Audit Report

Numberholders Age 112 or Older 

Who Did Not Have a Death Entry on 

the Numident 

A-06-14-34030 | March 2015
MEMORANDUM

Date: March 4, 2015 Refer To: 

To: The Commissioner 

From: Inspector General

Subject: Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident 

(A-06-14-34030) 

The attached final report presents the results of our audit. Our objective was to determine 

whether the Social Security Administration had controls in place to annotate death information 

on the Numident records of numberholders who exceeded maximum reasonable life 

expectancies.

Please provide within 60 days a corrective action plan that addresses each recommendation. If 

you wish to discuss the final report, please call me or have your staff contact 

Steven L. Schaeffer, Assistant Inspector General for Audit, at (410) 965-9700. 

Patrick P. O’Carroll, Jr.

Attachment
Numberholders Age 112 or Older Who Did Not Have a Death 

Entry on the Numident

A-06-14-34030

March 2015 Office of Audit Report Summary

Objective

Our objective was to determine 

whether the Social Security 

Administration (SSA) had controls in 

place to annotate death information on 

the Numident records of 

numberholders who exceeded 

maximum reasonable life expectancies.

Background 

We obtained information indicating a 

man opened bank accounts using 

several different Social Security 

numbers (SSN). SSA records 

indicated two of the SSNs belonged to 

numberholders born in 1886 and 1893, 

respectively. SSA’s Numident

indicated both numberholders were 

alive. As a result, neither of these 

SSNs appeared in the Death Master 

File. 

In September 2013, a New York 

resident, believed to be the world’s 

oldest living man, died at age 112. 

According to the Gerontology 

Research Group, as of October 2013, 

only 35 known living individuals 

worldwide had reached age 112. 

We obtained Numident data that 

identified approximately 6.5 million 

numberholders born before 

June 16, 1901 who did not have a date 

of death on their record.

Findings

SSA did not have controls in place to annotate death information on 

the Numident records of numberholders who exceeded maximum 

reasonable life expectancies and were likely deceased. To

illustrate, we identified approximately 6.5 million numberholders 

age 112 or older who did not have death information on the 

Numident. 

 SSA issued approximately 6.4 million of the SSNs to process 

benefit claims filed before March 1972, including 48,746 SSNs 

issued to process death claims. 

 SSA had input dates of death on approximately 1.4 million nonbeneficiaries’ payment records but had not recorded the death 

information on the Numident. 

 SSA had terminated payments and input dates of death on 

410,074 beneficiaries’ payment records but had not recorded the 

death information on the Numident. 

We also determined that thousands of the SSNs could have been 

used to commit identity fraud.

 For Tax Years 2006 through 2011, SSA received reports that 

individuals using 66,920 SSNs had approximately $3.1 billion 

in wages, tips, and self-employment income. SSA transferred 

the earnings to the Earnings Suspense File because the 

employees’ or self-employed individuals’ names on the 

earnings reports did not match the numberholders’ names. 

 During Calendar Years 2008 through 2011, employers made 

4,024 E-Verify inquiries using 3,873 SSNs belonging to 

numberholders born before June 16, 1901. 

Resolving these discrepancies will improve the accuracy and 

completeness of the Death Master File and help prevent future 

misuse of these SSNs.

Recommendations

We made four recommendations for corrective action. SSA agreed 

with two and disagreed with two. 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 

TABLE OF CONTENTS

Objective ..........................................................................................................................................1

Background ......................................................................................................................................1

Results of Review ............................................................................................................................1

6.5 Million Numberholders Age 112 or Older with No Numident Death Information .............3

SSNs Issued to Facilitate Life and Death Claims ................................................................3

Non-beneficiaries with a Date of Death on Their Payment Records ...................................3

Beneficiaries with a Date of Death on Their Payment Records ..........................................4

Numberholders Receiving SSA Payments...........................................................................4

Numberholders with Reported Earnings ..............................................................................5

Additional Indications of SSN Misuse ......................................................................................6

$3.1 Billion in Earnings Transferred to the ESF..................................................................6

E-Verify Inquiries ................................................................................................................6

DMF .....................................................................................................................................7

Missing Death Information Reduces the Effectiveness of the Earnings After Death 

Program ................................................................................................................................8

Conclusions ......................................................................................................................................8

Recommendations ............................................................................................................................8

Agency Comments and OIG Response............................................................................................9

