service channel.
Call centers can also process two-way short message service (SMS) communications, as
well as Android and iOS application requests and questions.
4. External Gov Sources: These parties include Federal Agencies who manage the
databases used for criminal investigations (e.g., FBI NICS and FTC Consumer Sentinel).
This category of stakeholders also includes the state and local officials who manage
programs that interact with the participating federal benefits delivery agencies.
5. Private Sector Parties: This includes the private sector partners who can serve as a
pipeline for notification of fraud, as well as the organizations and databases federal
employees use for good standing verification of the applicant.
6. Congressional and Executive Oversight: This includes congressional oversight
committees, the Office of Management and Budget (OMB), and public auditors.

Figure 4-4 One-Stop Federal Redress Platform

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4.4 Redress Process Capability Needs
The stakeholders listed in section 4.3 need the following proposed capabilities as part of the
design elements of the new one-stop shop identity fraud redress process:
1. The ability to exchange applicant information in a digital format in real time.
2. The ability to securely authenticate and prescreen applicant data.
3. The ability for government employees to login once for access to systems and
applications required to process the applicant’s file.
4. The ability to readily access source data throughout the course of the claims investigation
process to make an informed adjudication of the facts as presented by the applicant and
the parties to the claim. This would support investigative efforts across federal agencies.
5. The ability to have a simplified view of the complete applicant file.
6. The ability to automate data capture and data processing.
7. The ability to integrate/interface with external systems via file transfer, webservices, or
application programming interface (API).
8. The ability to integrate all reporting systems to provide canned and ad hoc reporting.
9. The ability for all parties to reach help desk support for all processes (technical and non-
technical).
10. The ability for applicants to have a real-time completion status on the progression of their
request.
Figure 4-5 below provides a distribution of these capability needs by stakeholder.

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Figure 4-5 Distribution of Capability Needs by Stakeholder

Table 4-1 provides a breakdown of capabilities by providing a detailed description of that
capability.
Table 4-1 Potential Capability Needs with Description
Capability Title
Capability Description
Analytics
A system or capability that can retrieve data from the claimant-centric hub, combine and
derive information from it to be used for review and analysis.
Cloud Platform
The service used to provide on-demand availability of computer system resources,
including data storage and computing power, without direct active management by the
user to house custom software, PaaS platforms and SaaS software systems.

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Capability Title
Capability Description
Customer
Relationship
Management (CRM)
A tool, strategy, or process that helps business better organize, access, analyze and
manage customer data.
Data Management
The practice of collecting, keeping, organizing, maintaining, and using data securely and
efficiently.
Document
Management
A system used to receive, track, and store documents.
Document - OCR
Scanning
A technology used to distinguish printed or handwritten text characters inside digital
images to enable the parsing into defined datapoints.
Documentation
Verification
This tool will provide a “verify before validate” rule “verifying” that the documents
submitted by the victims are complete and accurate before proceeding to the “validation”
of the documents.
Eligibility
Eligibility automation tools are an initial step before the investigative process. Eligibility
automation will enable claimants to verify they meet all the eligibility requirements for
redress.

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Capability Title
Capability Description
Risk Management
This tool will identify claimants with complex situations that have a higher propensity
for fraud and tag them as high risk; and those with a less complex situations and thus a
lower propensity for fraud and tag them as low risk. This risk determination will assist in
triaging applications for the government staff who investigate each case. Agencies will
determine the risk assessment factors based on past indicators of fraud since bad actors
may fraudulently apply for redress.
Help Desk
A service and associated tools to provide information and support to users.
Real-Time Coaching
This tool will guide the victims throughout each screen with a real-time clear user-
friendly description of what they need to submit on the specific screen. Throughout each
step, if the tool discovers some discrepancy, the claimant will be notified in real-time
what is needed to correct the issue before moving to the next screen.
Workflow
A platform or tool to sequence administrative or other processes through which a piece
of work passes from initiation to completion.
Workflow – Data
Integration
A platform or tool, specific to data integration, to sequence, join, and parse data as the
work using such data passes from initiation to completion.

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4.5 Past Implementations of One-Stop Platforms Across
Government
Implementing the proposed one-stop federal redress platform necessitates a review of other
integrated benefits delivery systems and one-stop style systems across the United States at the
state and federal government levels.
4.5.1
State Government Implementation
In December 2021 MITRE published a report on integrated benefits delivery. The report, titled
“Integrated Benefits Delivery: An Environmental Scan of Current Systems in the United States
and around the Globe,” revealed that U.S. States have successfully integrated their delivery of
disparate federal benefits, including the Supplemental Nutrition Assistance Program (SNAP)
operated by the U.S. Department of Agriculture (USDA), Medicaid, and the Low-Income Home
Energy Assistance Program (LIHEAP) operated by the U.S. Department of Health and Human
Services (HHS).97 The report further noted that the CBPP and Code for America have partnered
with other public benefits corporations and states to run a project called “The Integrated Benefits
Initiative.”98 The pilot is focused on 5 states, yet as of 2019, 44 states have integrated their
benefits delivery with at least two benefit types, while 13 have fully integrated 4 or more federal
social service benefits into one application, delivery system, and management system.99
These facts have led to the formulation of this testable hypothesis of analysis:
Since US states can provide an integrated-benefits common application, delivery
system, and management system for disparate benefit types, victims of identity fraud
should be able to seek redress from federal benefits delivery organizations through
the same means.
4.5.2
Federal Government Implementation
Similar systems include:
1. Consumer Sentinel Network – For law enforcement coordination of identity fraud
Consumer Sentinel is an investigative cyber tool that provides members of federal, state,
and local law enforcement access to criminal reports about consumer scams and identity
theft and fraud related to federal benefit programs.100 Consumers submit reports when
making claims on the FTC website and other reports are provided by data contributors.

