Audit Report

OIG-16-042

Fiscal Service Faces Challenges in Obtaining Better Death 

Information For the Do Not Pay Business Center, But 

Alternatives Exist

May 18, 2016

Office of

Inspector General

Department of the Treasury

Contents

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Audit Report

Results in Brief .............................................................................................. 1

Background................................................................................................... 3

Review Results .............................................................................................. 9

Fiscal Service Faces Challenges in Obtaining Full Death Information for the 

Do Not Pay Business Center ....................................................................... 9

Obtaining Better Death Information for the Do Not Pay Business Center........... 13

Recommendations.......................................................................................... 17

Appendices

Appendix 1: Objectives, Scope, and Methodology .................................... 20

Appendix 2: Management Response ....................................................... 23

Appendix 3: Major Contributors to This Report......................................... 25

Appendix 4: Report Distribution.............................................................. 26

Abbreviations and Short References

AIS American InfoSource 

DMF Death Master File

EDRS Electronic Death Registration System

EVVE Electronic Verification of Vital Events System

Fiscal Service Bureau of the Fiscal Service

GAO Government Accountability Office

IPERIA Improper Payments Elimination and Recovery Improvement Act 

of 2012 

NAPHSIS National Association for Public Health Statistics and Information 

Systems

NDI National Death Index

NTIS National Technical Information Service

OIG Office of Inspector General

OMB Office of Management and Budget

PACER Payments, Claims, and Enhanced Reconciliation

PAM Payment Automation Manager

SSA Social Security Administration

The Center Do Not Pay Business Center

Treasury Department of the Treasury
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This Page Intentionally Left Blank.
OIG Audit

Report

The Department of the Treasury

Office of Inspector General

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May 18, 2016

Sheryl Morrow

Commissioner

Bureau of the Fiscal Service

This report presents the results of our review of the availability of 

death information to the Do Not Pay Business Center.

1 Our 

objective was to summarize the challenges that the Bureau of the 

Fiscal Service (Fiscal Service) faces in obtaining full death 

information for the Do Not Pay Business Center and discuss 

possible alternatives to overcome those challenges. 

To prepare this report, we reviewed laws, proposed legislation, 

Federal guidance, audit reports, and other documentation related to 

improper payments, Fiscal Service’s Do Not Pay Business Center, 

Social Security Administration (SSA) death information, and death 

information in general. We interviewed officials and personnel from 

Fiscal Service, SSA, and the National Association for Public Health 

Statistics and Information Systems (NAPHSIS). We conducted our 

fieldwork principally during January through May 2015. 

Appendix 1 contains a detailed description of our objective, scope, 

and methodology.

Results in Brief

During the course of our review we found that three conditions 

impacted the Do Not Pay Business Center’s access to death 

information to the records available in the publically available Death 

Master File (DMF): (1) SSA’s interpretation of the Social Security 

Act to prohibit SSA from sharing its full death file with Fiscal 

 

1 The Do Not Pay Business Center includes the Do Not Pay portal and Data Analytics Services. The Do 

Not Pay portal is a single-entry, web-based portal that allows agencies to check various databases to 

help identify ineligible recipients before making payments or awards. Data Analytics Services 

provides agencies specific, customized analysis to combat improper payments, including analyzing 

payment files for irregularities and matching payment files against available data sources.
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Service; (2) the slow pace of legislation that could allow for

sharing; and (3) the lengthy approval process to make additional 

databases available to the Do Not Pay Business Center beyond 

those required by the Improper Payments Elimination and Recovery 

Improvement Act of 2012 (IPERIA).

2

In addition, we also note that 

SSA death information does include inaccuracies.

Though there are challenges to obtaining better death information 

for the Do Not Pay Business Center, potential alternatives to 

improve the quality of the death data used by the Center exist. 

These alternatives include continuing to pursue the use of 

additional data sources, such as the commercial sources currently 

under evaluation. A nonprofit organization representing the State 

vital records offices may also merit periodic re-evaluation as a 

potential data source. Another alternative—entering into contracts 

with individual States to obtain State-reported death data—shows 

less promise.

Subsequent to the completion of our fieldwork, Congress enacted 

the Federal Improper Payments Coordination Act of 2015.

3 This 

law amended IPERIA to, among other things, make a technical 

correction to the database of death records that is to be used by 

the Do Not Pay Initiative. In addition, Fiscal Service is working with 

the Office of Management and Budget (OMB) to identify

commercial databases of death information to supplement the 

public DMF, and to gain OMB’s approval to use such databases for 

Do Not Pay purposes.

We are recommending that the Fiscal Service Commissioner:

(1) work with OMB and SSA to implement the Federal Improper 

Payments Coordination Act of 2015 to ensure all death records 

maintained by SSA are available to Fiscal Service to help prevent, 

identify, or recover improper payments; (2) continue to work with 

OMB to designate additional cost effective and accurate data 

sources for the Do Not Pay Business Center and identify possible 

ways to shorten the designation process, and (3) periodically 

 

2 Public Law 112-248 (Jan. 10, 2013).

3 Public Law 114-109 (Dec. 18, 2015).
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evaluate sources of death information for the Do Not Pay Business 

Center and consider adding cost-beneficial alternatives.

