SOCIAL SECURITY 

ADMINISTRATION

Preliminary Observations 

on the Death Master File

Statement of Daniel Bertoni, Director 

Education, Workforce, and Income Security Issues 

Testimony 

Before the Committee on Homeland 

Security and Governmental Affairs, 

U.S. Senate

For Release on Delivery 

Expected at 10:00 a.m. EDT

Wednesday, May 8, 2013

GAO-13-574T 

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-574T, a testimony 

before the Committee on Homeland Security 

and Governmental Affairs, U.S. Senate

May 8, 2013

SOCIAL SECURITY ADMINISTRATION

Preliminary Observations on the Death Master File

Why GAO Did This Study

As the steward of taxpayer dollars, the 

federal government is accountable for 

safeguarding against improper 

payments—those that should not have 

been made or that were made in an 

incorrect amount. One tool federal 

agencies can use to do this is the 

DMF, which is a file containing records 

of deceased individuals who are SSNholders. Through data matching, 

federal benefit-paying agencies can 

use the DMF to alert them of deceased 

benefit recipients. However, the SSA 

Office of Inspector General and others 

have identified inaccuracies in the 

DMF, including deceased individuals 

who were not listed in the file. Such 

inaccuracies could adversely affect its 

usefulness to federal agencies. 

This testimony addresses preliminary 

observations on (1) SSA’s process for 

handling death reports for inclusion in 

the DMF, and (2) federal agency 

access to the DMF. In addressing 

these objectives, we interviewed SSA 

officials regarding how the agency 

obtains death reports and maintains 

the DMF; reviewed applicable federal 

laws, SSA procedures, and reports; 

interviewed representatives of 

organizations that report deaths to 

SSA; and interviewed officials at other 

federal agencies that use the DMF.

What GAO Recommends

The work is ongoing and GAO has no 

recommendations at this time. GAO 

plans to issue its final report later in 

2013.

What GAO Found

The Social Security Administration’s (SSA) procedures for handling and verifying 

death reports may allow for erroneous death information in the Death Master File 

(DMF) because SSA does not verify certain death reports or record others. SSA 

officials said, in keeping with its mission, the agency is primarily focused on 

ensuring that it does not make benefit payments to deceased Social Security 

program beneficiaries. As a result, it only verifies death reports received for 

individuals who are current program beneficiaries, and even then, only for those 

reports received from sources it considers to be less accurate. For example, SSA 

officials consider death reports from states that have pre-verified decedents’ 

name and SSN to be highly accurate, so SSA does not verify that the subjects of 

these reports are actually deceased. It would, however, verify a report received 

from a source such as a post office. SSA verifies no death reports for individuals 

who are not beneficiaries, regardless of source. Because there are a number of 

death reports that SSA does not verify, the agency risks including incorrect death 

information in the DMF, such as including living individuals in the file or not 

including deceased individuals. Specifically, for death reports that are not 

verified, SSA would not know with certainty if the individuals are correctly 

reported as dead. SSA also does not record some deaths because incorrect or 

incomplete information included in death reports generally prevents SSA from 

matching decedents to SSA records. For example, if SSA is unable to match a 

death report to data in its records such as name and Social Security Number 

(SSN), it generally does not follow up to correct the non-match and does not 

record the death.

A number of federal agencies access the DMF for the purpose of matching it 

against data in their files, but the conditions of access depend on a variety of 

legal and other factors. Currently SSA shares a full version of the DMF with six 

federal agencies that it has determined meet legal requirements for accessing the 

file, which include being an agency that pays federal benefits. By law, SSA can

require reimbursement for the cost of sharing the data, however various factors 

affect what the agencies actually pay. The Department of Veterans Affairs and 

the Office of Personnel Management pay nothing to receive the file, whereas the 

Department of Defense annually pays more than $40,000. A number of other 

federal agencies—including several that administer programs that pay benefits—

purchase a partial version of the DMF that is publicly available through the 

Department of Commerce’s National Technical Information Service (NTIS). NTIS 

reimburses SSA for receipt of the file. The partial DMF does not include statereported data and, according to SSA officials, has about 10 percent fewer 

records than the full DMF (roughly 87 million, compared to 98 million). Thus, 

agencies accessing this version of the file, such as the Department of Labor’s 

Energy Employees Occupational Illness Compensation Program, may be missing 

deceased program participants. If agencies want access to the full DMF, they 

must formally request it. SSA makes determinations about their eligibility on a 

case-by-case basis. SSA officials said they were not aware of written standards 

or guidelines to follow in making these determinations. 