Appendix A – Scope and Methodology ..................................................................................... A-1

Appendix B – Agency Comments .............................................................................................. B-1

Appendix C – Major Contributors.............................................................................................. C-1
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 

ABBREVIATIONS

DMF Death Master File

EAD Earnings After Death

ESF Earnings Suspense File

Fed. Reg. Federal Register

IRS Internal Revenue Service

MBR Master Beneficiary Record

MEF Master Earnings File

OI Office of Investigations 

OIG Office of the Inspector General

PII Personally Identifiable Information

POMS Program Operations Manual System

SSA Social Security Administration

SSN Social Security Number

U.S.C. United States Code 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 1 

OBJECTIVE

Our objective was to determine whether the Social Security Administration (SSA) had controls 

in place to annotate death information on the Numident records of numberholders who exceeded 

maximum reasonable life expectancies.

BACKGROUND

SSA matches death reports received from various sources against its payment records and 

records dates of death on the Numident, an electronic file that contains personally identifiable 

information (PII) for each person issued a Social Security number (SSN).1 SSA uses information 

from the Numident to create the Death Master File (DMF).

2

 SSA provides DMF data to the 

Department of Commerce, which, in turn, sells the DMF data to public and private customers.3 

Financial institutions process financial, credit, payment, and other applications against the DMF 

to prevent and identify fraud. 

We obtained information indicating a financial institution reported that a man opened bank 

accounts using several different SSNs. According to the Numident, two of the SSNs belonged to 

numberholders who were born in 1886 and 1893, respectively. Neither of the Numident records 

contained a date of death.

4

 As a result, neither of these SSNs appeared in the DMF. 

In September 2013, a New York resident, believed to be the world’s oldest living man, died at 

age 112. According to the Gerontology Research Group, as of October 2013, only 35 known 

living individuals worldwide had reached age 112.5 Based on this, we obtained Numident data 

that identified approximately 6.5 million numberholders born before June 16, 1901 (at least 

112-years-old as of June 15, 2013) who did not have a date of death on their record. See 

Appendix A for a discussion of our scope and methodology. 

RESULTS OF REVIEW

SSA did not establish controls to annotate death information onto the Numident record of 

numberholders who exceeded maximum reasonable life expectancies and were likely deceased. 

At the time of our review, SSA’s Numident included approximately 6.5 million numberholders 

who were born before June 16, 1901 but who did not have a date of death on their record. SSA 

 

1 SSA, POMS, GN 02602.060 (May 13, 2011).

2 SSA, POMS, GN 02602.060.B.1 (May 13, 2011).

3 http://www.ntis.gov/assets/pdf/import-change-dmf.pdf. Effective November 1, 2011, SSA no longer provides the 

National Technical Information Service death information to sell to public and private customers if SSA records 

indicate that the source of death information was a State. Social Security Act, § 205 (r), 42 U.S.C. § 405 (r).

4 Neither numberholder received SSA payments at the time of our review. 

5

 On September 18, 2014, the Gerontology Research Group reported that 42 known living individuals worldwide 

had reached age 112. 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 2 

records contained further information indicating the majority of these numberholders was likely 

deceased. 

 SSA issued approximately 6.4 million (98.5 percent) of the SSNs to process benefit claims 

filed by the numberholders or their family members before March 1972, including 

48,746 SSNs issued to process death claims. 

 SSA had input dates of death on approximately 1.4 million non-beneficiaries’ payment 

records but had not recorded the death information on the Numident. 

 SSA had terminated payments and input dates of death on 410,074 beneficiaries’ payment 

records but had not recorded the death information on the Numident.6

 SSA issued payments to 266 numberholders. However, our review of SSA records indicated 

that only 13 beneficiaries were likely age 112 or older. In the remaining 253 cases, 

discrepancies in SSA records indicated the beneficiary receiving payments was not actually 

born before June 16, 1901. 

 Only 71 numberholders had $1,000 or more in earnings posted to the Master Earnings File 

(MEF) during any Tax Years 2008 through 2012. In no case did it appear someone who was 

actually born before June 16, 1901 was working. In 34 cases, it appeared someone was 

misusing a deceased numberholder’s name and SSN to work. In the other 37 cases, 

discrepancies in SSA records indicated the wage earners were not actually born before 

June 16, 1901. 