In its response, provided as Appendix 2, Fiscal Service 

management concurred with our recommendations. Fiscal Service

has been working OMB and SSA to implement the Federal Improper 

Payments Coordination Act of 2015. The response noted, 

however, that as the owners of the full death records, SSA must 

agree that the Act allows SSA to release the full death dataset to 

Fiscal Service. With respect to other data sources, Fiscal Service is 

continuing to work with OMB to complete an initial data 

designation for seven databases to be added to the Do Not Pay 

working system. Fiscal Service also stated that it will periodically 

survey the government and commercial marketplace to identify 

potentially useful data sources. These commitments by Fiscal 

Service are responsive to our recommendations. Fiscal Service will 

need to establish and record target dates for incomplete actions in 

the Joint Audit Management Enterprise System (JAMES), the 

Department of the Treasury’s audit recommendation tracking 

system.

Background

Agencies continue to face challenges in reducing improper 

payments.4In its report on the Fiscal Year 2015 Financial Report of 

the United States Government, the Government Accountability 

Office (GAO) identified the Federal government’s inability to 

determine the full extent to which improper payments occur and to 

reasonably assure that appropriate actions are taken to reduce 

them as a material weakness in internal control.5 Government-wide 

 

4 OMB, “Appendix C to Circular No. A-123, Requirements for Effective Estimation and Remediation of 

Improper Payments” (OMB M-15-02; issued Oct. 20, 2014), defines an improper payment as any 

payment that should not have been made or that was made in an incorrect amount (overpayments or 

underpayments) under statutory, contractual, administrative, or other legally applicable requirements. 

An improper payment also includes any payment that was made to an ineligible recipient or for an 

ineligible good or service, or payments for goods and services not received. 

5 Treasury, The Financial Report of the United States Government: Fiscal Year 2015 (Feb. 25, 2016). 
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improper payments were estimated at approximately $137 billion in 

fiscal year 2015.

6

The Improper Payments Elimination and Recovery Act of 20107

(IPERA) was enacted to expand improper payments elimination and 

recovery efforts. The Act requires agencies to perform improper 

payment reviews and risk assessments and prepare certain reports.

IPERA also requires the Inspector General of each agency to 

determine whether the agency complied with IPERA and to issue a 

report on that determination each fiscal year.8

IPERIA9 was enacted in 2012 to intensify efforts to identify, 

prevent, and recover payment error, waste, fraud, and abuse 

within Federal spending. Section 5 of IPERIA expanded on the Do 

Not Pay Initiative requiring that, at a minimum, and before issuing 

any payment or award, agencies review the following six

databases to verify the eligibility of payments:

 Death Master File (SSA)

 Excluded Parties List System (General Services 

Administration)

 Debt Check Database (Department of the Treasury)

 Credit Alert System or Credit Alert Interactive Voice 

Response System (Department of Housing and Urban 

Development) 

 List of Excluded Individuals/Entities (Department of Health 

and Human Services Office of Inspector General)

 Information regarding incarcerated individuals10 (SSA)

 

6 The 2015 estimate of government-wide improper payments consists of $126 billion in estimated 

overpayments and $11 billion in estimated underpayments. (Source: PaymentAccuracy.gov)

7 Public Law 111-204 (July 22, 2010).

8 Treasury OIG performs an annual IPERA compliance audit for Treasury. Our most recent report is 

Treasury’s Improper Payment Reporting Needs Improvement (OIG-15-033; issued May 15, 2015).

9 Public Law 112-248 (Jan. 10, 2013).

10 Information regarding incarcerated individuals maintained by the Commissioner of Social Security 

was added to Section 5 of IPERIA as a sixth required database in December 2013 with the 

enactment of the Bipartisan Budget Act of 2013. 
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OMB Memorandum M-13-20, “Protecting Privacy while Reducing 

Improper Payments with the Do Not Pay Initiative”

(OMB M-13-20), implements section 5 of IPERIA and provides 

guidance to Federal agencies on reducing improper payments with 

the Do Not Pay Initiative. Part 4 of the memorandum describes

Treasury’s responsibility to host a working system for the Do Not 

Pay Initiative that allows agencies to perform the pre-payment 

eligibility reviews required by IPERIA.

Fiscal Service

Fiscal Service is the principal disburser of payments to individuals 

and businesses on behalf of Federal agencies—for example, benefit 

payments paid by SSA or the Department of Veterans Affairs, 

Federal income tax refund payments, and payments to businesses 

for goods and services. Most payments are disbursed through 

electronic funds transfers; the remaining are check payments. 

Annually, Fiscal Service disburses more than a billion payments, 

with an associated value of more than $2.4 trillion.