View GAO-13-574T. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov.
Page 1 GAO-13-574T 

441 G St. N.W.

Washington, DC 20548

Chairman Carper, Ranking Member Coburn, and Members of the 

Committee:

I am pleased to discuss the Social Security Administration’s (SSA) death 

information, which is currently maintained for approximately 98 million 

deceased individuals who are Social Security Number (SSN) holders.

Federal benefit-paying agencies generally can access the information in 

this file and match it against data in their files to alert them to deceased 

benefit recipients, and therefore help reduce improper benefit payments. 

As the steward of taxpayer dollars, the federal government must guard 

against improper payments. Yet for fiscal year 2012, the Office of 

Management and Budget reported federal agency improper payment 

estimates totaling almost $108 billion.1 Over the past decade, we have 

issued numerous reports and testimonies highlighting the dangers of 

improper payments, including adverse effects on program integrity or 

economic hardship for beneficiaries who have to repay overpayments.2

We have also illustrated efforts agencies can take to help reduce these 

payments. For example, data matching allows benefit-paying agencies to 

compare information from different sources to confirm initial or continuing 

eligibility of participants or identify improper payments that have been 

made. Agencies can use SSA’s death information to help ensure they are 

not paying benefits to deceased individuals. However, the SSA Inspector 

General and others have identified inaccuracies in this file, commonly 

 

1 Improper payment estimates reported by federal agencies are not intended to be an 

estimate of fraud in federal agencies’ programs and activities. An improper payment is any 

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

(including overpayments and underpayments) under statutory, contractual, administrative, 

or other legally applicable requirements. It includes any payment to an ineligible recipient, 

any payment for an ineligible good or service, any duplicate payment, payment for a good 

or service not received (except for such payments where authorized by law), and any 

payment that does not account for credit for applicable discounts. Office of Management 

and Budget guidance also instructs agencies to report as improper payments any 

payments for which insufficient or no documentation was found. 

2 For example, see GAO, Supplemental Security Income: SSA Has Taken Steps to 

Prevent and Detect Overpayments, but Additional Actions Could Be Taken to Improve 

Oversight, GAO-13-109 (Washington, D.C.: Dec. 14, 2012); Improper Payments: 

Remaining Challenges and Strategies for Governmentwide Reduction Efforts, 

GAO-12-573T (Washington, D.C.: Mar. 28, 2012); Disability Insurance: SSA Can Improve 

Efforts to Detect, Prevent, and Recover Overpayments, GAO-11-724 (Washington, D.C.: 

July 27, 2011); and Strategies to Manage Improper Payments: Learning from the Public 

and Private Sector Organizations, GAO-02-69G (Washington, D.C.: October 2001).

 
 

Page 2 GAO-13-574T 

referred to as the Death Master File (DMF), such as deceased individuals 

not listed in the DMF. Such inaccuracies could adversely affect the DMF’s 

usefulness in helping agencies combat improper payments.

In my remarks today I will describe our preliminary observations on (1) 

SSA’s process for handling death reports for inclusion in the DMF, and (2) 

federal agency access to the DMF. To address these objectives, we 

interviewed SSA officials regarding how SSA obtains death reports and 

maintains the DMF, and reviewed applicable federal laws and SSA 

procedures, as well as relevant reports and evaluations. We also 

interviewed representatives of organizations that provide death reports to 

SSA. We analyzed the DMF to identify specific types of errors. Finally, we 

interviewed officials at other federal agencies that use the DMF about 

how they obtain and use it. This work is being conducted in accordance 

with generally accepted government auditing standards.

SSA historically has compiled death information about SSN-holders in 

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

individuals and to establish benefits for survivors. When SSA receives a 

report of death—which could include name, date of birth, date of death, 

and SSN—it matches that information against corresponding information 

in its database of all SSN-holders, known as the Numerical Index File 

(Numident).

3 SSA then marks the appropriate Numident record with a 

death indicator. This death information was not publicly available until 

1980 when, in response to Freedom of Information Act requests, SSA 

began to extract Numident records that had a death indicator into a 

separate file it called the DMF.

According to SSA officials, SSA received about 7 million death reports in 

2012 from a variety of sources.

4 These sources include family members, 

funeral directors, post offices, financial institutions, other federal 

 

3 The Numident file contains identifying information associated with SSN holders and 

there is one record for each SSN-holder.