2. Organized Crime Drug Enforcement Task Forces (OCDETF) – OCDETF is the largest
anti-crime task force in the country. OCDEFT is an independent component of the DOJ
established to combat transnational-organized-crime and to reduce the availability of

97 Fujita, Megumi K., Josh LeFevre, Samir Salifou, and Joshua I. Schwartz. Integrated Benefits Delivery: An Environmental Scan
of Current Systems in the United States and around the Globe. McLean, VA: MITRE, 2021.
98 Ibid.
99 Code for America, "Bringing Social Safety Net Benefits Online Examining online platforms for all 50 states." Last modified
August 2019. Accessed March 09, 2023. https://www.codeforamerica.org/features/bringing-social-safety-net-benefits-online/.
100 [6]

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illicit narcotics in the nation by using a prosecutor-led, multi-agency approach to
enforcement. OCDETF leverages the resources and expertise of its partners in
concentrated, coordinated, long-term enterprise investigations of transnational organized
crime, money laundering, and major drug trafficking networks.101 OCDETF implements a
nationwide strategy combining priority targeting, coordination, intelligence sharing, and
directed resourcing to have the greatest impact disrupting and dismantling command and
control elements of criminal organizations.

4.6 The Benefits of Utilizing a Common Process Platform
This analysis now turns to the benefits of utilizing a common business process across the
benefits delivery space and further shows that standardizing and enumerating a series of business
lifecycle functions, activities, business capabilities, business use cases, and standardized data
elements has specific benefits as outlined in the Federal Integrated Business Framework (FIBF)
approach.102 According to the President’s Management Agenda (PMA) of 2019, “State
governments, nonprofits, and businesses (including more than 90% of Fortune 500 companies)
have reduced costs and improved effectiveness by adopting shared services. By driving standards
in capabilities, data, business processes and technology to streamline administrative activities,
leaders in these fields have found the greatest gains in efficiency.”103
This section of the report demonstrates how utilizing a common business process will help
Federal government agencies achieve the following six benefits:
1. Leveraging best practices across agencies,
2. Capturing economies of scale,
3. Shortening claim resolution timeframes,
4. Alleviating common victim frustrations,
5. Alleviating common employee frustrations and,
6. Meeting the current administration’s PMA and Executive Order (EO) 14058, titled
transforming federal customer experience and service delivery to rebuild trust in
government.
4.6.1
Leveraging Best Practices
This report has established that despite the constraints of their unique statutory and regulatory
landscape, benefits delivery agencies have common capability needs as it pertains to federal
redress processes. Furthermore, this report frames the federal identity fraud redress process as
one enterprise to develop both a common business framework (see section 4.1), and a common

101 [5]
102 The Federal Integrated Business Framework (FIBF) is a model that enables the Federal government to better coordinate and
document common business needs across agencies, focusing on outcomes, data, and cross-functional end-to-end business
processes.
103 Office of Shared Solutions and Performance Improvement. "Centralized Mission Support Capabilities for the Federal Govern
ment." Shared Services. Last modified March 2020. Accessed March 9, 2023. https://ussm.gsa.gov/assets/files/SQS-Public-FAQs
-April-2020.pdf.

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business platform (see Section 4.3). However, in the current environment, each agency operates
in silos and conducts aspects of its business differently by utilizing different processes and tools
to achieve common desired outcomes. In some instances, agencies do not have an existing
identity fraud redress program in place outside of their OIGs (e.g., SBA and SSA), while others
have clearly articulated rules for how individuals can seek redress from the agency (e.g., the IRS
and the VA). The FTC, for example, has endeavored to use a one-stop shop system for law
enforcement purposes through the Consumer Sentinel system, which is available to all law
enforcement entities, not for comprehensive victim assistance and coordination.
Another example of this siloed approach is at the IRS where the Taxpayer Protection Program
(TPP) utilizes a “multi-pronged approach” to identity theft prevention to alleviate the case load
of individuals seeking redress. By using “link analysis [to identify] various patterns and trends
that might not be picked up by [existing filters].”104 IRS and SSA currently use these types of
preventative capabilities, but they are less prevalent with other benefits delivery agencies.
Leveraging best practices will promote process optimization across all agencies by replicating
proven and effective practices.
4.6.2
Capturing Economies of Scale
Moving from a siloed operation where agencies administer separate redress programs to a
common business platform that views the federal redress process as one enterprise will promote
economies of scale from the utilization of common policies to shared IT and business services.
According to the Organization of Economic Cooperation and Development (OECD), economies
of scale “refer to the phenomenon where the average costs per unit of output decreases with the
increase in scale of magnitude of the output being produced.” By merging certain activities such
as vendor services and reporting capabilities, the fixed cost of those activities will reduce the per
claimant cost of processing an application.105 In a research paper published in the journal
Government Information Quarterly Gouscos et al. argue that “lowering of unit costs for
administrative transactions, combined with increased visibility of services that form part of one-
stop offerings, provides favorable conditions for increasing transaction volumes.”106 In summary,
sharing the fixed costs of processing federal identity theft redress claims by pooling the increased
volume of claimants with common vendor will help alleviate administrative fiscal burdens of
operating these programs. This finding is in line with the guiding principle which calls for
redress programs to minimize impacts to current operations and budgets.
4.6.3
Shortening Claim Resolution Timeframes
CBPP and Code for America have partnered with other public benefits corporations and states to
run The Integrated Benefits Initiative across multiple states, and they have been tracking data on
the quantifiable benefits that come with using a consolidated business model utilizing technology
to automate processes.107 Michigan, having participated in this initiative, has seen substantively

104 Senior Internal Revenue Service Official. Videoconference interview by the author. McLean, VA. November 07, 2022.
105 Gouscos, Dimitris, Manolis Kalikakis, Maria Legal, and Soumi Papadopoulou. "A General Model of
Performance and Quality for One-Stop E-Government Service Offerings." Government Information Quarterly 24,
no. 4 (October 2007): 860-85.
106 Ibid.
107 Fujita, Megumi K., Josh LeFevre, Samir Salifou, and Joshua I. Schwartz. Integrated Benefits Delivery: An Environmental
Scan of Current Systems in the United States and around the Globe. McLean, VA: MITRE, 2021.