The fact that almost all of the 6.5 million numberholders were aged but had no earnings and 

received no payments from SSA further indicated the individuals were likely deceased.

In addition, we matched the SSNs against SSA’s Earnings Suspense File (ESF) and the E-Verify 

system7

 and identified thousands of instances of potential SSN misuse. To illustrate, SSA 

received reports that individuals using 66,920 SSNs had approximately $3.1 billion in wages, 

tips, and self-employment income in Tax Years 2006-2011. SSA transferred the earnings to the 

ESF because the employees’ or self-employed individuals’ names on the wage or 

self-employment earnings reports did not match the numberholders’ names. We also determined 

that, from Fiscal Years 2008 through 2011, SSA received 4,024 E-Verify inquiries using the 

SSNs of 3,873 numberholders born before June 16, 1901. 

 

6 We conducted prior audits that compared death information on deceased beneficiaries’ and recipients’ payment 

records with death information on the DMF, including Title II Deceased Beneficiaries Who Do Not Have Death 

Information on the Numident (A-09-11-21171), July 9, 2012, and Title XVI Deceased Recipients Who Do Not Have 

Death Information on the Numident (A-09-12-22132), May 3, 2013. 

7

 E-Verify is a Department of Homeland Security program that allows employers to verify that newly hired 

employees are authorized to work in the United States under immigration law.
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 3 

Because so much time had passed since these numberholders’ deaths, we could not determine 

why their death information did not appear on the Numident. 

Any numberholder’s death that SSA does not record on the Numident is not included in the 

DMF. As a result, Federal and private entities that rely solely on the DMF to detect deaths 

would not know these individuals are deceased. This missing death information could result in 

erroneous payments made by Federal benefit-paying agencies that rely on the DMF to detect 

inaccurate or unreported deaths. The missing death information will also hinder private industry 

as well as State and local governments’ ability to identify and prevent identity fraud. 

6.5 Million Numberholders Age 112 or Older with No Numident 

Death Information

The Numident includes approximately 6.5 million numberholders who, according to their dates 

of birth, were at least 112-years-old but did not have death information on their record. We 

reviewed available information in SSA records and identified further information indicating most 

of the numberholders were likely deceased.

SSNs Issued to Facilitate Life and Death Claims 

The Numident indicated that SSA issued approximately 6.4 of the 6.5 million SSNs to facilitate 

processing of benefit claims filed by the numberholders or their families before March 1972. 

 Numident records for most of the 6.4 million numberholders contained entry code—type of 

record established “L,” which SSA defines as Life claim (filed before March 1972). 

According to SSA staff, SSA typically issued these SSNs when individuals who had never 

been issued SSNs filed benefit claims. Upon verification of benefit eligibility, SSA issued 

the SSNs to facilitate claims processing. 

 The Numident records for 48,746 numberholders contained entry code—type of record 

established “D,” which SSA defines as Death claim (filed before March 1972). According to 

SSA staff, SSA typically issued these SSNs when family members filed death benefit claims 

on behalf of deceased individuals who had never been issued an SSN. Upon verification of 

benefit eligibility, SSA issued the SSNs using the deceased individuals PII and established 

the death claims against the SSNs. However, SSA did not record the numberholders’ dates 

of death on the Numident. 

The fact these numberholders were at least 112-years-old, and their SSNs were associated with 

benefit claims—including death benefit claims—filed more than 40 years ago, yet almost none 

of these numberholders remained in current payment status, indicated the numberholders were 

likely deceased.

Non-beneficiaries with a Date of Death on Their Payment Records 

SSA had input dates of death on approximately 1.4 million non-beneficiaries’ Master 

Beneficiary Records (MBR) but had not recorded the numberholders’ death information on the 

Numident. The average year of death for these numberholders was 1959. The MBRs primarily 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 4 

involved auxiliary benefits that SSA paid to deceased wage earners’ family members. Examples 

follow. 

 A numberholder born in 1883 died in 1951. His MBR indicated that SSA issued auxiliary 

benefits to his widow until her death in 1966. The primary line of the MBR included the 

numberholder’s month and year of death, but his Numident record contained no death 

information. 

 A numberholder born in 1882 died in 1966. His MBR indicated that SSA was issuing

auxiliary benefits to his 82-year-old child. The primary line of the MBR included the 

numberholder’s month and year of death, but his Numident record contained no death 

information. 

