Policy & Practice | Fall 2023

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Figure 2: Is Identity Proofing Required to Submit an Online Application?

using KBV practices and strengthen their identity proofing processes. 8 The use of biometric comparisons for identity verification, such as facial recognition software to evaluate a selfie against a government ID—a technique introduced by many state labor agencies during the pandemic and the IRS—can present accessibility and equity issues for individuals who are unable to successfully complete the process, and introduce potential for bias and disparate impacts. 9 Such use cases also raise broader questions about privacy and transparency. To read more about our findings and access the full dataset, you can visit our digital identity data page on the Digital Benefits Hub, where you can also find datasets and analysis for each program. Emerging Practices and Standards The DBN sees authentication and identity proofing as part of the overall service design of benefits delivery. During our data collection, we observed promising practices that may promote access, including benefits applications that allow users to submit initial applications without mandating any authentication or identity proofing steps; simple, optional account creation processes that do not require users to provide an email address; and portals that offer multiple pathways for users to verify their identities. We are interested in further exploring best practices in this space that can improve access while meeting security requirements and addressing pro gram-specific risks. As we continue to study how to make digital identity approaches more equitable and accessible in benefits contexts, our team is also closely fol lowing the ongoing process to update the National Institute of Standards and Technology’s (NIST) Digital Identity Guidelines. 10 While state agencies are not required to follow NIST’s standards, updated digital identity guidelines and implementation guidance may help state agencies select

approaches tailored to their specific risks and population needs. We are also encouraged by NIST’s efforts to identify secure, equitable, and reliable options for identity proofing that do not rely on facial recognition. We are also interested in further exploring with experts and state agencies how cybersecurity approaches can help protect against fraud without blocking legitimate applicants and creating undue burdens. 11 Following the release of this land scape data on authentication and identity proofing approaches, the DBN is eager to continue working closely with state human services and labor agencies and other partners to help agency decision makers navigate tradeoffs in different digital identity approaches, map out key decision points around digital identity in benefits delivery, and promote best practices for accessibility, equity, privacy, and data security. Elizabeth Bynum Sorrell , PhD, is a Project Researcher for Digital Benefits Network at the Beeck Center for Social Impact & Innovation at Georgetown University. Ariel Kennan is the Fellow and Research Faculty Member for the Digital Benefits Network at the Beeck Center for Social Impact & Innovation at Georgetown University.

Reference Notes 1. The Digital Benefits Network. (2023).

Beeck Center for Social Impact + Innovation. https://beeckcenter.

georgetown.edu/projects/ digital-benefits-network 2. Bynum Sorrell, E., & Kennan, A. (2023, May 19). Digital authentication and identity proofing in public benefits applications. Digital Benefits Network. https://www.digitalbenefitshub.org/ digital-authentication-and-identity proofing-data 3. Moffitt, R. A., & Ziliak, J. P. (2020). COVID-19 and the U.S. Safety Net. Fiscal studies, 41 (3), 515–548. https://www.nber.org/papers/w27911 4. Unemployment insurance: Data indicate antifraud strategy. (2023, January 23). U.S. Government Accountability Office. https:// www.gao.gov/assets/gao-23-105523.pdf 5. Benefits enrollment field guide. (2023). Code for America. https://codeforamerica .org/programs/social-safety-net/ benefits-enrollment-field-guide 6. SNAP online applications best practices. (2015). USDA Food and Nutrition Service, U.S. Department of Agriculture. https://www.fns.usda.gov/snap/admin/ online-application-best-practices 7. Wagner, J., & Gaudet, G. (2020, April 22). Removing barriers to access from remote identity proofing. Center on Budget and Policy Priorities. https://www.cbpp.org/ research/health/removing-barriers-to access-from-remote-identity-proofing 8. NIST Special Publication 800-63: Digital substantial levels of fraud during the pandemic; DOL should implement an

identity guidelines: Frequently asked questions. (2022, March 13). National

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