The Do Not Pay Business Center

In April 2011, Fiscal Service established the Do Not Pay Business 

Center to support Federal agencies in their efforts to reduce the 

number of improper payments made through programs funded by 

the Federal government. In our November 2014 audit report on the 

establishment of the Do Not Pay Business Center, we noted that it 

did not have access to two of the six IPERIA-required databases 

and that access to SSA’s death information was limited to the lesscomplete public DMF.

11 This situation remained substantially 

unchanged as of March 2016, although progress had been made to 

obtain access to the two IPERIA-required databases.

 

11 Treasury OIG, OIG-15-006, Fiscal Service Successfully Established the Do Not Pay Business Center 

But Challenges Remain (Nov. 6, 2014). The two required databases that the Do Not Pay Business 

Center did not have access to were the Credit Alert System or Credit Alert Interactive Voice 

Response System and the Prisoner Update Processing System.
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In 2013, Fiscal Service began automatically running all of the 

Payments, Claims, and Enhanced Reconciliation (PACER)12 and 

Payment Automation Manager (PAM)13 payment files that it 

processes on behalf of Federal agencies against the public DMF

and the Excluded Parties List System. Do Not Pay Business Center 

client agencies may also customize their use of the Do Not Pay 

Portal to run against the other available databases.

From April 2014 to April 2015, approximately 675 million 

payments (591 million PACER payments and 84 million PAM 

payments), totaling $1.6 trillion, were run against the DMF. Of 

those payments, there were matches to the DMF (before postpayment activity) for approximately 780,000 payments, totaling 

$876 million. 

Matches are not conclusive proof that an improper payment has 

occurred. Paying agencies need to investigate the matched 

payments to determine whether payments are improper. Agencies 

enrolled in the Do Not Pay portal can review their matches in the 

portal, while agencies not enrolled in the Do Not Pay Portal receive 

matches via email. Documentation provided by Fiscal Service 

states that for the 9 months ending June 2015, the Do Not Pay 

Portal screened $941 billion in payments that resulted in agencies 

identifying $5.7 million in improper payments. We did not verify 

that information as part of this audit.

SSA’s Full Death File

SSA collects death information to help administer its programs and 

to ensure that it does not pay Social Security benefits to deceased 

individuals. SSA’s full death file, also referred to as the “public plus 

State” version of the DMF, contains all death information reported 

to SSA. Sources of death information in this file include States, 

family members, funeral homes, Federal agencies (such as the

Centers for Medicare and Medicaid Services and Veteran’s Benefits 

Administration), postal authorities, financial institutions, and 

 

12 PACER functions as an online, shared database that supports accounting and claim processes in 

Fiscal Service’s Regional Financial Centers. The application provides daily check reconciliation, daily 

electronic fund transfer reconciliation, daily accounting balancing, and cancellation information.

13 PAM is a standardized payment processing application that can be expanded and configured to 

support the specific needs of Federal agencies, annually processing approximately 1 billion Federal 

payments.
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internal sources from SSA’s payments records. The full death file 

contains beneficiary and non-beneficiary death records, as well as 

verified and unverified data. As of March 2015, this file contained 

about 100 million records. Approximately 2.5 million records are 

added to the file each year. 

State-reported Death Data

The State-reported death data included in the full death file is 

accumulated and reported to SSA either electronically or manually

by State vital records offices. In 2014, 39 jurisdictions (37 States 

plus New York City and the District of Columbia) were able to 

submit death records to SSA electronically via the jurisdiction’s

Electronic Death Registration System (EDRS).14 These jurisdictions 

submitted 1,839,243 death records to SSA via EDRS (66 percent

of the State death records submitted) and 211,713 death records 

manually (8 percent of State death records submitted to SSA).

Fourteen jurisdictions (13 States and Puerto Rico) could only 

submit death records manually in 2014. These jurisdictions

submitted 739, 439 death records to SSA (26 percent of the total 

number of death records submitted). 

In accordance with section 205(r)(2) of the Social Security Act,15

SSA pays for the State death records to administer its programs. 

These records are then included in the full death data file. SSA 

uses a tiered fee structure to pay the States for transcribing and 

transmitting death information to SSA. The price per death 

reported by the States for 2014 ranges from $0.86 to $3.09. For 

pre-verified death information reported via the EDRS within 6 days 

of the date of death, SSA pays the States $3.09. For non-EDRS 

reports submitted within 120 days of the date of death, it pays 

 

14 EDRS is a system that automates the electronic registering and processing of death reports to 

improve timeliness and accuracy. SSA considers reports submitted by States through EDRS to be the 

most accurate because most States first verify the name and social security number of the decedent 

with SSA databases before submitting a death report. 

15 Section 205(r)(2) of the Social Security Act provides that each State (or political subdivision thereof) 

that furnishes the Commissioner of Social Security with information on records of deaths in the State 

or subdivision may be paid from amounts available for administration of this Act, the reasonable 

costs (established by the Commissioner of Social Security in consultations with the States) for 

transcribing and transmitting such information.
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$0.86. SSA paid approximately $12 million for EDRS and nonEDRS death records using fiscal year 2014 funds.