Because the numberholders were not listed as beneficiaries on these MBRs, the numberholders’ 

names and dates of birth generally did not appear on these MBRs. Prior reviews indicated that 

differences between a numberholder’s non-SSN identifying information on SSA payment 

records and Numident can prevent propagation of death information from one system to the 

other. However, in these particular cases, the numberholders’ non-SSN identifying information 

generally did not appear on the MBRs. This may explain why SSA systems did not propagate 

death information on these MBRs to the appropriate Numident records. 

Beneficiaries with a Date of Death on Their Payment Records 

SSA had terminated payments and input dates of death on 410,074 beneficiaries’ payment 

records. However, SSA did not input a corresponding death entry on the beneficiaries’ 

Numident record. We have identified this problem and made recommendations for corrective 

action in prior audits. 

Numberholders Receiving SSA Payments 

When we initiated our review, SSA was issuing payments to 266 numberholders whose 

Numident records contained a date of birth before June 16, 1901. However, in only 13 cases was 

it likely the beneficiary was actually age 112 or older. In the remaining 253 cases, discrepancies 

in SSA records indicated the beneficiary receiving payments was not born before June 16, 1901. 

 In 96 cases, SSA had superimposed 2 individuals’ PII on the same Numident record—1 born 

before and 1 after June 16, 1901. The individual receiving benefit payments was the person 

born after June 16, 1901. 

 In 68 cases, the name of the individual receiving benefits under the SSN was different than 

the name on the numberholders’ Numident. This occurred because SSA had established the 

incorrect SSN on the beneficiaries’ payment record—primarily because of transposition 

errors.

 In 37 cases, the beneficiary’s payment record contained a date of birth on or after 

June 16, 1901, but their Numident records contained a date of birth before June 16, 1901. 

We believe it is likely these beneficiaries were younger than 112-years-old, and the dates of 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 5 

birth on the Numident were incorrect. However, when processing the benefit claim, SSA did 

not notice or resolve the date-of-birth discrepancies.

 In 52 cases, the beneficiary’s payment record contained a date of birth on or after 

June 16, 1901, and their Numident contained multiple entries with different dates of birth, 

1 before June 16, 1901, and 1 on or after June 16, 1901. We believe it likely the later 

birthdates on these records were correct, and these beneficiaries were younger than 

112-years-old. 

Numberholders with Reported Earnings 

As part of the Annual Wage Reporting process, SSA matches Forms W-2, Wage and Tax 

Statement, submitted by employers against the Numident. SSA performs a similar match of 

self-employment earnings information received from the Internal Revenue Service (IRS). If the 

earnings reports contain a valid name and SSN combination, SSA posts the earnings to the MEF. 

Only 71 numberholders had $1,000 or more in earnings posted to the MEF during any Tax Year 

from 2008 through 2012. In no case did it appear someone who was actually born before 

June 16, 1901 was working. 

 In 34 cases, it appeared someone misused a deceased numberholder’s name and SSN to 

work. Examples follow.

 A numberholder born in 1886 filed a “Life claim” in 1953. SSA payment records 

indicate the numberholder died in January 1965; however, SSA did not record the 

numberholder’s death on the Numident. SSA continued paying benefits to the 

numberholder’s widow until her death in February 1973. The MEF contains no reported 

earnings information for this numberholder from 1956 through 2007. However, 

beginning in Tax Year 2008 and each Tax Year through 2012, an Arizona employer 

reported paying wages (ranging from $12,594 to $17,100) to someone using the 

numberholder’s name and SSN. 

 A numberholder born in 1896 filed a “Life claim” in 1958 (at age 62). The MEF 

indicates the numberholder continued earning wages through Tax Year 1962 and contains 

no reported earnings from 1963 through 2006. However, beginning in Tax Year 2007 

and each year since, a South Carolina employer has reported payment of wages (ranging 

from $11,450 to $27,694) to someone using the numberholder’s name and SSN.8

 

 

8

 We referred this and five additional cases to our Office of Investigations (OI). OI opened a criminal investigation 

in one case where it appeared an individual was working under a deceased relative’s SSN. In three cases, OI 

confirmed that illegal aliens were using deceased numberholders’ names and SSNs to work, but U.S. Attorneys in 

Arizona, Florida, and South Carolina declined prosecution. In the two remaining cases, it appeared employers 

erroneously reported earnings under the names and SSNs of individuals in our audit population. OI referred these 

cases to SSA for corrective action and closed the allegations due to lack of criminal intent. 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 6 

 In 16 cases, SSA had superimposed 2 individuals’ PII on the same Numident record—1 born 

before and 1 born after June 16, 1901. The wage earner appeared to be the individual born 

after June 16, 1901. 

