SOCIAL SECURITY 

DEATH DATA

Additional Action 

Needed to Address 

Data Errors and 

Federal Agency 

Access

Report to Congressional Requesters

November 2013

GAO-14-46

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-46, a report to 

congressional requesters

November 2013

SOCIAL SECURITY DEATH DATA

Additional Action Needed to Address Data Errors 

and Federal Agency Access

Why GAO Did This Study

As the steward of taxpayer dollars, the 

federal government must guard against 

improper payments. Federal agencies 

may avoid paying deceased 

beneficiaries by matching their 

payment data with death data SSA 

maintains and shares. In addition, 

recent legislation has established 

additional requirements for federal 

agencies to use death data to prevent 

improper payments. However, the SSA 

Office of Inspector General has

identified inaccuracies in SSA’s death 

data, which could diminish its 

usefulness to federal agencies. 

GAO was asked to examine SSA’s 

death data. This report explores (1) 

how SSA obtains death reports and 

steps it takes to ensure death reports 

are accurate; and (2) factors affecting 

federal agency access to SSA’s death 

data. In addressing these objectives, 

GAO interviewed SSA officials and 

representatives of entities reporting or 

using the death data. GAO reviewed 

applicable federal laws, SSA 

procedures, and reports. GAO also

performed independent testing of 

SSA’s death data for certain errors.

What GAO Recommends

GAO recommends that SSA assess 

risks associated with inaccuracies;

develop and publicize guidance it will 

use to determine agency access under 

the Act; and share detailed 

reimbursement estimates. SSA 

partially agreed with the 

recommendations to assess risks and 

share detailed reimbursement

estimates, but did not agree to develop 

and publicize guidance, stating that 

each request is unique. GAO believes 

that the recommendation remains valid

as discussed in the report.

What GAO Found

The Social Security Administration (SSA) receives death reports from multiple 

sources, including state vital records agencies (states), family members, and 

other federal agencies to create its set of death records. In accordance with the 

Social Security Act (Act), SSA shares its full set of death data with certain 

agencies that pay federally-funded benefits, for the purpose of ensuring the 

accuracy of those payments. For other users of SSA’s death data, SSA extracts 

a subset of records into a file called the Death Master File (DMF), which, to 

comply with the Act, excludes state-reported death data. SSA makes the DMF 

available via the Department of Commerce’s National Technical Information 

Service, from which any member of the public can purchase DMF data. Certain 

procedures that SSA uses for collecting, verifying, and maintaining death reports 

could result in erroneous or untimely death information. For example, SSA does 

not independently verify all reports before including them in its death records. In 

accordance with its policy, the agency only verifies death reports for Social 

Security beneficiaries in order to stop benefit payments, and then, verifies only 

those reports from sources it considers less accurate, such as other federal 

agencies. GAO identified instances where this approach led to inaccurate data. 

For example, GAO’s analysis of a sample of death records SSA erroneously 

included in its death data found that these errors may not have occurred if SSA 

had verified them. In other cases, when data provided do not match SSA’s 

records, SSA typically does not record these deaths. According to federal internal 

control standards, agencies should conduct risk assessments of factors impeding 

their ability to achieve program objectives, such as data errors that could result in 

improper benefit payments. Agency officials told us SSA has not performed such 

risk assessments, but has initiated work on a full redesign of its death processing 

system. 

SSA lacks written guidelines other than the language in the Act for determining 

whether agencies are eligible under the Act to access the full death file, and it 

does not share with agencies how it determines the reasonable cost of sharing 

the data, which recipients of the full file are required to reimburse SSA. Because

SSA has not developed or shared guidance on how it determines agency 

eligibility, this could create confusion among potential recipients regarding 

eligibility. Ensuring appropriate access is important because the DMF contains 

about 10 percent fewer records than the full death file, and officials expect that 

difference to increase over time. Additionally, there is a lack of transparency of 

cost information about the amounts recipients expect to pay. As a result of not 

knowing the factors that lead to the reimbursement amounts, agencies may not 

have sufficient information to make informed decisions. We found that SSA

provided differing estimates for agencies’ reimbursement amounts. Some 

variation is due to legal requirements and a quid pro quo arrangement. For 

example, one agency does not reimburse SSA for the cost of providing the death 

data because it provides SSA with its own data, and the agencies have agreed 

that the expenses involved in the exchanges are reciprocal. However, for some 

agencies this variation could not fully be explained by the frequency with which 

they expected to receive the data. For example, two agencies expected to pay 

similar reimbursement amounts in 2013 despite expecting to receive the file at 

different frequencies.

View GAO-14-46. For more information, 

contact Dan Bertoni at (202) 512-7215 or 

bertonid@gao.gov
Page i GAO-14-46 Social Security Death Data

Letter 1

Background 2

SSA Receives Death Reports from a Number of Sources, but Its 

Procedures for Handling Them Allow for Erroneous, 

Incomplete, and Delayed Death Information 6

Access to Death Data Varies and SSA Lacks Transparency in 

Communicating How it Determines Agency Eligibility and 

Reimbursement Costs 19

Conclusions 25

Recommendations for Executive Action 26

Agency Comments and our Evaluation 26

Appendix I Objectives, Scope, and Methodology 31

Appendix II Comments from the Social Security Administration 35

Appendix III GAO Contact and Staff Acknowledgments 42

Related GAO Products 43

Table

Table 1: Projected Reimbursement Amounts for Federal Agencies 

Receiving SSA’s Full Death Data 23

Figures

Figure 1: Social Security Administration (SSA) Processing of Death 

Reports 9

Figure 2: Social Security Administration (SSA) Death Report 

Verification Procedures 11

Figure 3: Distribution of Social Security Administration (SSA) 

Death Information 13

Contents
Page ii GAO-14-46 Social Security Death Data

Abbreviations

CMS Centers for Medicare & Medicaid Services

DACUS Death Alert Control and Update System

DMDC Defense Manpower Data Center

DMF Death Master File

EDRS Electronic Death Registration System

IRS Internal Revenue Service

NTIS National Technical Information Service

Numident Numerical Index File

OIG Office of Inspector General

OMB Office of Management and Budget

OPM Office of Personnel Management

PBGC Pension Benefit Guaranty Corporation

RRB Railroad Retirement Board

SSA Social Security Administration

SSN Social Security Number

USDA U.S. Department of Agriculture

VA Department of Veterans Affairs

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-14-46 Social Security Death Data

441 G St. N.W.

Washington, DC 20548

November 27, 2013

Congressional Requesters

The Social Security Administration (SSA) maintains death data—including 

names, Social Security Numbers (SSN), dates of birth, and dates of 

death—for approximately 98 million deceased SSN-holders. Federal 

benefit-paying agencies generally can access this information and match 

it against data in their files to alert them to deceased benefit recipients, 

and therefore help identify and prevent improper 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 (OMB) reported federal agency improper payment estimates 

totaling almost $108 billion.1 For example, the Office of Personnel 

Management (OPM) improperly paid over $500,000 in retirement benefits 

to a deceased beneficiary’s son over the course of 37 years, believing the 

beneficiary was still alive and receiving the payments himself.2 Despite 

the potential usefulness of SSA’s death information, the SSA Office of 

Inspector General (OIG) and others have identified inaccuracies in the 

data. For example, in 2012 SSA’s OIG reported that 1.2 million deceased 

Social Security beneficiaries were not included in SSA’s death data.3

 1 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, any 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. Improper payment estimates reported by federal agencies are not 

intended to be an estimate of fraud in federal agencies’ programs and activities. See 

section 2(g) of the Improper Payments Information Act of 2002, as amended, codified at 

31 U.S.C. § 3321 note. Office of Management and Budget guidance also instructs 

agencies to report as improper payments any payments for which insufficient or no 

documentation was found.

Such inaccuracies could adversely affect the usefulness of SSA’s death 

information in helping agencies combat improper payments.

2 Office of Personnel Management, Office of the Inspector General, Stopping Improper 

Payments to Deceased Annuitants (Washington, D.C.: Sept. 14, 2011).