Publicly Available Death Master Files

SSA shares death information, subject to limitations specified in 

the Social Security Act16 and the Bipartisan Budget Act of 2013,

17

with the U.S. Department of Commerce’s National Technical 

Information Service (NTIS). NTIS reimburses costs incurred by 

SSA, and then sells two separate DMF products to public and 

private organizations.

 The “Limited Access DMF” is available to persons certified 

by the Department of Commerce to have a legitimate fraud 

prevention or business purpose; and, systems, facilities and 

procedures in place to safeguard the information.18 The 

Limited Access DMF includes information on deceased 

individuals maintained by SSA other than that obtained by 

SSA under section 205(r) of the Social Security Act (i.e., 

State-reported death data). Fiscal Service purchases the 

Limited Access DMF from NTIS for the Do Not Pay Business 

Center for approximately $10,000 per year.

 

16 Section 205(r)(6) of the Social Security Act states that information furnished to the Commissioner of 

Social Security through a “program under which States (or political subdivisions thereof) voluntarily 

contract with the Commissioner of Social Security to furnish the Commissioner of Social Security 

periodically with information concerning individuals with respect to whom death certificates (or 

equivalent documents maintained by the States or subdivisions) have been officially filed with 

them...may not be used for any purpose other than the purpose described in Section 205(r) of the 

Social Security Act and is exempt from disclosure under section 552 of Title V of the United States 

Code (also known as the Freedom of Information Act)”.

17 Section 203 of the Bipartisan Budget Act of 2013 (Pub. L. 113-67) (Act) prohibits disclosure of DMF 

information during the 3 years following a death unless the person requesting the information has 

been certified under a program established by the Secretary of Commerce.

18 Department of Commerce, Interim Final Rule, Temporary Certification Program for Access to the 

Death Master File, 79 FR 16670 (Mar. 26, 2014) (to be codified at 15 CFR 1110) implements the 

certification process provided for by Section 203 of the Bipartisan Budget Act of 2013 (Pub. L. 

113-67). Supplementary Information included in the Interim Final Rule states that “Executive 

Departments and agencies will not have to complete the Certification Form as set forth in the rule. 

Those working on behalf of and authorized by Executive departments or agencies may access the 

Limited Access DMF through that sponsoring Executive department or agency”. Accordingly, Fiscal 

Service is able to purchase the Limited Access DMF.
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 The “Public DMF” is available to persons without restriction.

The Public DMF includes information on deceased individuals 

maintained by SSA other than that which was provided 

under section 205(r) of the Social Security Act (i.e., Statereported death data) and that which is prohibited from 

disclosure by the Bipartisan Budget Act of 2013 (i.e., 

information on deaths occurring in the prior 3 years).

Other Death Information

Federal agencies other than SSA, including the Department of 

Defense, Department of State, Department of Education, and the

National Center for Health Statistics, also collect and maintain 

death information. 

The National Center for Health Statistics works with the States’

departments of vital records and statistics offices to establish the 

National Death Index (NDI). However, the NDI is available solely for 

statistical purposes in medical and health research.

19

Review Results

Fiscal Service Faces Challenges in Obtaining Full Death 

Information for the Do Not Pay Business Center

GAO stated in its March 2015 testimony on improper payments 

that 

“sharing death information can help prevent improper 

payments to deceased individuals or those who use 

deceased individuals’ identities, but SSA faces challenges in 

maintaining these data, and other agencies face challenges 

in obtaining them.”

20

 

19 Section 308(d) of the Public Health Services Act provides that the data collected by the National 

Center for Health Statistics, in the Centers for Disease Control and Prevention, may be used only for 

the purpose of health statistical reporting and analysis. The United States Census Bureau also uses 

birth and death information from the National Center for Health Statistics and from the States’

departments of vital statistics in its population projections program.

20 GAO, Improper Payments—Government-Wide Estimates and Use of Death Data to Help Prevent 

Payments to Deceased Individuals (GAO-15-482T; issued Mar. 16, 2015).
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Fiscal Service’s Do Not Pay Business Center can access only the 

Limited Access DMF. The Center’s inability to access the most 

complete death information available reduces its effectiveness as a 

tool to help agencies identify and prevent improper payments.

Fiscal Service officials told us that running payment files against a 

more complete set of death records would likely result in more 

matches which, once investigated, could identify and prevent more 

improper payments.

The Do Not Pay Business Center’s access to death information has 

been limited by three conditions: (1) SSA’s interpretation of the 

Social Security Act to prohibit SSA from sharing the full death file 

with Fiscal Service; (2) the slow pace of legislation that could allow 

for sharing, and (3) the lengthy approval process to make additional 

databases available to the Do Not Pay Business Center beyond 

those required by IPERIA. We discuss these challenges further in 

this report. In addition, we have noted that concerns with the 

overall accuracy of SSA’s death information pose another 

challenge.