4 These reports pertained to approximately 2.5 million individuals in the Numident, 

according to SSA officials. 

Background 
 

Page 3 GAO-13-574T 

agencies,5 and state vital records agencies (states).6 To get death reports 

from the states, SSA has established formal agreements7 that set forth a 

payment structure for the states’ death reports and limit SSA’s ability to 

share this information. However, the Social Security Act requires SSA to 

share death information, including data reported by the states, with 

federal agencies to ensure proper payment of benefits to individuals.

8 The 

act also prohibits SSA from sharing state-reported death information for 

any other purposes. As a result, SSA maintains two versions of the DMF.

The “full DMF,” which contains all death records, is available to federal 

benefit-paying agencies.9 The “partial DMF,” which excludes statereported death information, is available publicly to any interested party. 

Following the Social Security Act, SSA removes the state-reported 

records from the full DMF and provides the partial DMF to the Department 

of Commerce’s National Technical Information Service (NTIS), which 

reimburses SSA for the cost of providing the file and sells it through a 

subscription service.10

Our work to date has identified ways in which SSA’s procedures for 

compiling and verifying death reports may affect the accuracy of death 

reports in the DMF. To guide how to handle death reports, SSA has 

determined accuracy levels for each of the sources based on its past 

experience. Of all the sources of death reports that SSA receives, SSA 

considers those submitted by states through Electronic Death 

Registration Systems (EDRS) to be the most accurate.11 As part of these 

systems, states generally verify the names and SSNs from death reports 

 

5 The Department of Veterans Affairs and Centers for Medicare & Medicaid Services 

provide death reports to SSA. 

6 For purposes of this testimony, we use the term states to include the vital records 

agencies in the 50 states, 5 territories, New York City, and the District of Columbia.

7 Social Security Act § 205(r)(1), codified at 42 U.S.C. § 405(r)(1). 

8 Social Security Act § 205(r)(3), codified at 42 U.S.C. § 405(r)(3).

9 As of March 2013, the full DMF contained 98 million records. 

10 NTIS distributes a range of federally-funded scientific and technical information.

11 These are systems used by states to automate the electronic registering and 

processing of death reports in order to improve their timeliness and accuracy. 

SSA’s Procedures May 

Allow for Erroneous 

Death Information in 

the DMF
 

Page 4 GAO-13-574T 

with SSA’s databases before submitting them. As of March 2013, 35

states submit their death reports using EDRS.

12 SSA considers reports 

from funeral directors and family members of decedents the next most 

accurate. Finally, SSA considers reports from the remaining sources to be 

less accurate. According to SSA officials, SSA does not collect data on 

the number of death reports submitted by each source. However, officials 

told us that if SSA receives multiple death reports for the same individual, 

the Numident record is updated to reflect only the source SSA considers 

to be the most accurate. For example, if SSA first receives a death report 

from a family member and subsequently receives an electronic report 

from a state about the same individual, the original report is overridden 

and SSA records only the state as the source of the death report.

Whether SSA verifies death reports depends upon (1) whether the 

decedent is receiving Social Security benefits, and (2) the source of the 

report. Verification includes confirming the date of death and decedent’s 

SSN to ensure that the person identified in the death report is the person 

who has died. According to SSA officials, the agency only verifies death 

reports for individuals currently receiving Social Security program benefits 

because it is essential to its mission to stop payments to deceased 

beneficiaries. Even then, SSA verifies only those reports from sources it 

considers to be less accurate, such as financial institutions and other 

federal agencies. Therefore, death reports for non-beneficiaries are not 

verified (see table 1).13 SSA officials said they do not maintain data on the 

number of death reports they verify annually or how long such 

verifications take.

 

12 This includes 33 states, the District of Columbia, and New York City. Two additional 

states use EDRS but do not verify names and SSNs with SSA’s databases before 

submitting death reports. 

13 According to agency officials, SSA would not be able to verify non-beneficiary deaths 

because it does not maintain contact information for non-beneficiaries.
 

Page 5 GAO-13-574T 

Table 1: Types of Death Reports and Whether SSA Verifies Them

Source of Death Report

SSA verification of death

Beneficiary Non-Beneficiary 

State (EDRS) No No

Funeral directors No No

Family members No No

Post offices Yes No

Financial institutions Yes No

Centers for Medicare & Medicaid Services Yes No

Department of Veterans Affairs Yes No

State (non-EDRS) Yes No

Source: GAO analysis.