3 Social Security Administration, Office of Inspector General, Title II Deceased 

Beneficiaries Who Do Not Have Death Information on the Numident, A-09-11-21171 

(Baltimore, MD: July 2012). The OIG found that Social Security benefit payments to a 

sample of these deceased individuals had been terminated. 
Page 2 GAO-14-46 Social Security Death Data

You asked us to review issues related to SSA’s death information, 

including its accuracy and usefulness to federal agencies. This report 

examines (1) how SSA obtains death reports for inclusion in the death 

data it maintains and steps it takes to ensure these reports are accurate; 

and (2) the factors affecting federal agency access to SSA’s death data. 

To address these objectives, we reviewed applicable federal laws and 

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

interviewed SSA officials about how SSA obtains and processes death 

reports and maintains its death information. We also interviewed 

representatives of entities that provide death reports to SSA. We 

assessed SSA’s processes for obtaining, processing, and sharing death 

information against standard criteria, such as Standards for Internal 

Control in the Federal Government.4 We performed independent testing 

of SSA’s death data to identify specific types of errors, such as dates of 

birth that followed dates of death. We also reviewed a randomly selected 

but non-generalizable sample of 46 cases that SSA had removed from 

the death information to identify potential explanations for that action. 

Finally, we interviewed officials at other federal agencies that use SSA’s 

death information about how they access it. Appendix I describes our 

scope and methodology in more detail. We conducted this performance 

audit from November 2012 through November 2013 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.

SSA’s primary mission is to pay benefits under its Old-Age, Survivors, 

and Disability Insurance and Supplemental Security Income programs, in 

accordance with Titles II and XVI of the Social Security Act of 1935 (the 

 4 GAO, Government Operations: Standards for Internal Control in the Federal 

Government, AIMD-00-21.3.1 (Washington, D.C.: Nov. 1, 1999). These standards, issued 

pursuant to the requirements of the Federal Managers’ Financial Integrity Act of 1982, 

Pub. L. No. 97-255, 96 Stat. 814, provide the overall framework for establishing and 

maintaining internal control in the federal government, and for identifying and addressing 

major performance and management challenges and areas at greatest risk of fraud, 

waste, abuse, and mismanagement.

Background
Page 3 GAO-14-46 Social Security Death Data

Act), as amended.5

SSA issues SSNs and uses them to administer its programs, including 

tracking U.S. workers’ earnings in order to determine the types and 

amounts of benefits individuals may be eligible for.

In addition, SSA issues the Social Security Number 

(SSN)—a unique identifier assigned to each person through a process 

known as “enumeration”—as a way of tracking individuals’ work activities 

and the benefits paid to retired workers and eligible family members. In 

order to properly administer payments, SSA also tracks death information 

of SSN-holders.

6 As a result, SSA has 

also historically collected death information about SSN-holders so it does 

not pay Social Security benefits to deceased individuals and to establish 

benefits for survivors. The 57 vital records jurisdictions—the 50 states, 

New York City, the District of Columbia, and five territories—are 

responsible for registering deaths. 7 Fifty-three of these jurisdictions, 

along with a number of other parties, provide SSA with decedents’ 

names, dates of death, dates of birth, and SSNs. SSA receives state 

death data under contracts with the 50 states, New York City, the District 

of Columbia, and Puerto Rico.

8

 5 Unless otherwise specified, in this report we refer to these benefits collectively as “Social 

Security benefits.”

When SSA receives a report of death it 

matches that information against corresponding information in its 

databases, verifies the information for certain cases, and records the 

individual as deceased.

6 The Bureau of Internal Revenue, in the U.S. Department of the Treasury, began issuing 

account numbers to each employee covered under the Act in 1936. T.D. 4704, 1 Fed. 

Reg. 1741 (Nov. 7, 1936). As currently amended, the Act requires SSA to establish and 

maintain wage and income records, and comply with certain requirements for the issuance 

and use of SSNs. 42 U.S.C.§ 405(c).

7 Vital records are permanent legal records of life events and include live births, deaths, 

fetal deaths, marriages, and divorces. The five U.S. territories are American Samoa, the 

Commonwealth of Puerto Rico, Guam, the Northern Mariana Islands, and U.S. Virgin 

Islands. 

8 Section 205(r) of the Social Security Act requires SSA to establish a program under 

which states voluntarily contract with SSA to periodically provide it with death information, 

and further requires that this information be used to compare with, validate, and correct 

the records used to administer Social Security programs. Each state may be paid the 

reasonable costs for providing death information to SSA. See 42 U.S.C. § 405(r)(1)-(2).

We define “state” consistent with the definition in the Social Security Act, which includes 

the District of Columbia and the Commonwealth of Puerto Rico. 42 U.S.C. § 1301(a). 
Page 4 GAO-14-46 Social Security Death Data

Various entities, including federal agencies, can obtain SSA’s death data. 

The complete file, which we refer to as “SSA’s full death file,”9 is available 

to certain eligible entities. A subset of the full death file, which SSA calls 

“the Death Master File (DMF),” is available to the public. The Social 

Security Act requires that SSA share its full death file, to the extent 

feasible, with agencies that provide federally funded benefits (for the 

purposes of this report, we refer to these as “benefit-paying agencies”), 

provided the arrangement meets statutory requirements.10 However, SSA 

may not include death data received from states in the DMF, which can 

be accessed publicly.11 Agencies may use the data to determine if 

individuals receiving benefits under their respective programs are 

deceased, and thus no longer entitled to those benefits. GAO has noted 

the value of using this information for guarding against improper 

payments. For example, in a June 2013 report, we recommended that the 

U.S. Department of Agriculture (USDA) match its payment records 

against SSA’s full death file to prevent improper payments to deceased 

farmers.12

Given the focus on guarding against improper payments, there has been 

new emphasis on how agencies access critical data, such as death 

 9 Use of the term “full” is not meant to indicate a file that contains all deaths, but a file that 

includes the deaths reported by states. SSA does not guarantee the completeness or 

accuracy of its death data, stating that SSA does not have a death record for all deceased 

individuals. 

10 42 U.S.C. § 405(r)(3). Under the Act, SSA is required to provide the data under a 

cooperative arrangement with benefit-paying agencies for the purpose of ensuring proper 

payment of those benefits, provided that the recipient agency reimburses SSA for its 

reasonable costs, and the arrangement does not conflict with SSA’s duties with respect to 

the state death information. Benefit-paying agencies may be state agencies, and the Act 

also authorizes SSA to use or provide for the use of records from its full death file for 

certain other purposes, such as statistical and research activities conducted by federal 

and state agencies, 42 U.S.C. § 405(r)(5). However, in this report we discuss only federal 

agencies’ use of the data to prevent improper payments.

11 The Social Security Act prohibits SSA from using death information it obtains from the 

states for purposes other than those described in section 205(r) of the Act, and exempts 

that information from disclosure under the Freedom of Information Act and the 

requirements of the Privacy Act. 42 U.S.C. § 405(r)(6).

12 GAO, Farm Programs: USDA Needs to Do More to Prevent Improper Payments to 

Deceased Individuals, GAO-13-503 (Washington, D.C.: June 28, 2013). USDA generally 

agreed with our report’s findings and recommendations and, as of May 2013, had begun 

implementing formal, systematic procedures to prevent subsidies on behalf of deceased 

individuals consistent with our recommendation.
Page 5 GAO-14-46 Social Security Death Data

records, while maintaining the security of sensitive information such as 

SSNs. The Improper Payments Elimination and Recovery Improvement 

Act of 2012 established the Do Not Pay Initiative and requires federal 

agencies to review a number of databases, as appropriate, including the 

DMF, to verify eligibility prior to making payments with federal funds.13 A 

component within the U.S. Department of Treasury (Treasury) 

administers the Do Not Pay Business Center, which operates the 

centralized portal through which agencies can verify individuals’ eligibility 

to receive payments. Recent legislative proposals have also sought to 

encourage federal agencies to use SSA’s death information. For 

example, a Senate bill introduced in July 2013 would provide for federal 

agency access to the full death file for specified purposes, such as 

ensuring authorized payments and facilitating other agency functions, 

including public health or safety, law enforcement, tax administration, 

health administration oversight, and debt collection, as determined 

appropriate by the SSA Commissioner.14 At the same time, other 

proposals have sought to limit public access to SSA’s death data. For 

example, proposed legislation introduced in the House in July 2013 seeks 

to deter identity theft and tax fraud by limiting public access to the DMF, 

according to the bill’s sponsor.15 The current administration has also 

advanced a proposal that includes critical elements of both legislative 

proposals, and SSA officials have publicly supported their central 

provisions.