SSA Interpretation

According to a November 2013 GAO report, SSA interpreted the 

Social Security Act to prevent sharing of the full death file with 

Treasury (Fiscal Service) even though the Do Not Pay Business 

Center serves the purpose of preventing improper payments. 

Section 205(r)(3) of the Social Security Act allows SSA to share 

the contents of the full death file with Federal or State agencies 

that pay Federally funded benefits. In addition, the Act gives SSA 

discretionary authority to provide State death information to 

Federal and State agencies for research purposes. SSA provides 

this file to several Federal agencies, including the Centers for 

Medicare and Medicaid Services, Department of Defense, 

Department of Veterans Affairs, Office of Personnel Management, 

Internal Revenue Service, GAO, the Railroad Retirement Board, and 

the Pension Benefit Guaranty Corporation. 

GAO reported in November 2013 that SSA officials could not 

provide documentation outlining their rationale for denying Treasury 
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access and did not have written guidance available for determining 

agency access to full death information.21

Slow Pace of Legislation

Past legislative proposals to provide greater access to SSA’s full 

death data were not enacted. For example, the proposed Improper 

Payments Agency Cooperation Enhancement Act of 2013 (S. 1360 

and H.R. 3555) would have required SSA to create a National 

Deaths Registry, using its full death information, and to enter into 

cooperative agreements with agencies to provide access. SSA 

would have been required to provide the National Deaths Registry 

in full, and without limitation, to agencies for the purposes of 

making authorized payments or for the prevention, identification, or 

recovery of improper payments. However, since the last action on 

this legislation was in September 2014, the legislation became 

ineligible for consideration at the end of the 113th Congress in 

January 2015.

Lengthy Approval Process to Add Databases

Fiscal Service may recommend to OMB to add databases to the Do 

Not Pay Business Center to supplement those currently available, if 

the databases will substantially assist agencies in preventing

improper payments. Fiscal Service officials stated that some

commercial sources provide better death information than the

public DMF and, perhaps, SSA’s full death file. However, obtaining 

death information for the Do Not Pay Business Center from 

commercial sources can take time because OMB M-13-20 requires 

OMB to follow an extensive authorization process to designate 

additional data sources for inclusion in the Do Not Pay Initiative.

According to OMB M-13-20, before designating additional 

databases, OMB will publish a 30-day notice of the designation 

proposal in the Federal Register asking for public comment. At the 

conclusion of the 30-day comment period, if OMB decides to 

finalize the designation, it will publish a notice in the Federal 

Register to designate officially the database for inclusion in the Do 

 

21 GAO, Social Security Death Data: Additional Action Needed to Address Data Errors and Federal 

Agency Access (GAO-14-46; issued Nov. 27, 2013).
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Not Pay Initiative. In the process to designate additional databases, 

OMB considers the following:

 statutory or other limitations on the use and sharing of 

specific data

 privacy restrictions and risks associated with specific data

 likelihood that the data will strengthen program integrity 

across programs and agencies

 benefits of streamlining access to the data through the 

central Do Not Pay Initiative

 costs associated with expanding or centralizing access, 

including modifications to system interfaces or other 

capabilities needed to make data accessible

 other policy and stakeholder considerations, as appropriate

On March 19, 2015, Fiscal Service submitted a draft designation 

proposal to incorporate three data sources to the Do Not Pay 

Business Center. On September 4, 2015, almost 6 months after 

submission, OMB provided Fiscal Service with comments and 

questions on the proposal. Fiscal Service officials have told us that 

OMB’s comments deal primarily with its assessment of the data 

sources, and that Fiscal Service is working with OMB to address 

them. Fiscal Service officials told us that the delay in authorization 

is due, in part, to the fact that this is the first time either Fiscal 

Service or OMB is executing the approval process required by OMB 

M-13-20.

Accuracy of Available Death Information

Various audits have identified concerns with the quality of SSA’s 

death information. For example, GAO reported in November 2013 

that certain procedures SSA uses for collecting, verifying, and 

maintaining death reports could result in erroneous or delayed 

death information. GAO reported that SSA does not independently 

verify all reports before including them in its death records. The 

agency verifies death reports only for Social Security beneficiaries 

to stop benefit payments, and verifies only those reports from 

sources it considers less accurate, such as other Federal 

agencies.22 In addition, in March 2015 SSA’s Office of Inspector 

 

22 GAO-14-46.
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General (OIG) reported on concerns with controls to annotate death 

information on social security numberholders who exceeded 

reasonable life expectancies.23 In this regard, SSA OIG identified 

approximately 6.5 million social security numberholders, age 112 

or older, for which there is no death information in records that 

SSA uses to compile its death files.