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significant positive impacts on its benefits delivery system as identified in Figure 4-6. These
impacts included a 77% reduction in the application time, an increase of 17% in the approval
rate, and a 15% reduction in the days to determination of eligibility.108 Although this report is not
making the assertion that existing redress programs will see comparable benefits, these numbers
indicate that process integration, leveraging best practices and systems automation have led to
shortening the benefits delivery timeframe in comparable instances.

Figure 4-6 The Impacts of Automation and Using a Common Business Platform in Michigan109
4.6.4
Alleviating Common Victim Frustrations
Section 2.1 of this report highlights the common frustrations expressed by victims of identity
theft. These frustrations centered around the following themes:
1. The burdensome need for the victim to navigate the siloed federal redress processes where
they exist and submit multiple applications where necessary.

108 Civilla and Code for America, “Streamlining Access to Public Benefits in Michigan: Designing a User-Centered Digital
Enrollment Experience.” 2019. Accessed March 27, 2023. http://s3-us-west-1.amazonaws.com/codeforamerica-
cms1/documents/Streamlining-Access-Report_Integrated-Benefits-Initiative-Civilla_Code-for-America_March-2019.pdf
109 Ibid.

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2. The lack of inclusive, equitable, and secure service channels to accommodate all
demographics who are victims of identity theft.
Viewing the federal redress process as one enterprise, with a single front door that serves as a
one-stop shop, will alleviate these two concerns as well as meet the guiding principles outlined in
Section 3.
4.6.5
Alleviating Common Government Employee Frustrations
Section 2.2 of this report highlights the common frustrations expressed by government officials
who interact with the victims of identity theft. These frustrations centered around the following
three themes:
1. The lack of established identity theft redress processes within certain institutions.
2. The lack of standardization of thresholds and policies when those policies exist.
3. The need for dedicated funding for redress programs to ensure prioritization.
Viewing the federal redress process as one enterprise, instead of several silos, will alleviate these
three concerns as well as meet the guiding principles outlined in Section 3 by providing the
capabilities outlined in Section 4.3.
4.6.6
Meeting the Intent of the Current Administration’s PMA and
Executive Order (EO) 14058
Increasing trust in government through effective management of government institutions is a
critical component of the current administration’s Presidential Management Agenda (PMA). In
the PMA, the administration states that the manner in which “the public interacts with
government programs and benefits influences their level of trust in Government as an institution.
[…] Delivering results and being accountable for [public sector] actions will steadily rebuild
trust between the public and their government.”110 In an effort to operationalize the PMA, the
current administration issued EO instructing federal agencies to take certain actions to build trust
in government. EO 14058, titled Transforming Federal Customer Experience and Service
Delivery to Rebuild Trust in Government, identifies 34 high impact agencies, inclusive of all the
agencies that fall within the scope of this analysis. This EO, for example, directs the
Commissioner of the Social Security Administration:
1. To develop a mobile-accessible, online process so that any individual applying for or
receiving services from the Social Security Administration can upload forms,
documentation, evidence, or correspondence associated with their transaction without the
need for service-specific tools or traveling to a field office,
2. To the maximum extent permitted by law, support applicants and beneficiaries to identify
other benefits for which they may be eligible and integrate Social Security
Administration data and processes with those of other Federal and State entities whenever
possible.111

110 The President’s Management Council. The Biden-Harris Management Agenda Vision Toward an Equitable, Effective, and
Accountable Government that Delivers Results for All. Washington, DC: Office of Management and Budget, 2021.
111 Exec. Order No. 14058, 86 Fed. Reg. 71357 (Dec.16, 2021). Accessed June 25, 2022.
https://www.federalregister.gov/documents.

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“[the manner in which] the public interacts with Government programs
and benefits influences their level of trust in Government as an institution
[…] delivering results and being accountable for [public sector] actions will
steadily rebuild trust between the public and their government.”112 – The
Presidential Management Council
EO 14058 applies to most federal benefits agencies, not just SSA. Each agency of interest for
this report fell within the scope of EO 14058. Federal benefits agencies provide fundamental
services that not only support their individual missions, but additionally work to foster and
promote the American social contract. The evidence presented thus far indicates that these
agencies are well-suited to utilize a common business platform that would allow all agencies to
meet the spirit and intent of this EO.
4.7 Use Cases
As part of this study, several use cases (detailed in Appendix C) were developed to reflect the
business processes that a one-stop solution should provide as part of a redress solution. Use cases
represent typical processing that would occur as part of the process including the following:
• Interactions between individuals and the organization providing redress
• Events to be accomplished by the organization
• Information to be received, processed and/or provided.
Use cases are agnostic as to whether the events in the business use case are automated, semi-
automated, or manually accomplished.

112 The President’s Management Council. The Biden-Harris Management Agenda Vision Toward an Equitable, Effective, and
Accountable Government that Delivers Results for All. Washington, DC: Office of Management and Budget, 2021.

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5 Key Considerations
In this section, the report defines the key considerations essential to the implementation of a re-
imagined redress program. The considerations are broken out into short-, mid-, and long-term
considerations. They will include strategic and where applicable, tactical considerations to
establish a federal benefit redress program.
5.1 Short-Term Considerations
The following considerations are steps that government can take immediately to move toward an
enterprise perspective of the federal redress process. The immediacy of this action lies in the
White House’s ability to issue executive orders that initialize these processes. In this section we
will highlight the consideration, then provide a suggestion of which organization could
administer the consideration, and finally some initial steps on how the consideration could be
materialized.
5.1.1
Establish Common Thresholds and Processes
Establishing thresholds and process would require the federal government to establish a common
lexicon for how to address identity fraud across the federal enterprise and establish benchmark
levels that trigger an investigation. Similar to the current administration’s approach in EO 14008
on Tackling the Climate Crisis at Home and Abroad, the White House could signal the
importance of the need for a redress process by “taking a government-wide approach”113 and
convening the relevant government agencies and departments into a federal Identity Fraud Task
Force (e.g., IRS, SSA, DOL, SBA, VA). This task force should set guidelines around authorities
and responsibilities of agencies and victims. Furthermore, the Task Force could spearhead
agencies efforts’ by begin to identify and plan for solutions and operational change by
documenting:
•
specific organization and location information, which defines the entities/people that
will perform the functions, processes, and activities, and specifies where the
functions, processes, and activities will be performed;
•
data/information that would be used by the functions, processes, and activities;
•
physical descriptions of systems or applications they believe will need to be developed or
acquired;
•
the physical infrastructure (e.g., hardware and systems software) that will be needed
to support the redress programs; and
•
the organizations that will be accountable for security and their roles and
responsibilities, including technology standards.
To ensure the viability of the institutional changes described herein, OMB could instruct
agencies to establish the processes and rules by which the newly developed identity fraud redress
program will operate. Outside of providing the operational guidelines of the program, these