 13 Pub. L. No. 112-248, § 5, 126 Stat. 2390, 2392 (2013). Prior to the enactment of this 

law, a 2010 presidential memorandum had directed agencies to follow similar procedures 

to prevent improper payments. Enhancing Payment Accuracy Through a “Do Not Pay 

List,” 75 Fed. Reg. 35,953 (June 23, 2010). OMB and the Department of the Treasury 

were the lead agencies in implementing the directive. See Reducing Improper Payments 

Through the “Do Not Pay List,” OMB Memorandum M-12-11 (Apr. 12, 2012).

14 Improper Payments Agency Cooperation Enhancement Act of 2013, S. 1360, 113th 

Cong. § 2 (2013).

15 Alexis Agin Identify Theft Protection Act of 2013, H.R. 2720. 113th Cong. (2013). See 

159 Cong. Rec. H4607 (daily ed. July 18, 2013) (statement of Rep. Johnson).
Page 6 GAO-14-46 Social Security Death Data

SSA receives death reports from a variety of sources, including states, 

family members, funeral directors, post offices, financial institutions, and 

other federal agencies.16 According to agency officials, SSA received 

about 7 million death reports in 2012.17 However, except for reports 

submitted by states, it does not collect data identifying how many reports 

come from each source.18

Because of states’ custodial role in collecting and maintaining death 

records, SSA considers states to be a critical partner in its collection of 

death information. Thirty-four states, the District of Columbia, and New 

York City submit their death reports through an Electronic Death 

Registration System (EDRS), which automates the electronic registering 

and processing of death reports in order to improve timeliness and 

accuracy. SSA considers reports submitted by states through EDRS to be 

the most accurate because these systems are used by most states to

Officials also said nearly all death reports are 

received within 30 days of the date of death.

 16 The Department of Veterans Affairs (VA) and Centers for Medicare & Medicaid 

Services (CMS) provide death reports to SSA. SSA officials we met with stated that they 

were not aware of any formal agreements that outlined these arrangements.

17 These reports pertained to approximately 2.5 million individuals in the Numerical Index 

File (Numident), an agency database of all SSN-holders, according to SSA officials. 

18 SSA officials explained that death reports from states are tracked and noted in 

decedents’ Numident records in order to ensure these records are not included in the 

DMF.

SSA Receives Death 

Reports from a 

Number of Sources, 

but Its Procedures for 

Handling Them Allow 

for Erroneous, 

Incomplete, and 

Delayed Death 

Information

SSA Receives Death 

Reports From Multiple 

Sources to Create Its Set of 

Death Records
Page 7 GAO-14-46 Social Security Death Data

verify the name and SSN of the decedent with SSA databases before the 

report is submitted to SSA. To get death reports from the states, SSA has 

established contracts that set forth a payment structure to compensate 

states for the reasonable costs of providing these records, in accordance 

with the Social Security Act.19

Some states and other sources provide death information voluntarily to 

SSA through methods other than EDRS. For example, funeral directors 

routinely submit a form that includes the decedent’s full name and SSN, 

as provided by the decedent’s family. In addition, family members often 

contact SSA field offices directly to report a death. SSA considers reports 

from families and funeral directors generally to be accurate because 

those sources have first-hand knowledge of the death and the decedent’s 

identity. SSA views death reports from post offices, financial institutions, 

and other government agencies generally to be less accurate because 

SSA does not consider these sources to have first-hand knowledge of the 

death.

Payments are higher for reports submitted

via EDRS and pre-verified with SSA databases, and those that are 

submitted relatively soon after decedents’ deaths. For example, for 

calendar year 2013, SSA paid $2.93 for each EDRS report that was preverified and submitted to SSA within 6 days of the date of death, 

compared to $0.82 for non-EDRS reports submitted within 120 days of 

the date of death. Because of the time saved through automated 

transmission of data and the use of pre-verification to ensure accuracy, 

SSA has encouraged the expanded use of EDRS. The contracts with the 

states provide that SSA will not share this information, except as 

authorized by federal law and section 205(r) of the Act.

20

Generally, death reports SSA receives—including name, SSN, date of 

birth, and date of death—are processed through its Death Alert Control 

and Update System (DACUS) (see fig. 1).21

 19 42 U.S.C. § 405(r)(1)-(2).

Among other purposes, 

DACUS is intended to ensure that death information is correctly recorded 

20 According to officials and SSA’s operating procedures, post offices and financial 

institutions typically become aware of a death when a benefit payment is returned. CMS 

and VA report deaths of their program beneficiaries to SSA through electronic data 

transfers.

21 Death reports from sources other than states and federal agencies are generally 

provided to SSA field offices.
Page 8 GAO-14-46 Social Security Death Data

in other SSA records so payments to deceased beneficiaries can be 

stopped. As shown in figure 1, death reports from some sources are sent 

to DACUS directly, while reports from other sources are entered into 

DACUS by field office staff.
Page 9 GAO-14-46 Social Security Death Data

Figure 1: Social Security Administration (SSA) Processing of Death Reports

Note: In addition to use by federal benefit-paying agencies, the full death file may be available for 

certain additional purposes under 42 U.S.C. § 405(r); however, those purposes were beyond the 

scope of this report.

a

See figure 2 for a description of reports that are not verified and those that are verified by SSA.
Page 10 GAO-14-46 Social Security Death Data

DACUS matches the information in the death reports with SSA’s benefit 

payment systems to determine if the decedents are currently receiving 

Social Security program benefits (i.e. whether they are program 

beneficiaries).22 It then matches the information to SSA’s database of all 

SSN-holders, known as the Numerical Index File (Numident).23

Information in death reports from certain sources (see fig. 2) is also 

verified by field office staff. If the name, date of birth, gender and SSN all 

match a record on the Numident, SSA marks that record with a death 

indicator. The Numident is updated with death information on a daily 

basis. Numident records with new death indicators are then extracted for 

inclusion in the death data file also on a daily basis. SSA does not track 

how long it takes from the time it receives a death report until the death is 

recorded in the Numident.

SSA does not independently verify all death reports it receives. In 

accordance with policy, the agency only verifies death reports for Social 

Security beneficiaries, and then verifies only those reports from sources it 

considers less accurate. For example, SSA only verifies death reports for 

persons currently receiving Social Security retirement or disability benefits 

because, according to agency officials, it is essential to SSA’s core 

mission to stop payments to deceased Social Security beneficiaries. As a 

result, death reports for non-beneficiaries are not verified. Officials told us 

it would be difficult to verify death reports for individuals who do not 

receive Social Security benefits because SSA would not likely have 

current contact information for these individuals or their family members.

As shown in figure 2, SSA verifies death reports of Social Security 

beneficiaries received from other federal agencies; third parties that learn 

about the death, such as post offices and financial institutions; and states 

that do not submit reports via EDRS. SSA considers these sources to be 

less accurate because they do not have first-hand knowledge of the death 

and, unlike states using EDRS, do not perform any verification before 

submitting the death report to SSA. To verify reports, SSA field office staff 

typically contact families or other parties with first-hand knowledge of the 

 22 The payment systems are for the Old Age, Survivors, and Disability Insurance program 

and the Supplemental Security Income program.

23 The Numident file contains identifying information associated with SSN-holders and 

there is one record for each SSN-holder.

SSA Verifies Only Certain 

Death Reports Before 

Including Them in Its 

Death Records, and Does 

Not Include Others
Page 11 GAO-14-46 Social Security Death Data

death to confirm the fact and date of death and confirm the decedent’s 

SSN.