 In 19 cases, the Numident contained multiple entries with different dates of birth, 1 before

June 16, 1901 and 1 on or after June 16, 1901. We believe it likely the later birthdates on 

these records were correct, and these beneficiaries were younger than 112-years-old. 

 In two cases, the wage earner’s payment record contained a date of birth on or after 

June 16, 1901, but the Numident record contained a date of birth before June 16, 1901. We 

believe it is likely these wage earners were younger than 112-years-old, and dates of birth on 

the Numident were incorrect. However, when processing the benefit claims, SSA did not 

notice or resolve the date-of-birth discrepancies.

The fact that so few of these SSNs had earnings activity further indicates the numberholders 

were likely deceased.

Additional Indications of SSN Misuse

We matched the 6.5 million SSNs against SSA’s ESF and E-Verify systems and identified 

thousands of instances of potential identity theft or other fraud. 

$3.1 Billion in Earnings Transferred to the ESF 

As part of the Annual Wage Reporting process, SSA matches Forms W-2 submitted by 

employers against SSA’s Numident. If the Form W-2 contains a valid name/SSN combination, 

SSA posts the earnings to the MEF. However, when the name/SSN combination cannot be 

matched to SSA’s records, the wage information is transferred to the ESF—SSA’s repository for 

unmatched wages. SSA performs a similar match of self-employment earnings information 

received from the IRS.

9

For Tax Years 2006 through 2011, SSA transferred to the ESF approximately $3.1 billion in 

wages, tips, and self-employment income reported under 66,920 of the 6.5 million SSNs. One 

SSN appeared on 613 different suspended wage reports, and 194 additional SSNs appeared on at 

least 50 suspended wage reports that SSA received during this 6-year period. Individuals can 

commit various types of fraud against the Government by reporting earnings under deceased 

individuals’ SSNs.

E-Verify Inquiries 

SSA supports the Department of Homeland Security in operating and administering the E-Verify 

program. Participating employers input information about new hires, including name, date of 

 

9 SSA maintains separate ESFs for wages and self-employment income.
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 7 

birth, and SSN into the E-Verify system. E-Verify matches the information against the 

Numident. If the data input by the employer do not match the Numident, SSA sends a response 

to E-Verify, which, in turn, generates a message for the employer indicating there is a 

discrepancy with SSA’s records. 

During Calendar Years 2008 through 2011, SSA received 4,024 E-Verify inquiries using the 

SSNs of 3,873 numberholders born before June 16, 1901.10 These inquiries indicate individuals’ 

attempts to use the SSNs to apply for work. 

DMF 

Various Federal entities rely on SSA’s death information to detect unreported deaths and verify 

the accuracy of reported deaths. Under section 205(r) of the Social Security Act, only agencies 

that pay federally funded benefits, such as the Railroad Retirement Board, Department of 

Defense, Office of Personnel Management, and Department of Veterans Affairs, may receive the 

full file of SSA’s death information. SSA also provides the full file to the Centers for Medicare 

and Medicaid Services, Government Accountability Office, and IRS. Agencies that do not pay 

any type of federally funded benefits may receive only the public version of the DMF, which 

does not contain State death information. Private industry customers (including banks, hospitals, 

universities, and insurance companies) may purchase the public version of the DMF through the 

Department of Commerce’s National Technical Information Service to verify death and prevent 

fraud.

In June 2010, the President directed Federal agencies to ensure they thoroughly review available 

databases with relevant information on eligibility before they release any Federal funds. At a 

minimum, agencies shall, before payment and award, check the existing databases, including 

SSA’s DMF, to verify eligibility.

11

Any deceased numberholder whose death is not recorded on the Numident will not appear in 

either version of the DMF. As a result, Federal and private entities that rely solely on the DMF 

to detect deaths would not know these individuals are deceased. We identified as many as 

6.5 million deceased numberholders who did not have death information on the Numident and 

therefore were not included in the DMF. This missing death information could result in 

erroneous payments by other Federal agencies that rely on the DMF to detect unreported deaths. 