113 Exec. Order No. 14008, 86 Fed. Reg. 7619 (Feb. 1, 2021).

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policy documents would ensure the programmatic permanence of the outlined changes, as well
as allow for continuity of operations with changing administrations.
To this end, OMB could instruct agencies to develop the following policy documents in line with
the thresholds and processes developed by the federal Identity Fraud Task Force and consistent
with the Payment Integrity Information Act (PIIA):
1. A Claimant-Centric Redress Directive. This policy document will be the overarching
guidance establishing the integrated redress programs in each agency. The Directive will
include:
a. A clear purpose statement defining the authorities from which the author of the
document is drawing to establish the program.
b. An applicability statement explaining who the document will impact within the
agency.
c. Clearly defined policy goals of the identity fraud redress programs.
d. A mission statement for the identity fraud redress programs.
2. Claimant-Centric Identity Fraud Redress Program Standard Operating Procedures
(SOP). Agencies will create SOPs in line with their scope of authority, defining the step-
by-step instructions for how to execute the newly established identity fraud redress
program. These desk procedures will be at the tactical level of operations and will serve
as “cookbooks” on how to properly execute program. The SOPs will include:
a. A clearly defined purpose of the job function operating within the identity fraud
redress programs.
b. Step-by-step instructions on how to operate the tools used in the identity fraud
redress program (e.g., Customer Relationship Management tools, or data
management tools).
An Identity Fraud Task Force could spearhead agencies efforts' by beginning to identify
and plan for solutions and operational changes and documenting:
a. specific organization and location information, which defines the entities/people
that will perform the functions, processes, and activities, and specifies where the
functions, processes, and activities will be performed;
b. data/information that would be used by the functions, processes, and activities;
c. physical descriptions of systems or applications they believe will need to be
developed or acquired;
d. the physical infrastructure (e.g., hardware and systems software) that will be
needed to support the redress programs;
e. the organizations that will be accountable for security and their roles and
responsibilities, including technology standard, and
f. performance metrics.

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5.1.2
Establish Inter-Agency Agreements on Data Sharing
In line with the guiding principles outlined herein, federal benefits agencies can create data
sharing agreements with other federal benefits agencies to start the process of streamlining the
redress process.  The White House could instruct federal benefits agencies to start the process of
creating a memorandum of agreement (MOA) or a memorandum of understanding (MOU) with
respect to data sharing consistent with applicable laws and regulations. This order would be in
line with EO 14058 on Transforming Federal Customer Experience and Service Delivery to
Rebuild Trust in Government.114 By instructing federal agencies that, to the maximum extent
permitted by law, they should integrate data systems and processes with those of other Federal
and State entities.
5.1.3
Make All Service Channels Available
As identified herein, service channels have the capacity to make the new redress process
equitable and inclusive. OMB could instruct agencies to make their full suite of service channels
available for the redress process. Where some service channels are not available at specific
agencies, the administration should encourage agencies, to the maximum extent permitted by
law, to share resources ensuring that victims of identity fraud have equitable access to the redress
process. This tactic would be similar to the approached us by Services Australia called no wrong
door. During an interview conducted for this report representatives from Services Australia
stated that “if someone is a victim of identity compromise, they can contact [a state or
commonwealth government agency], an [approved] not-for-profit organization, or [approved]
private entities like ID Care. It doesn’t really matter where they come in; they come in once and
then they’re warm transferred [to the] relevant door they need to go through.”115 Though Services
Australia partners with private entities and not-for-profits, the federal government could start by
leveraging all available federal service channels to victims. As an intermediary step to a fully
developed one-stop shop process, the no wrong door process would allow victims of identity
fraud to use any of the many service channels already currently offered by federal agencies.
5.2 Mid-Term Considerations
The following considerations are steps government can take over the course of the next six
months to move toward an enterprise perspective of the federal redress process. In this section
we will highlight the consideration, then provide a suggestion of which organization could
administer the consideration, and finally some initial steps on how the administrator could
implement this consideration.
5.2.1
Conduct a Macro Economic Benefit-cost Analysis
Implementing the capabilities outlined in this report will require the investment of financial and
human capital. To fully understand the return on investment for the American public, OMB
should conduct a macro economic benefit-cost analysis (BCA) of a one-stop shop redress
process. The BCA should clearly articulate and quantify categories of benefits associated with
making this investment (e.g., cost savings due to shared services, time saved by victims), and the

114 Exec. Order No. 14058, 86 Fed. Reg. 71357 (Dec. 13, 2021).
115 Services Australia Representative. Videoconference interview by the author. McLean, VA. April 11, 2023.