The following scenarios illustrate SSA’s approach to verification:

• SSA receives a death report from a funeral director and determines 

the decedent is currently receiving Social Security benefits. Because 

the report was received from a source considered highly accurate, 

SSA takes no further steps to verify the death. The death is recorded 

in the decedent’s Numident record and subsequently the DMF.

• SSA receives a death report from a post office based on a returned 

Social Security benefit check noting the addressee is deceased.

Because the decedent is a current SSA beneficiary and the report 

came from a source considered less accurate, it is turned over to an 

SSA field office to verify. Field office staff attempt to contact either the 

family of the decedent or some other source that is likely to have firsthand knowledge of the death to confirm the decedent’s identity and 

date of death. Once this is completed, the death is recorded in the 

decedent’s Numident record and the DMF.

• Veterans Affairs submits a death report to SSA. SSA determines the 

decedent is not receiving Social Security benefits. SSA does not verify 

the death before recording it in the Numident record and subsequently 

the DMF.

Because there are a number of death reports that SSA does not verify, 

the agency risks having erroneous death information in the DMF, such as 

including living individuals in the file or not including deceased individuals. 

Specifically, for death reports that are not verified, SSA would not know 

with certainty if the individuals reported as dead are, in fact, the ones who 
 

Page 6 GAO-13-574T 

are dead. SSA acknowledges these limitations and does not guarantee 

the accuracy of the file.

Other SSA practices may prevent deaths from being included in the DMF 

or lead to other errors. For example, if SSA cannot match a death report 

to a corresponding Numident record because of differences in name, date 

of birth, or gender, it generally will not take actions to resolve the nonmatch.14 As a result, these deaths would not be included in the DMF. In 

addition, analysis we performed on existing DMF records identified 

potentially erroneous information. Specifically, we identified:15

• 130 records where the date of death was recorded to occur before the 

date of birth;

• 1,295 records where the recorded age at death was between 111 and 

129; and

• 1,791 records where the recorded death preceded 1936, the year 

SSNs were first issued, although the decedents had SSNs assigned 

to them.

SSA officials said some of these anomalies were likely associated with 

records added prior to the mid-1970s that were manually processed. For 

example, SSA staff could have keyed in a date of birth that occurred after 

a date of death. In addition, they told us SSA is taking steps toward 

identifying or preventing these types of potential errors. These include 

implementing an edit check to catch records showing a date of birth after 

date of death, and undertaking a review of cases in which persons appear 

to be unreasonably old and still receiving benefits to determine if they are 

dead or if their birth date was entered incorrectly.

Finally, there are other situations in which deaths would not be included in 

the DMF. For example, decedents who were never assigned an SSN 

cannot be matched to the Numident.16 In addition, some deaths may not 

be reported to SSA, because, for example, identity cannot be established 

 

14 According to SSA officials, if SSA receives a death report that does not match a 

Numident record, SSA will take some internal steps to identify the decedent. 

15 The number of errors we identified is based on approximately 98 million DMF records, 

which were available for our analysis as of March 2013. The number of errors may change 

in future analysis.

16 These could include very young infants who had not been assigned an SSN, and older 

women who never worked outside the home and, therefore, did not obtain their own SSN.
 

Page 7 GAO-13-574T 

or a body is never found. However, it was beyond the scope of our review 

to determine the extent to which such gaps occurred.

A number of federal agencies access the DMF, but the conditions of 

access vary widely due to legal and administrative factors. Federal 

agencies’ access to the full DMF depends on various legal requirements, 

including (1) whether they pay federal benefits and (2) whether their 

proposed use of the DMF is consistent with uses outlined in the Social 

Security Act. Currently, SSA shares the full DMF with six federal benefitpaying agencies which have requested access and which it has 

determined meet the relevant legal requirements:17

• Centers for Medicare & Medicaid Services18

• Department of Defense (Defense Manpower Data Center)

• Department of Veterans Affairs

• Internal Revenue Service

• Office of Personnel Management 

• Railroad Retirement Board

To address administrative conditions of access, these agencies have 

established information exchange agreements to receive the full DMF. As 

a part of these agreements, SSA and the agencies agree on what the 

agency will pay for receiving the data, among other things. SSA has 

statutory authority to require reimbursement to cover the reasonable cost 

of sharing the data,19 and the amount varies by agency. According to SSA 

officials, although the cost is generally related to the volume of data SSA 

provides, other factors may affect what agencies pay. For example, the 

Department of Veterans Affairs does not reimburse SSA for the DMF 

because it is statutorily exempted from doing so.20 The Office of 

Personnel Management similarly does not reimburse SSA because it 

 

17 GAO, while not a benefit-paying agency, also receives the full DMF from SSA.

18 Centers for Medicare & Medicaid Services administers the Medicare Fee-For-Service 

program, which reported the highest improper payment estimates of all federal programs 

for fiscal year 2012. 