The missing death information could also hinder private industry and State and local 

governments’ ability to identify and prevent identity fraud. 

 

10 In only two instances, did the SSN, name and date of birth (one born in 1886 and the other born in 1898) input 

into E-verify match the name and date of birth on the numberholder’s Numident record. 

11 Presidential Memorandum - Enhancing Payment Accuracy Through a “Do Not Pay List” June 18, 2010 (75 Fed. 

Reg. 35953, June 23, 2010).
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 8 

Missing Death Information Reduces the Effectiveness of the Earnings After 

Death Program 

SSA receives earnings reports from employers and records valid earnings on the MEF. To 

determine the validity of an earnings report, SSA compares the name and SSN on the earnings 

report to information on the Numident. In addition to verifying the individual’s name and SSN, 

SSA reviews the Numident to determine whether the individual is deceased. Generally, when 

the Numident contains a date of death and the year of death is before the year of the reported 

earnings, the earnings are placed in SSA’s ESF as an earnings after death (EAD) record.

For any EAD, SSA investigates and attempts to resolve the reported earnings. SSA sends 

notices to employers, employees, and self-employed individuals. If the employer states the 

individual is working for them but does not provide adequate information to resolve the issue, 

SSA sends a notice to the employee requesting that he/she contact SSA to correct the earnings 

information. If SSA can resolve the earnings, it records the wages to the proper SSN. If the 

employer informs SSA the individual is deceased, SSA instructs the employer to refund the 

employee's share of the Social Security taxes to the employee’s estate or next of kin.

CONCLUSIONS

SSA did not establish controls to annotate death information on the Numident record of 

numberholders who exceeded maximum reasonable life expectancies and were likely deceased. 

At the time of our review, SSA’s Numident included approximately 6.5 million numberholders 

who were born before June 16, 1901 but who did not have death information on their record. 

SSA issued almost all the SSNs to process benefit claims filed by the numberholders or their 

family members before March 1972 and had previously input dates of death on more 1.8 million 

of these numberholders’ payment records but did not record the death entries on the Numident. 

In addition, we identified thousands of instances of potential identity theft or other fraud 

involving these SSNs. Specifically, we identified approximately $3.1 billion in earnings 

reported by employers and self-employed individuals using 66,920 SSNs although they were not 

the actual numberholder. 

Resolving these discrepancies will improve the accuracy and completeness of the DMF and help 

prevent future misuse of these SSNs. 

RECOMMENDATIONS

We recommend that SSA:

1. Add death information to the 48,746 “Death Claim” Numident records that did not already 

contain a death entry.

2. Record dates of death appearing on the MBR to the Numident records of 1.4 million 

non-beneficiary numberholders. 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 9 

3. Determine whether it can efficiently correct the approximately 5 million remaining records 

identified by our audit. 

4. Review and take appropriate action to resolve discrepancies in cases where multiple 

individuals appeared on the same Numident record, beneficiaries’ payment records 

referenced the wrong SSN, or date-of-birth discrepancies existed between the beneficiaries’ 

payment and Numident records. 

AGENCY COMMENTS AND OIG RESPONSE

SSA agreed with Recommendations 3 and 4. SSA stated that, while it had concerns about the 

resource impact and error risk of correcting very old non-beneficiary records, it would explore 

the legal and technical feasibility, as well as the cost, to establish an automated process to update 

these records. SSA agreed to complete its analysis by the end of FY 2015. SSA also stated it 

would review the 219 cases discussed in Recommendation 4 and take corrective action, as

appropriate, in accordance with policy. 

However, SSA disagreed with Recommendations 1 and 2. SSA stated that updating the 

Numident based on old payment record information would require significant manual analysis 

and development of new automated screening protocols and could result in inaccurate death 

information on the Numident and DMF. SSA stated this data validation for non-beneficiary 

records would detract from other mission-critical work, such as redesigning SSA’s death 

processing system. The Agency’s comments are included in Appendix B. 

As encouraged as we are by SSA’s response to Recommendations 3 and 4, we are equally 

disappointed with SSA’s simultaneous refusal to correct the 1.5 million records in 

Recommendations 1 and 2. In these cases, SSA records already contained the date SSA 

processed a death claim on the deceased individual’s record (Recommendation 1) or the 

numberholders’ actual month and year of death (Recommendation 2). We are simply asking that 

SSA incorporate into the Numident the death information already in its payment records. 