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direct costs of implementation (e.g., the human capital associated with the increased programs).
The BCA should also provide a sensitivity analysis to account for margins of error. Furthermore,
the BCA should also bifurcate between macro-economic systemic costs and benefits from the
micro-economic costs and benefits for the individual agencies.
5.2.2
Develop a Whole-of-Government Redress Governance Model
Moving from a siloed operating posture to an integrated one-stop shop style system requires the
development of the proper institutional mechanisms that break down silos. One such tool is the
use of inter-agency advisory boards chaired by OMB.
OMB could develop the following claimant-centric governance model which operates in an
ongoing iterative process.
1. OMB could instruct Agency heads to craft a unified strategic vision of a claimant-centric
identity fraud customer experience. This will unify Agency leaders and the program
teams toward a shared vision of a claimant-centric redress program as being integral to
the successful execution of that Agency’s mission. Similar to section 211 of EO 40008
the White House could instruct “the head of each agency shall submit a draft action plan
to the Task Force […] within 120 days of the date of this order that describes steps the
agency can take with regard to its facilities and operations to bolster adaptation and
increase resilience to the impacts of climate change.”116 In developing this unified vision,
the Agencies must think across the enterprise, and frame the user experience in a manner
where the newly developed customer experience program becomes a fundamental
component of the victim’s assistance culture across the federal enterprise.
2. OMB could issue guidance to benefits delivery Agency directors to embed a claimant-
centric redress model into their governance models by advising the Agency heads to
select quick wins for initial focus. These quick wins will allow the agency to start small
by identifying fundamental areas of the customer experience where the program leads can
show quick tangible success. These successes will engender a sense of accomplishment
and will promote buy-in to this new claimant-centric governance model for both
operational and tactical level personnel.
3. OMB could create an inter-agency identity fraud customer experience board comprised
of the directors of the newly created Identity fraud redress offices, a set of rotating front-
line staff who interact with victims of identity fraud (temporary membership that rotates
annually), and identity fraud victim-advocate groups. This board will develop guidance
for identity fraud programs by leveraging identity fraud customer experience best
practices across government. This board will serve as a matrix-style organizational
structure. The board will have advisory authorities as prescribed by OMB and will report
back to OMB on how to improve the claimant-centric process.
4. OMB, in collaboration with the identity fraud customer experience board, could develop
key performance indicators (KPIs) for the customer experience program. They could also
establish a common lexicon and set of thresholds for benefits delivery agencies to process
these claims. OMB would use these metrics as evaluative measures for the success of the
claimant-centric redress program and publish and annual report card for each agency.

116 Exec. Order No. 14008, 86 Fed. Reg. 7619 (Feb. 1, 2021).

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OMB will evaluate the KPIs annually and readjust them based on the success of the
program.
5.2.3
Run Communication Campaigns
As identified herein, discovering that you are a victim of identity fraud is a traumatizing
experience according to individuals interviewed for this report.117 These victims have called the
current redress process, “burdensome, messy, confusing, isolating, and frustrating.”118 According
to the PRAC, “the decentralized nature of the government’s identity fraud redress process
ultimately places the burden of resolving identity theft and identity fraud on the victims.”119 Part
of alleviating this sense of isolation is ensuring that victims of identity theft know how to seek
redress. The reimagined redress process described herein would be ineffective if the intended
cohort of interest does not know how to access the integrated process. To this end, the FTC, as
the current operator of identitytheft.gov, could be responsible for running communications
campaigns to inform the government.
Benefits delivery agencies need to educate the potential registrant of the availability of that
program’s benefit. Whether done proactively or passively, there is a requirement to communicate
the availability of the redress processes to the public. Inputs for this process include messages,
communication tools, and active searches.120 Outputs for this phase of the lifecycle include
identifying the intended population groups and ensuring they understand the program.121
In the American Journal of Public Health, Anand Parekh identified the lessons learned for the
ACA by identifying a need for multi-level communication, and a need for steady incremental
communication.122 Multilevel communication would include “not only general messages for the
mass audience but also targeted messages at the group level and tailored messages at the
individual level.”123 Given the diversity of the demographics of identity fraud identified herein,
an equally diverse level of communication is required to target those populations. Notably, in its
2021 survey, the U.S. Census found that over 67 million Americans aged five years and older
speak a language other than English at home.124 Furthermore, there is an opportunity to partner
with credit reporting agencies to allow them to serve as a pipeline of reporting for potential
identity fraud cases. Many consumers receive credit reports and other credit related information
from the credit bureaus and know how to reach them for any identity fraud related matters. With
respect to steady, incremental communications the agencies would have to adopt a consistent and
sustained message around Identity Fraud. This is why it would be important for Congress to
allocate dedicated funding for identity fraud redress programs.

117 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.
118 National Victim's Advocate. Videoconference interview by the author. McLean, VA. November 3, 2022.
119 Executive Council of the Inspectors General on Integrity and Efficiency. Key Insights: Identity Fraud Reduction and Redress
in Pandemic Response Programs. By Pandemic Response Accountability Committee. Washington, DC: PRAC, 2022.
120 K. Lindert, T. G. Karippacheril, I. R. Caillava, and K. N. Chávez, eds., Sourcebook on the Foundations of Social Protection
Delivery Systems, Washington, DC: World Bank, 2020. doi:10.1596/978-1-4648-1577-5. License: Creative Commons
Attribution CC BY 3.0 IGO.
121 Ibid.
122 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5388982/
123 Ibid.
124 https://data.census.gov/table?tid=ACSDP5Y2021.DP02&hidePreview=true