Figure 2: Social Security Administration (SSA) Death Report Verification Procedures

SSA does not verify death reports submitted by families, funeral directors, 

or states using EDRS. According to SSA officials, families and funeral 

directors have first-hand knowledge of decedents’ identities and deaths, 

and the information in death reports submitted through EDRS is typically 

already verified with SSA databases. They also noted, for example, that 

SSA would very quickly find out about an erroneous report because, if 

that beneficiary were still alive, he or she would quickly contact SSA once 

benefit payments stopped.
Page 12 GAO-14-46 Social Security Death Data

SSA does not track the proportion of death reports it verifies or how long 

verifications take. Moreover, according to agency officials, SSA has never 

performed an analysis validating the accuracy of the various sources of 

death reports, but instead has based its decisions about which ones to 

verify on general experience over time. For example, officials told us that 

for death reports submitted by family members, general experience over 

many years has shown that a large portion of these reports are accurate.

Some death reports, including those that SSA cannot match with a 

Numident record, are not included in SSA’s death data. Agency officials 

told us that staff conduct some follow-up steps to see if they can match 

the information in these reports with other agency records, but if these 

efforts are unsuccessful, the reports are not included.24 SSA also does 

not attempt to follow up with the source of these reports. According to 

agency officials, it is unlikely the sources would know any additional 

information beyond what they already provided. Moreover, a subsequent 

death report for the same individual may arrive from another source.25

After receiving death reports and updating the Numident with death 

information, SSA makes the information available, in the appropriate 

form, to federal agencies and other parties (see Fig. 3).

They also added that federal privacy laws may prevent SSA from 

providing identifying information on the decedent because the individual’s 

living status is unclear. SSA does not track these cases, so officials were 

unable to tell us how often this occurs. There are also some deaths that 

SSA cannot reasonably be expected to include in its death information. 

These include deaths not reported to SSA because the identity of the 

decedent cannot be established or a body has not been recovered. While 

improper benefit payments to these individuals may occur, it would not be 

appropriate to attribute them to lack of a record in SSA’s death data.

 24 SSA requires that the name, SSN, date of birth, and gender recorded on the death 

certificate match a corresponding record in the Numident before posting the death in the 

Numident record. The death will not be posted in the Numident if any one of those data 

elements does not match.

25 Although it may receive multiple death reports for the same individual, SSA only records 

the source it considers to be the most accurate as the source of the death report in 

decedents’ Numident records. For example, if SSA first receives a death report from a 

family member and subsequently receives a report from a state via EDRS for the same 

individual, the original report is overridden and SSA records only the state as the source of 

the death report because SSA considers the state EDRS record to be more accurate.
Page 13 GAO-14-46 Social Security Death Data

Figure 3: Distribution of Social Security Administration (SSA) Death Information

Note: In addition to use by federal benefit-paying agencies, the full death file may be available for 

certain additional purposes under 42 U.S.C. § 405(r); however, those purposes were beyond the 

scope of this report.

SSA provides the full death file, containing over 98 million records, 

directly to federal benefit-paying agencies that have an agreement with 

SSA for use in preventing improper payments to deceased beneficiaries 

or program participants. SSA also extracts Numident death records that 
Page 14 GAO-14-46 Social Security Death Data

are reported by non-state sources to create the DMF, which contains over 

87 million records. SSA makes the DMF available publicly via the 

Department of Commerce’s National Technical Information Service 

(NTIS), from which any interested party or member of the public—

including other federal agencies—can make a one-time purchase, 

subscribe for periodic updates, or subscribe to an on-line query service. 

For example, financial institutions or firms conducting background 

investigations can purchase the DMF from NTIS and subscribe to receive 

monthly or weekly updates. SSA does not guarantee the completeness or 

accuracy of its death data, stating that SSA does not have a death record 

for all deceased individuals. SSA also informs users of its death data that 

all deaths should be verified before any action, such as stopping benefits, 

is taken.

SSA’s methods for processing death reports may result in inaccurate, 

incomplete, or untimely information for users of its death data. 

Consequently, this could lead to improper payments if benefit-paying 

agencies rely on this data. The specific procedures include (1) verifying a 

limited portion of death reports, (2) not including death reports that do not 

match with the Numident file, and (3) not performing additional reviews of 

reports of deaths that occurred years or decades in the past.

Because SSA does not verify death reports from sources it considers 

most accurate, the agency risks having erroneous information in its death 

data, such as including living individuals or not including deceased 

individuals. Analysis we performed on records in the full death file that 

were erroneously included showed that most of these errors would not 

have occurred if SSA had verified the death reports when it received 

them. We identified nearly 8,200 deaths SSA deleted from its death data 

between February 2012 and January 2013. These data reflect cases 

where a death report matched a record in the Numident and SSA marked, 

then later removed, a death indicator for that record. SSA officials told us 

this could occur because the decedent turned out to be alive or was 

misidentified as another individual, or as a result of data entry errors. We 

drew a random but non-generalizable sample of 46 cases from this group 

and asked SSA to search its records to see if it could determine the 

reasons for deleting them from its death data. In 28 of these cases, SSA 

SSA’s Verification and 

Other Procedures Do Not 

Ensure Accurate, 

Complete, or Timely Death 

Data For Federal Users
Page 15 GAO-14-46 Social Security Death Data

was able to identify a reason for deletion.26 Of these, 12 were false death 

reports filed while the reported decedent was still alive, and 4 involved 

decedents for whom identifying information—such as SSNs—of other 

people was mistakenly included in the death reports. Separately, SSA 

was also able to determine that 13 of the 46 cases were reported by 

either family members or funeral directors—sources SSA considers more 

accurate and from which it does not verify death reports.27 Nine of the 46 

cases involved non-beneficiaries, which are also not verified.28

Another SSA practice—not contacting the source of a death report that 

does not match a Numident record—poses a risk to the data’s 

completeness. As described earlier, if SSA staff cannot match a death 

report to a corresponding Numident record, they do not contact the 

source that submitted the report or undertake any other outside 

investigation to resolve the discrepancy. SSA’s OIG has found that these 

omissions are substantial. In one case, data for about 182,000 deceased 

Supplemental Security Income recipients were not included in SSA’s 

death data. In another, it found that as many as 1.2 million deceased Old 

Age and Survivors Insurance beneficiaries were not included in the death 

data. The OIG determined that these gaps occurred because SSA could 

not match the identifying information for these individuals included in the 

death reports or other SSA records with Numident records. Therefore, no 

death indicator was added to the Numident records. Samples of the 

cases drawn for the OIG’s reviews showed that these individuals had 

been deceased for an average of nearly 17 years.29

 26 SSA researched 46 cases. In 18 of these, it was unable to determine from its records 

the reason for deleting the case from its death data.

As a result of this 

practice, other federal benefit-paying agencies relying on these data 

could make improper benefit payments.

27 In two of these cases, SSA was unable to determine the reason for deleting the cases 

from its death data.

28 In four of these cases, SSA was unable to determine the reason for deleting the cases 

from its death data.

29 Social Security Administration, Office of the Inspector General, Title XVI Deceased 

Recipients Who Do Not Have Death Information on the Numident, A-09-12-22132 

(Baltimore, MD: May 3, 2013); and Title II Deceased Beneficiaries Who Do Not Have 

Death Information on the Numident, A-09-11-21171 (Baltimore, MD: July 9, 2012). The 

OIG found that Social Security benefit payments to a sample of these deceased 

individuals had been terminated. 
Page 16 GAO-14-46 Social Security Death Data

Finally, we also identified cases in which death reports submitted to SSA 

in early 2013 listed dates of death that were more than a year old. 