SSA generally dismisses these discrepancies by stating that the numberholders do not receive 

payments. However, the 6.5 million records represent a significant void in the DMF. Federal 

benefit-paying entities, the Department of Homeland Security, the Internal Revenue Service, 

State and local government entities, and private industry customers who rely on the accuracy of 

completeness of SSA’s death information to detect unreported deaths and prevent fraud are not 

concerned with the deceased individuals’ Social Security benefit status. Even though these 

identities are not being used to receive Social Security benefits, they can be used for other 

improper activities, such as filing for benefits from other Federal agencies or States, opening 

bank accounts, or applying for jobs. 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) 

APPENDICES 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) A-1 

Appendix A – SCOPE AND METHODOLOGY

To accomplish our objective, we: 

 Reviewed pertinent sections of the Social Security Administration’s (SSA) policies and 

procedures as well as other relevant Federal laws and regulations.

 Interviewed SSA staff.

 We identified approximately 6.5 million numberholders whose Numident date of birth was 

before June 16, 1901 (age 112 or older as of June 15, 2013) but whose Numident record did 

not contain a death entry (date of death). We then 

 matched the Social Security numbers (SSN) against SSA’s Earnings Suspense Files (both 

wages and self-employment);

 identified numberholders who had either a Master Beneficiary or Supplemental Security 

Record that contained a death entry; 

 identified numberholders with wages posted to the Master Earnings File in at least 1 Tax 

Year from 2008 through 2012; 

 identified numberholders who were in current pay status on either the Master Beneficiary 

or Supplemental Security Record; and

 matched the SSNs against E-Verify data for Calendar Years 2008 through June 2011. 

 We also matched 1,000 randomly selected SSNs against SSA’s Death Master File and 

confirmed that none of the SSNs appeared in the Death Master File. 

We conducted our audit between November 2013 and September 2014 in Dallas, Texas. We 

determined the data used for this audit were sufficiently reliable to meet our audit objective. The 

primary entities audited were the Offices of the Deputy Commissioners for Systems and 

Operations. We conducted this performance audit in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit objectives. 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) B-1 

Appendix B – AGENCY COMMENTS

SOCIAL SECURITY

MEMORANDUM

Date: February 06, 2015 Refer To: S1J-3

To: Patrick P. O’Carroll, Jr.

Inspector General

From: Frank Cristaudo /s/ 

 Executive Counselor to the Commissioner 

Subject: Office of the Inspector General Draft Report, “Numberholders Age 112 or Older Who Did Not 

Have a Death Entry on the Numident” (A-06-14-34030) – INFORMATION

Thank you for the opportunity to review the draft report. Please see our attached comments. 

Please let me know if we can be of further assistance. You may direct staff inquiries to 

Gary S. Hatcher at (410) 965-0680. 

Attachment
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) B-2

COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL DRAFT

REPORT, "NUMBERHOLDERS AGE 112 OR OLDER WHO DID NOT HAVE A

DEATH ENTRY ON THE NUMIDENT" (A-06-14-34030)

Thank you for the opportunity to review and comment on this report. Your findings and 

recommendations from prior audits helped us to improve and update our records with

accurate dates of death. For example, we:

• created a management information system to capture death report information;

• made systems changes to prevent future discrepancies between death data on our 

Social Security number (SSN) records (the Numident file) and payment records 

(Master Beneficiary Record (MBR) and the Supplemental Security Record); and

• conducted a monthly match to identify discrepancies between SSN records and the 

payment records, which we send to the field offices for resolution.

To date, we have corrected death information for over 200,000 beneficiary records. We

would like to emphasize several important points.

• The cases identified by OIG in this report are not cases where we are making 

improper payments. When we receive a report of death, we take timely action to 

terminate payment.

• We place the highest priority on ensuring the accuracy and integrity of our payment 

files. This means first ensuring that our program records-the records upon which

we base eligibility and payments-are as accurate and consistent as possible for

current and future beneficiaries. Most of the cases identified by the OIG are nonbeneficiary records, for which we do not have a business reason to expend resources 

to correct records. Recent efforts to correct beneficiary records include:

o In 2012, we implemented a project to improve consistency of identifying 

information in our records. Before technicians approve a claim the

identifying information within our records must match. Consistency ensures 

that when we receive a death report, the death information is posted to all of

our master records.

o In 2013, we began an effort to place a special termination code of “aged 

termination” for certain beneficiary records who were at least 115 years or

older who did not have death information in our records.