19 See 42 U.S.C. § 405(r)(3)(A).

20 38 U.S.C. § 5106.Under this section, the cost of providing information to the Secretary 

of Veterans Affairs for the purposes of determining eligibility for or amount of veterans 

benefits shall be borne by the agency providing the information.

Agencies’ Access to 

the DMF Depends on 

a Variety of Factors
 

Page 8 GAO-13-574T 

provides other data to SSA, and the agencies have agreed that the 

expenses involved in the exchanges are reciprocal. In contrast, the 

Defense Manpower Data Center pays over $40,000 annually for monthly 

updates, while CMS officials told us it pays about $10,000 per year for 

weekly updates.

A number of other federal agencies purchase only the partial DMF that is 

publicly available from NTIS. Several of these pay federal benefits, 

including the Department of Labor’s Energy Employees Occupational 

Illness Compensation Program, which provides compensation and health 

benefits to eligible Department of Energy workers and certain survivors. 

In addition, the Department of Agriculture’s Farm Service Agency 

administers several programs that pay benefits to farmers. Other 

agencies include, for example, the Department of Homeland Security, the 

Department of Justice, and the Department of the Treasury office that 

administers the Do Not Pay Initiative.21 According to SSA officials, the 

partial DMF has about 10 percent fewer records than the full DMF due to 

the removal of state-reported deaths. As more states submit records via 

EDRS, SSA officials expect this difference to grow over time.22 As a

result, any benefit-paying agency relying on the partial DMF to help 

identify deceased program participants may be missing death records for 

some of its beneficiaries because it has access to only about 87 million of 

the 98 million records in the full DMF. 

Although SSA officials make the determination about which agencies are 

eligible to receive the full DMF, they told us agencies must first formally 

request it. In response to agencies’ requests, SSA makes determinations 

about agencies’ statutory eligibility on a case-by-case basis. However, 

SSA officials said they were not aware of written standards or guidelines 

to follow in determining which federal agencies meet statutory 

requirements. SSA officials said that Offices of Inspectors General at 

benefit-paying agencies would likely be eligible to receive the full DMF for 

the purpose of ensuring proper payments of benefits. In contrast, SSA 

 

21 The Improper Payments Elimination and Recovery Improvement Act of 2012 

established the Do Not Pay Initiative and set forth a requirement for federal agencies to 

review a number of databases, as appropriate, including the DMF, for individuals’ eligibility 

information prior to making payments with federal funds. Pub. L. No. 112-248, § 5, 126 

Stat. 2390, 2392 (2013). 

22 Officials noted that in 2012 alone, SSA removed about 40 percent of records for death 

reports received in that year because the deaths were state-reported.
 

Page 9 GAO-13-574T 

officials said that the agency has determined that the Department of the 

Treasury would not be eligible to receive the full DMF for the purposes of 

administering the Do Not Pay Initiative. Even though this initiative is 

designed to help agencies prevent improper payments, SSA officials 

explained that under the Do Not Pay Initiative, Treasury would share state 

death information with agencies that do not pay benefits, which would put 

SSA in violation of the Social Security Act and its agreements with the 

states.

In summary, SSA’s death information can serve as a helpful tool in 

preventing improper payments, but can only do so if it is accurate and

accessible to federal agencies that need it. As we continue our work, we 

will explore these and other issues in more detail and look forward to 

providing a final product later in 2013.

Chairman Carper, Ranking Member Coburn, and Members of the 

Committee, this completes my prepared statement. I would be pleased to 

respond to any questions that you may have at this time.

For further information about this testimony, please contact me at (202) 

512-7215 or bertonid@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this testimony. Other key contributors to the testimony include Keira 

Dembowski, Holly Dye, Joel Marus, Sara Pelton and Lori Rectanus.

Contacts and Staff 

Acknowledgments 

(131256)
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