Specifically, we found about 500 records in which the date of death 

recorded had occurred in 2011 or earlier; in about 200 of these, the date

of death was recorded to be 10 or more years before SSA received the 

death report. For example, in 11 of the cases, the date of death was in 

1976; in another 11, the date was 2004. This is of concern because, if 

these dates of death are accurate, SSA and other agencies may have 

been at risk of paying benefits to these individuals for long periods after 

they died.30 SSA officials were not able to explain with certainty why this 

was occurring, but suggested some cases might be the result of data 

entry errors, and in others, deaths of non-beneficiaries may not be 

reported to SSA until spouses or families become eligible for survivor’s 

benefits.31

We found other instances of potentially erroneous information in the 

death data that raise questions about its accuracy and usefulness. These 

included:

They informed us that SSA payment systems would identify 

benefit payments the agency made after these deaths occurred. When 

these reports are sent to field offices for verification or other development, 

they added, it could take an extended period of time to complete because 

the contact information for someone who died years ago may not be 

available.

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

birth;

 30 Late-reported deaths can cause other problems for federal agencies that use SSA’s 

death data. For example, under one Internal Revenue Service (IRS) program, overdue 

taxes are collected through levies on certain federal payments. These levies can be 

assessed against certain Social Security benefits, but if the beneficiary dies, IRS returns 

any levied payments made after the death. IRS officials told us that the majority of 

returned payments from October 2011 through June 2012 in which the original levy 

payment was more than nine months old were for Social Security payments made to 

deceased individuals. In some cases, the deaths were reported (and the levies returned) 

too late for IRS to pursue the delinquent taxes through the collections process. 

31 According to SSA officials, there is no requirement to file a death report of a nonbeneficiary with SSA; however, in order to receive survivor’s benefits, the death of the 

primary beneficiary must be recorded in his or her Numident record. Therefore, if a death 

report had not been filed while the decedent was not eligible for benefits, surviving 

spouses or family members will need to file one in order to be eligible for survivor’s 

benefits.
Page 17 GAO-14-46 Social Security Death Data

• 1,941 records where the recorded age at death was between 115 and 

195; and

• 1,826 records where the recorded death preceded 1936, the year 

SSN’s were first issued, although these decedents had SSNs 

assigned to them.

Agency officials told us SSA has never investigated how these errors 

occurred or whether they may affect payments to Social Security and 

other federal program beneficiaries. They did not think these types of 

errors would have resulted in improper benefit payments because they 

involved persons recorded as deceased. SSA officials said some of these 

anomalies were likely associated with records added prior to the mid1970’s that were manually processed. For example, SSA staff could have 

incorrectly keyed in a date of birth that occurred after the reported date of 

death.

Officials added that SSA has undertaken or will soon undertake several 

initiatives aimed at correcting these types of errors and preventing them 

in the future. Among those they said have already been implemented are 

the following:

• SSA is using an edit check to identify records showing a date of birth 

that occurs after a date of death and taking corrective action before 

the report is processed further. SSA, however, has not decided 

whether to make corrections to these dates in records processed 

before the check was implemented.

• In December 2012, SSA identified cases and terminated benefits for 

individuals over 115 years old whose Numident record showed they 

were deceased and who had their benefits suspended or were entitled 

only to Medicare benefits. SSA plans to repeat this match for fiscal 

year 2013. SSA officials told us that, as a result of this initiative, the 

agency corrected about 17,000 cases to reflect terminated benefits 

due to death.

• In June 2013, SSA began making monthly comparisons of Numident 

records containing death information with its Title II and Title XVI 

payment records. It is sending alerts to field offices to resolve cases 

showing individuals who are receiving or scheduled to receive 

benefits in the near future even though they are listed as deceased. 

SSA officials told us, as a result of the initiative, the agency corrected 

about 14,500 payment records to reflect suspended or terminated 

payment status due to death.

• In September, 2013, SSA began a data exchange with CMS to 

identify beneficiaries ages 90 to 99 who are still receiving Title II 

benefits but have not used Medicare for 3 years or more and have no 
Page 18 GAO-14-46 Social Security Death Data

other insurance or nursing home information in their records. Agency 

officials stated that they identified and referred to SSA regional offices 

for action about 18,600 cases.

SSA also plans to introduce a computer code that can be used to 

terminate benefits for certain Title II beneficiaries who are 115 or older,

whose benefits have been continuously suspended for 7 or more years, 

and for whom SSA does not have a death record.

SSA officials informed us that the agency has not conducted a risk 

assessment to determine the impact of erroneous, incomplete, or 

untimely death information on SSA’s ability to prevent improper benefit 

payments. According to federal internal control standards, federal 

agencies should conduct risk assessments of both internal and external 

factors that may impact their ability to achieve program objectives, and 

implement appropriate control activities in response.32 More specifically, 

these standards note that agency management should pursue a 

comprehensive identification of possible risks, put in place mechanisms to 

identify risks posed by external and internal factors, and undertake a 

thorough and complete analysis of the possible effect of the risks 

identified. The standards specifically include consideration of the potential 

for improper use of funds—which would encompass improper benefit 

payments. Agency officials told us they believe errors in the death data 

likely represent a small fraction of all death reports, leading to a relatively 

small number of improper payments. Agency officials did note that SSA 

has initiated efforts to address errors identified by the SSA OIG,33

 32

and 

enhance the accuracy of its death information by fully redesigning how it 

processes death reports and compiles the data for dissemination. They 

also indicated that a risk assessment of the impact of death data errors 

may be conducted as part of the initiative but were unsure. Based on the 

description of the redesign project SSA staff provided us, we anticipate it 

will fill some of the gaps we identified in how SSA monitors its death 

reporting process, such as tracking the proportion of death reports that 

come from various sources and that SSA verifies.

GAO/AIMD-00-21.3.1

33 See, for example, Social Security Administration, Office of the Inspector General, Title 

XVI Deceased Recipients Who Do Not Have Death Information on the Numident, A-09-12-

22132 (Baltimore, MD: May 3, 2013); and A-09-11-21171.
Page 19 GAO-14-46 Social Security Death Data

The Social Security Act requires SSA to share its full death file, to the 

extent feasible, with federal benefit-paying agencies for the purpose of 

preventing improper payments, if the agency reimburses SSA for its 

reasonable costs and the arrangement does not conflict with SSA’s duties 

with respect to state data.34 However, SSA has no guidance on its 

process for determining an agency’s eligibility. As of September 2013, 

seven federal benefit-paying agencies obtained SSA’s full set of death 

information including the information reported by states, directly from 

SSA: 35

• Centers for Medicare & Medicaid Services (CMS)36

• Department of Defense (Defense Manpower Data Center—DMDC)

• Department of Veterans Affairs (VA)

• Internal Revenue Service (IRS)

• Office of Personnel Management (OPM)

• Pension Benefit Guaranty Corporation (PBGC)

• Railroad Retirement Board (RRB)

According to SSA officials, agencies receiving access to the full death file 

must make a formal request and have agreements in place with SSA that 

outline the circumstances of each data-sharing arrangement. In order to 

 34 42 U.S.C. § 405(r)(3).

35 GAO also receives SSA’s full death file directly from SSA for audit purposes pursuant to 

our authority under 31 U.S.C. § 716.

36 According to SSA officials, CMS also shares the full death file it obtains from SSA with 

the U.S. Department of Health and Human Services’ Health Resources and Services 

Administration, under an information exchange agreement between CMS and SSA, as 

authorized by 42 U.S.C. § 405(r)(9). 

Access to Death Data 

Varies and SSA Lacks 

Transparency in 

Communicating How 

it Determines Agency 

Eligibility and 

Reimbursement Costs

SSA Lacks Written 

Guidance on Its Process 

for Determining Agency 

Access to Full Death Data
Page 20 GAO-14-46 Social Security Death Data

determine whether they are eligible to receive access under the Act, 

officials told us that SSA asks the requesting agencies to explain how 

their proposed use of the information is in accordance with the allowable 

use outlined in the Act. Specifically, SSA bases its initial eligibility 

determinations on whether: (1) the agencies pay federally-funded 

benefits, and (2) the agencies propose to use the full death file to ensure 

proper payment of those benefits. According to officials, once SSA has 

determined an agency is eligible, it ensures the remaining statutory 

requirements regarding cost reimbursement and adherence to SSA’s 

duties with respect to state data are met, and establishes an information 

exchange agreement with the agency. However, in making this 

determination, SSA officials told us they do not use any criteria more 

specific than the language of the Act to guide decision-making, nor have 

they developed guidance for the procedures they follow.