• Furthermore, we continue to make progress on the re-design or our Death, Alert, and 

Control and Update System (DACUS). In fiscal year (FY) 2014, we implemented 

the first phase of this death redesign initiative, and we have scheduled further 

enhancements by the end of FY 2015. Further investments, beyond FY 2015 in 

improving our death record-keeping system, and correcting possible inaccuracies in 

existing death records will depend of course upon the availability of sufficient 

agency resources. As we have worked to implement these improvements to our 

death recordkeeping, we have placed the highest priority on ensuring the accuracy 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) B-3

and integrity of our payment files, which are the bases for our determining eligibility 

for payment of benefits.

• We continue to work to expand the use of Electronic Death Registration (EDR). 

This streamlined electronic process, which began in 2002, allows States to match the 

name and the SSN of a deceased person before submitting death records to us. Thus, 

EDR provides us with more accurate and timely death reports, and universal 

implementation could largely eliminate errors in the death reporting process.

Currently, 37 States and 2 jurisdictions participate in EDR. In combination, the 

increased use of EDR and implementation of our death redesign initiative will 

substantially improve the accuracy of death information in our databases 

prospectively.

We are pleased the review did not identify program fraud, and there were only three

confirmed instances of employment fraud in the sample of 6.5 million deceased individuals.

Based on the preliminary analysis provided, we believe correcting records for nonbeneficiaries who have a date of birth before June 16, 1901 would divert resources from our

highest priority, ensuring and improving payment accuracy. Therefore, we must 

respectfully disagree with the first two recommendations in the report. The

recommendations would create a significant manual and labor-intensive workload and

provide no benefit to the administration of our programs.

Recommendation I

Add death information to the 48,746 “Death Claim” Numident records that did not already 

contain a death entry.

Response

We disagree. We established Death claim payment records based on paper processes, prior

to the establishment of our Numident record. At the time the Numident was established, we

did not have automated processes to update death information from our payment records.

Updating the Numident based on old payment record information could result in inaccurate

death information on the Numident and DMF. Taking additional action to verify the

accuracy of death information on death claims would detract from other mission critical 

work such as redesigning our death processing system. 

Recommendation 2

Record dates of death appearing on the MBR to the Numident records of 1.4 million

non-beneficiary numberholders.

Response

We disagree. Due to the inaccuracies found in these very old records, we would have to 

undertake significant manual analysis and develop new automated screening protocols.

We would also incur significant risk of transferring inaccurate data to the Numident. The

OIG findings noted many of the data errors in these old records. In fact, some of the 
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) B-4

records identified included multiple dates of birth, so we would need to complete rigorous 

data validation to ensure that we do not mistakenly add a date of death to the Numident

for a living person. This expensive data validation effort for non-beneficiary records

would divert resources away from mission critical work.

Recommendation 3

Determine whether it can efficiently correct the approximately 5 million remaining 

records identified by our audit.

Response

We agree. While we remain concerned about the resource impact and error risk of 

correcting very old non-beneficiary records, we will explore the legal and technical 

feasibility, as well as the cost, to establish an automated process to update these records. 

We will complete our analysis by the end of FY 2015.

Recommendation 4

Review and take appropriate action to resolve discrepancies in cases where multiple 

individuals appeared on the same Numident record, beneficiaries’ payment records 

referenced the wrong SSN, or date-of-birth discrepancies existed between the 

beneficiaries’ payment and Numident records.

Response

We agree. We will review the 219 cases identified and take corrective action, as 

appropriate, in accordance with policy.
Numberholders Age 112 or Older Who Did Not Have a Death Entry on the Numident (A-06-14-34030) C-1

Appendix C – MAJOR CONTRIBUTORS

Ron Gunia, Director, Dallas Audit Division

Neha Smith, Audit Manager

David McGhee, Senior Auditor

Alla Resman, Information Technology Specialist

Luis Ramirez, Audit Data Specialist

Wilfred Wong, Audit Data Specialist
MISSION

By conducting independent and objective audits, evaluations, and investigations, the Office of 

the Inspector General (OIG) inspires public confidence in the integrity and security of the Social 

Security Administration’s (SSA) programs and operations and protects them against fraud, 

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