24

Obtaining Better Death Information for the Do Not Pay 

Business Center 

The quality of the death data used by the Do Not Pay Business 

Center could be improved by the recent enactment of legislation

and continuing to pursue the use of additional data sources, such 

as the commercial alternatives currently under evaluation. A

nonprofit organization representing the State vital record offices 

may also merit periodic re-evaluation as a potential data source. 

Another alternative—entering into contracts with individual States

to obtain State-reported death data—shows less promise.

Legislation

Two pieces of legislation introduced in the U.S. Senate and House 

of Representatives in 2015 were intended to give Fiscal Service’s 

Do Not Pay Business Center access to SSA’s full death file.

 The Federal Improper Payments Coordination Act of 2015

(S. 614 and H.R. 2320), introduced in February 2015, amends 

IPERIA to, among other things: (1) extend the availability of the 

Do Not Pay Initiative to the judicial and legislative branches of 

the Government and to the States; (2) expand the Do Not Pay 

Business Center’s access to death records maintained by SSA; 

(3) require the Departments of Defense and State to submit, 

promptly and regularly, relevant information on the deaths of 

individuals; and (4) require Treasury to report to Congress on 

data analytics performed as part of the Do Not Pay Initiative.

 

23 SSA OIG, A-06-14-34030, Numberholders Age 112 or Older Who Did Not Have a Death Entry on the 

Numident (Mar. 4, 2015).

24 SSA OIG noted in its report that as of September 2014, the Gerontology Research Group reported 

42 known living individuals worldwide had reached age 112.
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On December 18, 2015, subsequent to the completion of our 

field work, the Federal Improper Payments Coordination Act of 

2015 (S. 614) was signed into law.25 With respect to death 

data, the law amended the Improper Payments Elimination and 

Recovery Improvement Act of 2012 to state that the database 

of such information to be reviewed by agencies to verify 

eligibility of payments and awards was “the death records 

maintained by the Commissioner of Social Security.” Before the 

amendment, the database was referred to as “the Death Master 

File of the Social Security Administration.” Senate Report 

114-86 accompanying S. 614 reflected this change as a 

technical correction.

 The Stopping Improper Payments to Deceased People Act

(S 1073 and H.R. 2003), introduced in April 2015, amends Title 

II of the Social Security Act to direct SSA to (1) provide 

information on all deceased individuals that is furnished to or 

maintained by SSA to Federal or State agencies providing 

benefits or administering a Federal program and (2) provide for 

the use of such information by Federal agencies to operate the 

Do Not Pay working system (the Do Not Pay Business Center) 

and to carry out tax administration or debt collection duties. No 

further action on this legislation has occurred since April 2015.

Commercial Vendors

Available commercial sources, taken together with the public DMF 

or, pending enactment of the legislation mentioned previously, the 

full death file, could provide the Do Not Pay Business Center with 

incrementally more complete death data. During fieldwork, we 

identified several commercial sources of death information, 

including vendors such as LexisNexis®, TransUnion’s TLOxp®, the 

Berwyn Group, and American InfoSource (AIS). Our review of 

these vendors’ websites found the following.

 LexisNexis® provides public record search services through 

its PeopleWise application, which allows for the search of 

death records based on an individual’s name and location. 

 

25 Public Law No. 114-109. 
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 TransUnion’s TLOxp® has a national, comprehensive, online 

death record database of public and proprietary records that 

allows users to search for deceased individuals using names, 

aliases, or social security numbers. TLOxp® people searches 

are also designed to get users exact information, even in 

cases where only partial source information is available, such 

as incomplete social security numbers or addresses.

 The Berwyn Group provides mortality verification and locator 

services through its DeathCheckSM service. Files are updated 

weekly and contain records from SSA, State, and Federal 

agencies, as well as Berwyn’s own proprietary death data. 

The Berwyn Group’s DeathCheckSM service also allows 

customers to identify deceased individuals whose social 

security numbers were miss-typed in source files. 

 AIS, a global financial services company, acquires death 

information from three main sources—(1) the public DMF, 

(2) county court probate records, and (3) obituaries from

more than 3,000 funeral homes and thousands of 

newspapers. 

Nonprofit Organization—NAPHSIS

NAPHSIS is a national nonprofit organization representing State 

vital records and public health statistics offices in the United 

States.

26 NAPHSIS’ Electronic Verification of Vital Events (EVVE) 

system provides customers with the ability to verify and certify 

birth and death information. Electronic inquiries from authorized 

users can be matched against more than 250 million birth and 

death records from State- and jurisdiction-owned vital-record 

databases nationwide.

Although the EVVE system would allow Fiscal Service access to 

State-reported death information, concerns exist with its ability to 

meet the needs of the Do Not Pay Business Center. EVVE currently 

provides access to birth information for 53 of 57 jurisdictions,

27 but

 

26 Vital records offices register births and deaths and issue certified copies of birth and death 

certificates for legal and administrative purposes.