SSA’s determinations as to whether agencies meet these requirements 

have varied. In one example of an eligibility determination, officials told us 

they provide the full death file to IRS for purposes that include allowing 

IRS to confirm or deny taxpayers’ requests for exemptions and standard 

deductions. In addition, officials told us SSA would generally have the 

authority to share the full death file with the OIG at benefit-paying 

agencies for the purpose of ensuring proper payment of federally-funded 

benefits. In fact, SSA officials approved a request for access to the full 

death file for the OIG at the Department of Health and Human Services.37

 37 However, the agency determined it would instead seek out less costly sources of the 

data.

However, officials also told us that Treasury, which operates the Do Not 

Pay Business Center for a similar purpose as OIGs—preventing improper 

payments—is not eligible to receive the full death file. Officials provided 

no documentation outlining their rationale for this determination, but 

explained that one concern they had with providing Treasury with it was 

that they were not authorized to provide the state-reported death data to 

Treasury to distribute it to other agencies. Because SSA has some 

discretion in making such determinations and agencies’ circumstances 

may differ, this variation in determinations may not represent 

inconsistency with the Act. However, since SSA does not make available 

written guidance describing the criteria it uses to make determinations as 

to whether the agencies meet the statutory requirements, there is no 
Page 21 GAO-14-46 Social Security Death Data

assurance that SSA’s eligibility determinations under the Act are 

consistent across agencies.

Without written guidance explaining SSA’s criteria for approving or 

denying agencies’ requests for the full death file, such as the factors SSA 

considers in deciding whether an agency provides federal benefits, 

potential recipient agencies may not know whether they are eligible. For 

example, officials at PBGC told us that they undertook a comprehensive 

review of all the agency’s applicable legal authorities because they were 

unsure whether the benefits the agency paid met the requirements of the 

Act. According to federal internal control standards, agencies should have 

written documentation, such as this type of guidance, and it should be 

readily available for examination. The absence of written guidance may 

also pose a risk to the consistency of SSA’s future determinations in the 

event of staff turnover, changes in administration, or any other disruption 

that could lead to a loss of institutional knowledge. In a September 2008 

report, we found that there was a risk to the management and operational 

continuity of ongoing projects at SSA due to a lack of written policies and 

procedures.38

Any agency that does not access SSA’s full death file can instead access 

the publicly-available DMF. Agencies can purchase a DMF subscription 

through the Department of Commerce’s National Technical Information 

Service (NTIS), which reimburses SSA for the cost of providing the file.

We found that during organizational change, project 

objectives, designs, and evaluation may be affected absent 

comprehensive written policies and procedures. Also, until recently, SSA 

did not have an officially designated organizational component for 

monitoring use of death data or making decisions on access to its full 

death data, which could have introduced additional uncertainty to those 

decisions. However, officials told us the agency created the Office of Data 

Exchange in January 2013 to clarify, simplify, and strengthen existing 

data exchange programs. As part of this effort, it is looking at how SSA

makes decisions regarding access to its death data, as well as how it 

shares the data with other agencies, and is monitoring the data exchange 

agreements.

39

 38 GAO, Social Security Disability: Management Controls Needed to Strengthen 

Demonstration Projects, 

In accordance with the Act, SSA excludes state-reported death records 

GAO-08-1053 (Washington, D.C.: Sept. 26, 2008). 

39 NTIS distributes a range of federally-funded scientific and technical information.
Page 22 GAO-14-46 Social Security Death Data

from the DMF. Federal entities that purchase the DMF from NTIS include, 

among others:40

• Department of Justice

• Department of Homeland Security

• Drug Enforcement Administration

• National Institute on Occupational Safety and Health

• Veterans Affairs medical facilities

The death information included in the DMF is less complete and likely 

less accurate than that contained in SSA’s full death file, which may result 

in federal agencies that use the DMF receiving less useful information 

than agencies that use the full death file. According to SSA officials, 

agencies that purchase the DMF have access to 10 percent fewer 

records overall than agencies with access to the full death file due to the 

removal of state-reported deaths. Moreover, SSA officials said they 

expect the percentage of state-reported deaths as a proportion of all of 

SSA’s death records to increase over time, which could lead to a greater 

portion of death data being removed each year to create the DMF. For 

example, for deaths reported in 2012 alone, the DMF included about 40 

percent fewer death records than what was included in SSA’s full death 

file. As a result, agencies that purchase the DMF will continue to access 

fewer records over time than those that obtain SSA’s full death file. In 

addition, because the deaths reported through EDRS by states are 

generally more accurate, it is likely that federal agencies using the DMF 

would encounter more errors than agencies using SSA’s full death file. In 

fact, the SSA OIG found that approximately 98 percent of deaths that 

SSA erroneously included in its death file were reported by non-state 

sources.41

It is not SSA’s practice to proactively notify agencies that may be eligible 

for access to the complete set of death information. Officials explained 

that distributing death information to other federal agencies is not a part of 

SSA’s mission, nor is it an activity for which SSA receives an 

 40 We cannot be sure that we have a comprehensive list of federal DMF customers 

because, prior to our request, NTIS did not maintain such a list. In fulfilling our request, 

NTIS manually generated a list by judging customers’ federal status using email 

addresses as the sole criterion. 

41 Social Security Administration, Office of Inspector General, Sources of Erroneous 

Death Entries Input Into the Death Master File, A-06-09-29095 (Baltimore, MD: February 

4, 2009).
Page 23 GAO-14-46 Social Security Death Data

appropriation. As a result, some agencies may not know to request the 

full death file directly from SSA and may be relying on the less complete, 

less accurate DMF to assist them in administering their programs. In at 

least one case, an agency administering federal benefit-paying programs 

was using the less comprehensive DMF to match against its payment 

systems until it received access to the full file in January 2013. In a June 

2013 report, we found that two agencies within the U.S. Department of 

Agriculture (USDA) were not matching beneficiary lists against SSA’s full 

death file.42 We spoke with program officials at another benefit-paying 

agency that uses the DMF—the Department of Labor’s Division of Energy 

Employees Occupational Illness Compensation, within the Office of 

Workers’ Compensation Programs—who told us they did not know until 

very recently that obtaining the full set of death data was an option.

Under the Act, one condition of receiving SSA’s full death data is that the 

recipient agency reimburses SSA for the reasonable cost of sharing death 

data. However, factors including legal requirements and a quid pro quo 

arrangement have resulted in varying projected reimbursement amounts 

for different agencies (see table 1). 

Table 1: Projecteda

Agency

Reimbursement Amounts for Federal Agencies Receiving SSA’s 

Full Death Data

Projected fiscal year 2013 

reimbursement amount Frequency of receipt

Centers for Medicare & 

Medicaid Services

$9,900 Weekly updates

Department of Defense/DMDC $44,554 Monthly updates, plus 

the full file annually

Department of Veterans Affairs $0b Weekly updates, plus 

the full file annually

Internal Revenue Service $87,156 Weekly updates, plus 

the full file annually

Office of Personnel 

Management

$0c Weekly updates, plus 

the full file annually

Pension Benefit Guaranty 

Corporation

$70,000 (projected for 

FY2014)d Weekly updates, plus 

the full file annually

Railroad Retirement Board $9,000 Monthly updates

Source: GAO compilation of agency data.

 42 GAO-13-503.

Reimbursement Amounts 

Vary and SSA Does Not 

Share How They are 

Calculated
Page 24 GAO-14-46 Social Security Death Data

Note: GAO receives SSA’s full death file for audit purposes pursuant to our authority under 31 U.S.C. 

§ 716.