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5.3 Long-Term Considerations
The following considerations are steps the government can take over the course of the next 12
months to move toward an enterprise perspective of the federal redress process. In this section
we will highlight the consideration, then provide a suggestion of which organization could
administer the consideration, and finally some initial steps on how the consideration could be
materialized.
5.3.1
Apply the Federal Integrated Business Framework (FIBF)
OMB could request that the General Services Administration (GSA), through the Office of
Shared Solutions and Performance Improvement (OSSPI), commission a detailed assessment
using the Federal Integrated Business Framework (FIBF) to standardize and enumerate federal
redress business lifecycle functions, activities, business capabilities, business use cases, and data
elements.125 In 2019, the Director of OMB issued a memorandum to the heads of executive
departments and agencies titled “Centralized Mission Support Capabilities for the Federal
Government.” This issuance instructed heads of federal agencies that “the Government will
establish a process to identify mission support functions suitable for sharing based on cross-
agency agreement on targeted outcomes and service delivery standards.”126 The memorandum
further states that, “the standards will follow the FIBF to identify a common set of capabilities
for designated mission-support functions.”127 The standards are intended for inter-agency
collaboration, they may inform a path to implementation for the benefits delivery agencies.
According to OSSPI, “business standards, established and agreed to by agencies, using FIBF
enable the government to better coordinate on the decision-making needed to determine what can
be adopted and commonly shared. They are an essential first step towards agreement on
outcomes, data, and cross-functional end-to-end processes that will drive economies of scale and
leverage the government’s buying power.”128
The FIBF includes the following five components:
1. Federal Business Lifecycles, functional areas, functions, and activities serve as the
basis for a common understanding of what services agencies need and solutions that
should be offered.129 This report has provided a basis for this component.
2. Business Capabilities are the outcome-based business needs mapped to Federal
government authoritative references, forms, inputs, outputs, and data standards.130 This
report has provided a basis for this component.

125 The Federal Integrated Business Framework (FIBF) is a model that enables the Federal government to better coordinate and
document common business needs across agencies, focusing on outcomes, data, and cross-functional end-to-end business
processes.
126 Vought, Russell T. Memorandum, “Memorandum for Heads of Executive Departments and Agencies,” April 26, 2019.
https://www.whitehouse.gov/wp-content/uploads/2019/04/M-19-16.pdf.
127 Ibid.
128 General Services Administration. "Mission Support Business Standards." GSA.gov. Accessed March 27, 2023. https://ussm.gs
a.gov/fibf/#How-are-the-Business-Standards-Used.
129 Ibid.
130 Ibid.

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3. Business Use Cases are a set of agency “stories” that document the key activities, inputs,
outputs, and other line of business intersections to describe how the Federal government
operates.131 This report provides a foundation for this component.
4. Standard Data Elements identify the minimum data fields required to support the inputs
and outputs noted in the use cases and capabilities.132
5. Service Measures define how the government measures successful delivery of outcomes
based on timeliness, efficiency, and accuracy targets.133
5.3.2
Fusion Center for Investigations
Developing a national response to address identity fraud requires a modified approach to the
sharing of information and intelligence. Leaders must move forward with a new paradigm on the
exchange of information and intelligence, one that includes the integration of law enforcement,
public safety, and the private sector. Fusion Centers provide the capability for the collaborative
sharing of information amongst law enforcement, public safety, and the private sector to increase
the ability to detect, prevent, and solve crimes.134
5.3.3
Congressional Action
This report started from the foundational premise that seeking redress from the federal
government should be a seamless process where the claimant (the victim of a crime) can request
an investigation into their claim and, if the facts support their claim, be brought to a pre-injury
condition. Though the Executive branch of government has a role in the administration and
execution of a redress program, it would be within the US Congress’ authority to codify the
existence of these programs and allocate the funding for their execution. This report has laid out
a conceptual basis for action required from the US government to execute on the vision laid out
herein. Congress could use guiding principles outlined in Section 3 of this report as the basis for
legislation around a reimagined federal identity fraud redress system. As elucidated in Section 2,
the demographics of identity fraud touch every cohort of Americans equally. Congress has a
clear interest in addressing these concerns. Delivering results to victims of identity fraud is at the
core of rebuilding trust in government institutions and reinforcing the legitimacy of public
institutions.
Beyond the guiding principles outlined herein, Congress needs to re-examine the existing
barriers that inhibit agencies from sharing identity fraud data related to those specific claims
(e.g., IRS does not share data due to legal constraints established through 26 USC 6103). In an
interview with a senior IRS official, when asked whether there is a need for legislative change,
the senior official said, “I always thought it would be legislative. I don't know what OMB can do
[without congressional action to allow IRS to share information]. I thought that we would need
[something] similar to the expansion of our disclosure provisions to participate in the [Identity
Theft Tax Refund Information Sharing and Analysis Center] (ISAC). [That collaboration] did
require legislative activity [through the] Taxpayer First Act. So, from my vantage point, I always

131 Ibid.
132 Ibid.
133 Ibid.
134 Ibid.

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thought it had to be legislative to change the actual codes that we operate under, which is
generally 6103 for the IRS.”135 The legislative changes required to the tax code to allow for
interagency data sharing relating to identity fraud could be crafted in a manner similar to
legislation around tax information sharing for student loans and financial aid. When speaking to
this point the senior IRS official further stated that, “There is actually legislation that directed
that particular data exchange to reduce the burden of taxpayers applying for student loans and
financial aid, so it's a limited purpose but a specific purpose with specific information that will
be exchanged […] that particular legislation also directed the agencies to create an online portal
that integrated this information exchange with the backbone being basic income information
such as the amount of the adjusted gross income and other information. It’s not everything
around that return [rather] very specific[information] for a specific purpose.”136

135 Senior Internal Revenue Service Official. Videoconference interview by the author. McLean, VA. November 07, 2022.
136 Ibid.

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Appendix A Acronyms

ACA
Patient Protection and Affordable Care Act
ACSC
Australian Cyber Security Centre
AI

Artificial Intelligence
API

Application Programming Interface
ARPA
American Rescue Plan Act
BCA
Benefit-Cost Analysis
BJS

Bureau of Justice Statistics
CBPP
Center for Budget and Policy Priorities
CARES Act Coronavirus Aid, Relief, and Economic Security Act
CDC
Centers for Disease Control and Prevention
CIGIE
Council of the Inspectors General on Integrity and Efficiency
COVID-19
Novel Coronavirus Disease 2019 (SARS-CoV-2)
DC

District of Columbia
DOJ
Department of Justice
DOL
Department of Labor
EIDL
Economic Injury Disaster Loan Letter
EO

Executive Order
FBI

Federal Bureau of Investigations
FIBF
Federal Integrated Business Framework
FSB

Federation of Small Businesses
FTC
Federal Trade Commission
GAO
Government Accountability Office
GRM
Grievance Redress Mechanism
GSA
General Services Administration
HHS
U.S. Department of Health and Human Services
IRS