27 The 57 jurisdictions include the 50 states, five territories, the District of Columbia, and New York 

City.
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death information can only be accessed for 42 of those

jurisdictions. Additionally, at the time of our analysis, EVVE was 

unable to support the high volumes of transaction queries that 

Fiscal Service would require. NAPHSIS personnel told us that 

NAPHSIS is working with LexisNexis® to make the EVVE system

capable of supporting higher volumes of queries by fall 2015. They 

stated they were confident that the EVVE system could be scaled 

to handle the large data requirements of Treasury’s Do Not Pay 

Business Center. However, NAPHSIS personnel also acknowledged 

that the EVVE system acts as a hub to access the systems of 

individual jurisdictions, and could have difficulty handling the 

volume of Treasury’s requests.

NAPHSIS personnel also stated that Treasury’s cost if it chose to 

use the EVVE system would be based on volume and would 

include a subscription fee plus a per-record fee for queries.

NAPHSIS estimated that the cost per record would be between 

$0.05 and $0.25, depending on the volume and frequency of the 

queries. Higher volumes of queries would result in a lower perrecord cost. NAPHSIS personnel stated that they would have been 

able to provide a more accurate pricing model if they knew the 

transaction volume and amount of payments that would be run 

through the EVVE system for death queries, along with the volume 

of expected death matches.

According to Fiscal Service officials, Fiscal Service considered 

NAPHSIS a data source for death information in 2013. However, 

Fiscal Service determined that NAPHSIS’ EVVE system at the time 

would not be able to accommodate the volume of payment files 

currently run against the public DMF in the Do Not Pay portal. In 

addition, the EVVE system was based at the time, on individual 

queries using only first and last names, not social security numbers 

or tax identification numbers. According to NAPHSIS, in Spring 

2015 it began requiring States to include a field in the database for 

social security numbers.

28

 

28 In June 2015, NAPHSIS personnel stated that approximately 34 States and jurisdictions had added 

social security numbers to the EVVE system.
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Contracts with the States

As previously mentioned, SSA pays the States for transcribing and 

transmitting death information. According to 2014 DMF statistics 

obtained from SSA, SSA paid approximately $12 million for death 

records for fiscal year 2014. NAPHSIS assisted SSA and the States 

in negotiating contracts for these relationships and could 

conceivably assist Fiscal Service in negotiating similar contracts to 

obtain State death information. However, such an alternative

presents a number of drawbacks that would likely make it

questionable, including the following:

 NAPHSIS personnel stated that the price per death reported 

by the States to Fiscal Service would likely be much higher 

than what SSA pays because Fiscal Service would be using

death information to run against payments from many 

Federal agencies. NAPHSIS personnel were unable to provide 

us with an estimate of the price per death reported without 

knowing the actual number of Federal agencies or programs 

for which Fiscal Service disburses payments.

 This alternative would result in the Federal government 

paying the States again for the same information already 

acquired by SSA, a questionable use of public funds.

 This alternative would likely require Fiscal Service to build an 

infrastructure to collect, maintain, and secure the State 

death information—a duplication of the infrastructure that 

already exists within SSA. 

Recommendations

Fiscal Service officials have taken action to supplement the Do Not 

Pay Business Center’s use of the public DMF with a commercial 

database, pending OMB approval. We recommend that the Fiscal 

Service Commissioner take the following additional actions:

1. Work with OMB and SSA to implement the Federal Improper 

Payments Coordination Act of 2015 to ensure all death records 

maintained by SSA are available to Fiscal Service to help 

prevent, identify, or recover improper payments.
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Management Response

Fiscal Service has been working with OMB and SSA to deliver 

the full death records data set and will continue to request 

access from SSA. However, as the owners of the full death 

records, SSA must agree that the Federal Improper Payments 

Coordination Act of 2015 allows SSA to release the full death 

dataset (also known as the Full Death Master File) to Fiscal 

Service.

OIG Comment

Fiscal Service’s commitment to work with OMB and SSA to 

obtain access to the Full Death Master file is responsive to our

recommendation. Fiscal Service should establish, and record in 

JAMES, the anticipated date actions under this recommendation 

will be completed.

2. Continue to work with OMB to designate additional cost 

effective and accurate data sources for the Do Not Pay 

Business Center and identify possible ways to shorten the 

designation process.

Management Response

Fiscal Service continues to work with OMB to complete an 

initial Data Designation for seven databases to be added to the

Do Not Pay working system. The data designation was sent to 

OMB on March 25, 2016, and Fiscal Service is awaiting a 

response from OMB. Fiscal Service and OMB have a very close 

working relationship and that relationship will be leveraged to 

attempt to improve the timing of future OMB designations of 

data sources for Do Not Pay.

OIG Comment

Fiscal Service’s commitment to work with OMB to designate 

data sources and improve the timing of future designations is 

responsive to our recommendation. Fiscal Service should 

establish, and record in JAMES, the anticipated date action

Data Designations under OMB review will be completed.
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3. Periodically evaluate sources of death information for the Do 

Not Pay Business Center and consider adding cost-beneficial 

alternatives. 