NTIS receives the DMF from SSA on a weekly basis; in fiscal year 2012 its reimbursement amount 

was $148,186.

a

Reimbursement amounts are projected because SSA bills agencies in arrears. Therefore, SSA will 

bill agencies for the actual amount owed for fiscal year 2013 death data some time after the end of 

September 2013. 

b

By statute, the Department of Veterans Affairs is not required to reimburse SSA. 38 U.S.C. § 5106.

c

The Office of Personnel Management and SSA have agreed that the expenses involved in their data 

exchanges are reciprocal.

d

The Pension Benefit Guaranty Corporation began receiving weekly updates of the full death file in 

July 2013. 

Some agencies do not reimburse SSA at all. For example, VA is not 

required to provide reimbursement by statute, while OPM provides federal 

retirement data to SSA that is critical to its mission, and the agencies 

have agreed that the expenses involved in the exchanges are 

reciprocal.43

For other agencies, some of these differences in projected 

reimbursement amounts cannot fully be explained by the frequency with 

which the agencies expect to receive the data. For example, as noted in 

Table 1, CMS expected to receive updates to the full death file weekly 

from SSA and CMS officials told us the agency expected to reimburse 

SSA $9,900 in fiscal year 2013. RRB similarly expected to pay $9,000, 

despite expecting to receive the file less frequently—monthly, rather than 

weekly. At the same time, IRS expected to receive weekly updates to the 

full file plus the full file annually in fiscal year 2013, and PBGC expected 

to receive the file with the same frequency for fiscal year 2014. However, 

IRS expected to pay more than $87,000, while PBGC’s expected 

reimbursement amount was $70,000. 

However, SSA officials were unable to point to any 

reciprocity study supporting this decision. 

While the reimbursement amounts for agencies are sometimes included 

in the inter-agency agreements governing how SSA provides its full death 

file, the agreements lack information on how these amounts were 

determined. According to SSA officials, these agreements specify the 

permissible purpose for using the death data and limitations on sharing 

 43 VA does not provide reimbursement because it is statutorily exempted from doing so. 

The statute specifies that the cost of providing information to the Secretary of Veterans 

Affairs for the purposes of determining eligibility for or amount of veterans’ benefits is to be 

borne by the agency providing the information; in this case, SSA. 38 U.S.C. § 5106
Page 25 GAO-14-46 Social Security Death Data

the data within the agency. However, according to officials we spoke with 

at several agencies that receive the full death file, SSA staff did not 

provide an explanation for reimbursement amounts. SSA officials told us 

they calculate a detailed breakdown of expenses in an internal document, 

but provide only a summary of these expenses in the estimates and 

billing statements they send to agencies. As a result, recipient agencies 

do not know the factors that lead to the reimbursement amounts they are 

charged, which could prevent them from making informed decisions 

based on the amount they are spending. According to federal internal 

control standards, financial information is something agencies should 

communicate for external uses, because it is necessary to determine 

whether agencies are meeting goals for accountability for effective and 

efficient use of resources. In addition, SSA officials told us that because 

the Act provides for SSA to be reimbursed for its costs, the agency will 

not negotiate the reimbursement amounts if a prospective recipient 

agency indicates unwillingness to pay the quoted amount. In one case, 

SSA officials told us that while it approved a request for access to the file 

from the OIG for the U.S. Department of Health and Human Services, the 

two entities never finalized an agreement because the OIG determined it 

wanted to look for a lower-cost option for obtaining death information.

Federal benefit programs’ need for accurate administrative data, such as 

death information, is increasingly evident in an environment of continuing 

budget shortages, where improper payments due to inaccurate 

information cost taxpayers billions of dollars in fiscal year 2012. Because 

of its mission, SSA is uniquely positioned to collect and manage death 

data at the federal level. SSA already has a responsibility to ensure that 

this information is as accurate and complete as possible for its own 

beneficiaries. Further, proposed legislation, if enacted, would require SSA 

to disseminate full death data to a number of additional eligible federal 

agencies. Only with more accurate and complete data can these 

agencies reduce the risk of paying deceased beneficiaries. However, 

because SSA has never analyzed the risk posed by errors or processes 

that could result in errors, it is not fully aware of steps that would be 

needed to address them. As a result, SSA and other federal agencies that 

use the full death data and the DMF are potentially vulnerable to making 

improper payments. Similarly, the absence of written guidelines for 

determining which agencies can access the full death data may impede 

federal agencies’ ability to obtain that information in a timely and efficient 

manner. Finally, SSA’s approach to calculating and charging agencies for 

death data lacks transparency about the fact that federal agencies pay 

varying amounts for the same information. In such a setting, there is a 

Conclusions
Page 26 GAO-14-46 Social Security Death Data

risk that federal agencies that could otherwise benefit from death 

information will decline to participate, whether due to confusion over 

SSA’s access protocols or uncertainty concerning its financial 

reimbursement policies.

In order to enhance the accuracy of and ensure appropriate agency 

access to SSA’s death data, we recommend that the Social Security 

Administration’s Acting Commissioner direct the Deputy Commissioner of 

Operations to take the following three actions:

1. To be more informed about ways to improve the accuracy and 

completeness of its death information, conduct a risk assessment of 

SSA’s death information processing systems and policies as a 

component of redesigning SSA’s death processing system. Such an 

assessment should identify the scope and extent of errors, and help SSA 

identify ways to address them. In addition, assess the feasibility and cost 

effectiveness of addressing various types of errors, given the risk they 

pose.

2. To clarify how SSA applies the eligibility requirements of the Social 

Security Act and enhance agencies’ awareness of how to obtain access, 

develop and publicize guidance it will use to determine whether agencies 

are eligible to receive SSA’s full death file.

3. To increase transparency among recipient agencies, share a more 

detailed explanation of how it determines reimbursement amounts for 

providing agencies with death information.

We provided a draft of this report to the Social Security Administration

(SSA), the National Technical Information Service, the Department of 

Treasury (Treasury), the Department of Defense, the Department of 

Labor, the Centers for Medicare & Medicaid Services (CMS), the Internal 

Revenue Service (IRS), the Office of Personnel Management, the 

Pension Benefit Guaranty Corporation, and the Office of Management 

and Budget (OMB) for review and comment. SSA officials provided 

written comments, which are reproduced in appendix II and described 

below. IRS officials provided technical comments that further supported

the impact of late-reported deaths on federal users of SSA’s death data, 

and we incorporated an example they provided into that discussion. The 

Department of Labor, the Office of Personnel Management, the Pension 

Recommendations for 

Executive Action

Agency Comments 

and our Evaluation
Page 27 GAO-14-46 Social Security Death Data

Benefit Guaranty Corporation, and OMB also provided technical 

comments, which we incorporated in the report as appropriate. CMS, the 

Department of Defense, Treasury, and the National Technical Information 

Service had no comments.

In its comments, SSA partially agreed with our first and third

recommendations and disagreed with our second. In response to our first 

recommendation, SSA agreed to perform a risk assessment as part of its

death information processing system redesign project, but raised 

concerns about performing risk assessments for other users of the death 

data. In making this recommendation, we did not intend for SSA to 

perform risk assessments for other agencies’ programs. However, we 

believe that by assessing the risks of inaccuracies in its death data, 

SSA’s efforts could shed light on risks posed to other agencies’ programs

in addition to its own. To clarify this, we deleted the specific reference to 

other agencies. SSA also partially agreed with our third recommendation,

stating that it has implemented improvements in its estimating procedures 

for future reimbursable agreements to ensure consistent estimates for all 

customers. However, the agency stated that it is not a typical government 

business practice to share these detailed costs for reimbursable 

agreements. We are encouraged that SSA has made efforts to 

standardize the estimates it shares with its federal partners, though we 

have not had the chance to evaluate their effectiveness, since these 

efforts were made recently. Also, we recognize that there may be 

limitations on the type of cost details SSA can provide to recipient 

agencies. However, we continue to believe that more transparency in 

conveying the factors that lead to the estimated and final reimbursement 

amounts recipient agencies are charged could help them make more 

informed decisions. SSA disagreed with our second recommendation, 

stating that each request to obtain the full death file is unique, and that 

officials must review them on a case-by-case basis to ensure compliance 

with various legal requirements. It also expressed concern that 

developing this guidance as we recommended would require agency 

expenditures unrelated to its mission in an already fiscally constrained 

environment. We appreciate that agencies may base their request for the 

full death file on different intended uses, and support SSA’s efforts to 

ensure compliance with all applicable legal requirements. However, we 

continue to believe that developing this guidance could help to ensure 

consistency in SSA’s future decision making by the new Office of Data 

Exchange, as well as enhance agencies’ ability to obtain the data in a 

timely and efficient manner. We do not expect such guidance, which 

could include information such as the factors SSA considers in deciding 
Page 28 GAO-14-46 Social Security Death Data

whether an agency provides federal benefits, would restrict SSA’s 

flexibility. 