Internal Revenue Service
IDTVA
Identity Theft Victim Assistance
ISAC
Identity Theft Tax Refund Information Sharing and Analysis Center
IT

Information Technology
ITRC
Identity Theft Resource Center

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KPI

Key Performance Indicator
LEO
Law Enforcement Organization
LIHEAP
Low-Income Home Energy Assistance Program
MOA
Memorandum of Agreement
MOU
Memorandum of Understanding
NICS
National Instant Criminal Background Check System
N/A

Not Available
OAIC
Office of the Australian Information Commissioner
OCDETF
Organized Crime Drug Enforcement Task Forces
OIG

Office of Inspector General
OMB
Office of Management and Budget
PEUC
Pandemic Emergency Unemployment Compensation Program
PIIA
Payment Integrity Information Act of 2019
PII

Personally Identifiable Information
PMA
Presidential Management Agenda
PPP

Paycheck Protection Program
PRAC
Pandemic Response Accountability Committee
SARS
Severe Acute Respiratory
SMS
Short Message Service
SBA

Small Business Administration
SNAP
Supplemental Nutrition Assistance Program
SOP

Standard Operating Procedures
SSA

Social Security Administration
SSN

Social Security Number
TPP

Taxpayer Protection Program
USC
U.S. Code
USDA
U.S. Department of Agriculture
U.K.
United Kingdom
VA

US Veterans Affairs Administration
WHO
World Health Organization

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Appendix B Methodology
Environmental Scan
Overview
This report provides valuable information to key stakeholders, including the public, Congress,
executive branch agencies, and agencies adminsistering federal benefit programs on design
elements to reimagine a federal identity fraud redress program. MITRE’s environmental scan
leveraged a variety of information sources to characterize the current landscape, highlight
challenges and obstacles, and identify areas for improvement.
MITRE used a qualitative data-gathering protocol to capture the factors that affected the
outcomes of victims of identity fraud by examining the execution of federal benefit programs
and their processes, governance, and technology involved in providing any redress to victims.
The protocol provided a systematic approach to discover and document the challenges,
successes, and opportunities raised during MITRE’s interviews and document review. MITRE
conducted the analysis in four steps as shown in the figure below.

Figure B-1 Evaluation Methodology
The analysis process synthesizes information gathered from stakeholder interviews and
document reviews. Initially, observations are gathered from these data sources. Observations are
specific facts drawn from the document review or interview comments; they are directly
attributable to a particular data source. The team categorizes and collates the observations into
broader findings and themes and uses these to highlight best practices, lessons learned, and
optimal approaches for implementing a reimagined federal redress program. Findings are key
inferences drawn from the observations. Themes are high-level concepts that recur across
multiple findings; themes group findings to communicate the broadest analytical takeaways.
The team then applied evidence-based design principles to identify examples based on the
findings and what relevant, credible examples already exist and the validity of the examples. The
team translated the relevant evidence into design criteria (key considerations) that can be used to
guide the development to improve the federal redress program and outcomes for victims of
identity fraud.

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Appendix C Use Cases
C.1 Initial Contact With Agency
End-to-End Business Process: Requests for Federal Benefit Redress from Agency
Business Scenario Covered
Initial Identity Fraud Claim with Benefit Agency
Business Actors
•
Victim
•
Federal Benefit Agencies
•
FTC
Synopsis
A currently employed hospital worker receives a letter from their State Workforce Agency (SWA) stating s/he has been awarded
unemployment insurance benefits. The individual notifies their employer Human Resources department to get the matter resolved.
However, unfortunately, four months later the employee is notified they are a part of a layoff and seeks unemployment insurance benefits
to discover they have been denied benefits due to ineligibility.
Assumptions and Dependencies
1. There are three methods to correspond with agencies within the re-imagined redress “one-stop” shop approach including in-person,
telephone and digital (mobile device or internet).
2. Supporting information to file for unemployment insurance is available to the victim and are digitally available to the SWA.
3. All predecessor activities required to trigger the Initiating Event have been completed.
4. The one-stop shop platform has been stood up with all agencies able to leverage the suite of capabilities.
5. Victim has all information to complete the identity fraud claim.
6. There are sufficient resources to provide the service.

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Initiating Event
Victim requests benefit re-instatement
Typical Flow of Events
Table C-1. Typical Flow of Events for Initial Contact with Agency
#
Redress Event
Non-Redress Event*
Input(s)
Output(s) / Outcome(s)
1
-
a) Requests re-instatement of
eligibility for
unemployment insurance.
b) Requests protection of
personally identifiable
information (PII).
c) Requests counseling to cope
with stress of identity theft.

Caller contact information; fraud
incident claim information; data
about the victim.
• Submitted identity
theft and fraud
claim.
• Requests for PII
protection.
• Requests for trauma
care support.

2
• Receive and process
identity theft and
fraud claim.
• Receive and process
requests for protection
of PII.
• Receive and process
requests for trauma
care support.

-
• Submitted identity theft and
fraud claim.
• Requests for PII protection.
Requests for trauma care
support.
• Identity theft and
claim response.
• PII protection
response.
Trauma care support
response.
3

• Approve identity theft and
fraud claim
• Approve PII protection
request
• Identity theft and claim
response
• PII protection response
Trauma care support response
• Approved claim
• Approved PII
protection

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• Approve trauma care
support request

Approved trauma care
support
4
• Received approved claim
• Received approved PII
protection
• Received approved
trauma care support

-
• Approved claim
• Approved PII protection
Approved trauma care support
• Provide identity
fraud case
management docket
• Provide PII
protection
Provide trauma care
support
5
• Route identity fraud case
management information
to appropriate entities
including FTC
• Validate PII protection
Confirm trauma care support
-
Identity fraud case management
docket
Identity fraud case
docket updated