Management Response

Fiscal Service will continue to periodically survey the 

government and commercial marketplace to identify any 

potential data sources which could assist agencies in the 

prevention, identification or recovery of improper payments.

OIG Comment

Fiscal Service’s commitment to periodically evaluate sources of 

death information is responsive to our recommendation. We 

consider this recommendation to be closed.

* * * * *

We appreciate the courtesies and cooperation provided to our staff 

during the review. If you wish to discuss the report, you may 

contact me at (202) 927-6345. Major contributors to this report 

are listed in Appendix 3.

/s/

James L. Lisle, Jr.

Director, Fiscal Service Audits 
Appendix 1

Objectives, Scope, and Methodology 

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Our objective was to summarize the challenges that the Bureau of 

the Fiscal Service (Fiscal Service) faces in obtaining full death 

information for the Do Not Pay Business Center and discuss 

possible alternatives to overcome those challenges.

To accomplish our audit objective, we took the following actions:

 reviewed laws (and proposed legislation) and Federal 

guidance related to improper payments, including public 

laws, executive orders, presidential memoranda, and Office 

of Management and Budget (OMB) memoranda: 

o Improper Payments Elimination and Recovery 

Improvement Act of 2012 (IPERIA)

o Improper Payments Elimination and Recovery Act of 

2010 

o Presidential Memo, Enhancing Payment Accuracy 

Through a Do Not Pay List, June 2010

o Executive Order 13520, Reducing Improper Payments 

and Eliminating Waste In Federal Programs, November 

2009

o Bipartisan Budget Act of 2013, section 204,

Identification of Inmates Requesting or Receiving 

Improper Payments

o Public Health Service Act, section 308(d), National 

Center of Health Services Confidentiality Statute

o Federal Improper Payments Coordination Act of 2015

[Proposed Legislation]

o OMB M-13-20, Protecting Privacy while Reducing 

Improper Payments with the Do Not Pay Initiative

o OMB M-12-11, Reducing Improper Payments through 

the “Do Not Pay List”

 reviewed laws (and proposed legislation), Federal guidance, 

congressional testimonies, and audit reports related to the 

Social Security Administration (SSA) Death Master File

(DMF) and death information in general, including the 

following:

o Social Security Act, Section 205(r), “Use of Death 

Certificates To Correct Program Information”
Appendix 1

Objectives, Scope, and Methodology 

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o Improper Payments Agency Cooperation Enhancement 

Act of 2013 [Proposed Legislation]

o Stopping Improper Payments to Deceased People Act 

[Proposed Legislation]

o Government Accountability Office (GAO)-15-482T, 

Improper Payments: Government-Wide Estimates and 

Use of Death Data to Help Prevent Payments to 

Deceased Individuals, March 2015

o GAO-15-440T, Government Efficiency and 

Effectiveness: Opportunities to Reduce Fragmentation, 

Overlap, Duplication, and Improper Payments and 

Achieve Other Financial Benefits, March 2015

o GAO-14-46, Social Security Death Data: Additional 

Action Needed to Address Data Errors And Federal 

Agency Access, November 2013

o GAO-13-574T, Social Security Administration: 

Preliminary Observations on the Death Master File, 

May 2013

o GAO-12-405T, Improper Payments: Moving Forward 

with Governmentwide Reduction Strategies, February 

2012

o SSA A-06-14-34030, Number-holders Age 112 or 

Older Who Did Not Have a Death Entry on the 

Numident, March 2015 

 interviewed officials and personnel from Fiscal Service, SSA, 

and the National Association for Public Health Statistics and 

Information Systems

 reviewed documentation related to the Do Not Pay Business 

Center, SSA’s DMF, and the process SSA uses to receive 

death information, including:

o Pay Business Center Statistics for April 2014–April 

2015

o SSA FY 2014 DMF Statistics

We performed our audit fieldwork principally during January

through May 2015.
Appendix 1

Objectives, Scope, and Methodology 

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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 that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix 2

Management Response 

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Appendix 2

Management Response 

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Appendix 3

Major Contributors

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Christen J. Stevenson, Audit Manager

Ashley N. Smith, Auditor-in-Charge

Herb N. Addy, Auditor

Justin Summers, Referencer
Appendix 4

Report Distribution

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Department of the Treasury

Deputy Secretary

Fiscal Assistant Secretary

Office of the Deputy Chief Financial Officer, Risk and Control 

Group

Office of Strategic Planning and Performance Management

Bureau of the Fiscal Service

Commissioner

Executive Director, Do Not Pay Business Center

Director, Finance and Internal Control Division

OIG Liaison

Office of Management and Budget

OIG Budget Examiner

Treasury OIG Website

Access Treasury OIG reports and other information online: 

http://www.treasury.gov/about/organizational-structure/ig/Pages/default.aspx

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Email: Hotline@oig.treas.gov

Submit a complaint using our online form: 

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