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C.2 Trauma Care Support
End-to-End Business Process: Providing trauma-informed care to victims of identity theft and fraud
Business Scenario Covered
Initial Request for Trauma-Informed Care
Business Actors
•
Victim
•
Trauma-Informed Care Service Provider
•
Trauma-Informed Care Practitioner
•
Federal Benefit Agency Federal Benefit
Synopsis
A currently employed hospital worker receives a letter from their State Workforce Agency (SWA) stating s/he has been awarded
unemployment insurance benefits. The individual notifies their employer Human Resources department to get the matter resolved.
However, unfortunately, four months later the employee is notified they are a part of a layoff and seeks unemployment insurance benefits
to discover they have been denied benefits due to ineligibility. After initial contact with the federal agency, the victim is referred to a
trauma-informed care service provider to begin to restore their wellbeing.
Assumptions and Dependencies
1. The individual has already established contact with the federal benefit agency seeking redress.
2. All predecessor activities required to trigger the Initiating Event have been completed.
3. The one-stop shop platform has been stood up with all agencies able to leverage the suite of capabilities.
4. The federal benefit agency has an established relationship/partnership agreement with a trauma-informed care service provider.
5. The trauma-informed care service provider has trauma-informed care trained practitioners.
6. The trauma-informed care service provider has established best practices and processes for screening, assessment, case planning,
case coordination, secondary consultation, and client feedback.137

137 (Government, 2022)

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7. There are sufficient resources to provide the service.
8. There is information available in multiple languages.
9. The service is provided at the victim’s consent and is confidential.
10. The trauma-informed care service provider has connections with a broader system of support.
Initiating Event
Victim requests benefit re-instatement.
Typical Flow of Events
Table C-2. Typical Flow of Events for Trauma Care Support
#
Redress Event
Non-Redress Event*
Input(s)
Output(s) / Outcome(s)
1
-
a) Requests counseling to cope
with stress of identity theft
and fraud.

• Caller contact information;
fraud incident claim
information; data about the
victim.
• Submitted identity theft and
fraud claim.
• Approved trauma care
support request.

Victim is assigned a
trauma-informed care
practitioner.
2
Trauma-informed care
practitioner establishes initial
contact with victim.
Create Trauma-informed care
victim case management record.
• Submitted identity theft and
fraud claim.

• Identification of
immediate resources
available to the victim.
• Overview of the
trauma-informed care
process model and
where the victim is
within the various
phases of the model.

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• Trauma-informed care
service provider
mission statement.
• Initial triage
assessment of possible
outcomes.
• Copy of victim rights.
Next steps/direction for
victim.
3
Trauma-informed care
practitioner requests consent
from victim to provide
support.
-
• Informed consent from
victim.
Trauma-informed care victim
case management record.
• Consent confirmation.
Information regarding
grievances.
4
Trauma-informed care
practitioner provides intake
assessment to establish a
victim profile of potential
needs based on degree of
fraud victimization.
-
• Submitted identity theft and
fraud claim.
• Trauma-informed care
victim case management
record.

• Confidentiality
statement.
• Generated PIN.
• Individualized plan for
redress related trauma-
informed care
• Information on
benefits and limits of
service based on
intake assessment.
Identification of
additional support
services.

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C.3 Request Federal Fraud Fusion Center Investigation
End-to-End Business Process: Requests for Criminal Investigation Using a Federal Fraud Fusion Center Security Operations Center
(SOC)
Business Scenario Covered
Initial Identity Fraud Investigation
Business Actors
•
Victim
•
Federal Benefit Agencies
•
FTC
•
Law Enforcement
•
Federal, State and Local Public Safety Organizations
Synopsis
A request is made to initiate an identity fraud investigation based on information collected from victims and other threat intelligence
Assumptions and Dependencies
1. There have been several similar identity fraud incidents effecting multiple victims or a significant fraud incident meeting threshold
condition.
2. The amount of the fraud committed meets the threshold for criminal investigation.
3. The Fraud Fusion (Data) Center Security Operations Center (SOC) applies the scanning, analysis, response, and assessment
(SARA) model.
4. There are adequate resources including fraud prevention, cybersecurity, threat intelligence and analytics teams.
5. The Fraud Fusion center leverages law enforcement and public safety agencies at the federal, state, and local levels in addition to
federal agencies’ Office of the Inspector General (OIG).
6. The Fraud Fusion Center SOC includes threat intel, advanced analytics, monitoring, and response operations.
7. There are automated interfaces between functional areas/functions/activities or between provider solutions/systems to promote
information sharing when required.

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8. There is no presumption as to which activities are executed by which actor, or which activities are automated, semiautomated, or
manual.
9. There is sufficient information to conduct the criminal investigation based on the initial and subsequent fraud incident reports.
Initiating Event
Fraud incident meets the threshold for cross-agency collaboration and exchange of information and intelligence among law enforcement
and public safety agencies at the federal, state, and local levels.
Typical Flow of Events
Table C-3. Typical Flow of Events for Request Federal Fraud Fusion Center Investigation
#
Redress Event
Non-Redress Event*
Input(s)
Output(s) / Outcome(s)
1
-
a) Requests cross-agency fraud
investigation
Fraud incident claim
information; data about the
victim.
•
Approved identity
theft and fraud claim.
•
Requests cross-agency
fraud investigation
2
•
Receive approved
identity theft and
fraud claim.
•
Receive additional
threat intelligence
related to fraud
incident.
•
Receive requests for
cross-agency fraud
investigation
-
Pre-investigation assessment
•
Fraud incident report
Formal fraud case
3
•
Distribute fraud
incident report across
multiple agencies as
•
Perform fraud analysis
Fraud analysis
Enhanced fraud incident
report

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part of data fusion
center fraud
investigation
• Issue notice to
agencies to collect
and preserve data

• Monitor networks for cyber-
related fraud activity
• Fuse data from multiple
data sources
• Collect additional
supporting evidence
• Leverage forensic expertise

4
• Collect reports and
information

-
• Fraud investigation
analysis reports
Threat intelligence
• Provide final reports
Updated fraud case

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