SSA also outlined two general concerns with the body of the report. First, 

it expressed concern that we inaccurately described SSA officials’ 

reasons for determining that the agency could not provide Treasury with 

full death data for the Do Not Pay Initiative. We made revisions to the 

report to more accurately describe SSA’s reasoning. Second, SSA was

concerned about the use of estimated reimbursement costs in Table 1

because these costs fluctuate throughout the year. SSA suggested 

instead using figures it provided reflecting the actual costs from fiscal year 

2012. The agency also noted that Table 1 contains incorrect information 

related to the frequency at which the agencies receive the file. While we 

agree that actual costs are inherently more accurate than estimated 

costs, we chose to use estimated costs because this is the information 

federal agencies receive when they are deciding whether and how to 

obtain death data. In response to SSA’s assertion that our table contains 

incorrect information, we have added information to the table regarding 

whether agencies expected to receive the annual file. We followed up 

with an official, who clarified that our previous table was incomplete 

because, for some of the agencies, it lacked information about receipt of 

the annual full file. SSA also provided technical comments, which we 

incorporated in the report as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees and the heads of the agencies 

listed above. In addition, the report will be available at no charge on 

GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, 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 29 GAO-14-46 Social Security Death Data

page of this report. GAO staff who made major contributions to this report 

are listed in appendix III.

Dan Bertoni

Director, Education, Workforce,

 and Income Security Issues
Page 30 GAO-14-46 Social Security Death Data

List of Requesters

The Honorable Thomas R. Carper

Chairman 

Committee on Homeland Security and Governmental Affairs

United States Senate 

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate 

The Honorable Claire McCaskill

Chairman

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate 

The Honorable Ron Johnson

Ranking Member

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate 

The Honorable Susan M. Collins

United States Senate

The Honorable Sam Johnson

Chairman

Subcommittee on Social Security

Committee on Ways and Means

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-14-46 Social Security Death Data

This report examines (1) how the Social Security Administration (SSA) 

obtains death reports for inclusion in the death data it maintains and steps 

it takes to ensure these reports are accurate; and (2) the factors affecting 

federal agency access to SSA’s death data. To address these objectives, 

we reviewed applicable federal laws and SSA procedures, as well as 

relevant reports and evaluations, such as reports from multiple Offices of 

Inspectors General. We interviewed SSA officials regarding how SSA 

obtains and processes death reports and maintains and shares its death 

information. We also interviewed representatives of some entities that 

provide death reports to SSA. We obtained and reviewed available 

corroborating documentation such as the data sharing agreements SSA 

made with other federal agencies. To evaluate SSA’s processes for 

obtaining, processing, and sharing death information, we reviewed 

standard criteria, such as the Standards for Internal Controls in the 

Federal Government.1

We tested for specific types of errors within SSA’s death data in several 

different ways using the full death information file; however, we did not 

attempt to identify all possible errors in the death data. Our reliability tests 

included identifying cases in which the date of birth was listed as 

occurring after the date of death. We also looked for cases involving 

deaths at very old ages—115 and higher—and cases of death that 

occurred before 1936 (when account numbers were first issued for 

administering Social Security programs) after observing such cases in a 

publicly-available version of the Death Master File (DMF). We then 

systematically tested for incidences of these occurrences in the full death 

information file.

We performed independent testing of SSA’s death 

data to identify specific types of errors such as dates of birth that followed 

dates of death. We also drew a randomly selected but non-generalizable 

sample of cases that SSA removed from the death information for further 

review in order to identify potential explanations for that action. Finally, we 

interviewed officials at other federal agencies that use SSA’s death 

information about how they access and use it.

 1 GAO, Government Operations: Standards for Internal Controls in the Federal 

Government, AIMD-00-21.3.1 (Washington, D.C.: Nov. 1, 1999). These standards, issued 

pursuant to the requirements of the Federal Managers’ Financial Integrity Act of 1982, 

Pub. L. No. 97-255, 96 Stat. 814, provide the overall framework for establishing and 

maintaining internal control in the federal government, and for identifying and addressing 

major performance and management challenges and areas at greatest risk of fraud, 

waste, abuse, and mismanagement.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-14-46 Social Security Death Data

As part of our tests to identify deaths that occurred at age 115 or older 

and those that occurred before 1936, we examined the monthly update 

file of cases SSA added in March 2013, which represent new death 

reports received by SSA. In conducting our analysis, we found a total of 

539 deaths were added to the death data during this month that 

reportedly occurred in years prior to 2012 (and another 9,462 that 

occurred in 2012). At SSA’s request, we provided a sample of these 

cases to SSA staff to investigate. We selected and provided SSA lists of 

those cases in which the deaths were reported to have occurred in 1976 

and 2004—a total of 22 cases. We chose these two years because each 

of these years included a sufficiently large number of cases to allow us to 

potentially identify patterns with respect to whether SSA had been paying 

benefits to deceased beneficiaries. We also chose two years that were 

nearly three decades apart to determine if there were any differences due 

to time period variation. SSA was unable to research these cases 

individually because of time constraints, but provided explanations of 

possible reasons why the agency receives reports this many years after a 

death.

SSA also produces weekly and monthly update files listing deaths to be 

deleted from and death reports to be added to its death information files. 

To identify possible reasons for deleting deaths, we drew a random 

sample of 97 cases from the monthly update files produced from 

February 2012 through January 2013. 2

 2 There were a total of 8,197 unique deleted records from this time period.

If all cases in this sample were 

reviewed, we would have been able to make generalized observations 

about all of the deleted cases in this time period. We provided this list of 

cases listed in the order selected and requested SSA to research them—

beginning at the top of the list—to determine if it had any record of the 

reason for deleting the case from its death data. To identify possible 

relationships with other characteristics, we also asked officials to provide, 

if available, the source of the death report, and whether or not the listed 

decedent was a Social Security beneficiary. We were satisfied we had a 

sufficient number of cases after SSA had completed work on 46 of the 97 

cases. While still randomly-selected, this smaller sample was nongeneralizable. In recognition of the time and resources SSA was 

committing to this work, we determined that the 46 cases would be 

sufficient to describe characteristics of these cases, even though we 

would not be able to make generalized statements about all deleted 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-14-46 Social Security Death Data

cases in our population. Of these 46 cases, SSA officials were able to 

determine reasons for deletion in 28 cases, source of the death report in 

13, and determine the beneficiary/non-beneficiary status in all 46. They 

were able to identify all three of these characteristics in 11 of the cases.3

For all of the tests and sampling just described, we used the full death 

data file. We determined that the data we used was sufficiently reliable for 

our reporting purposes. The computer programming we used was 

checked by a second programmer for accuracy, giving us further 

assurance that the results we present in the report are reliable.

To assess the factors affecting agencies’ access to SSA’s death data, we 

interviewed officials at seven federal agencies that used the death data—

either the full death file or the Death Master File (DMF). We obtained the 

list of federal agencies that obtain the full death file directly from SSA, as 

well as the list of federal entities that purchase the public Death Master 

File (DMF) from the National Technical Information Service (NTIS). We 

obtained the former through prior discussions with SSA officials and 

congressional testimonies. For those federal entities that purchase the 

public DMF, we requested a list of federal customers from officials at 

NTIS. According to NTIS officials, they had to compile the list manually 

because, prior to our request, they had no business reason to separate 

federal customers from other customers. They described their manual 

compilation process as looking through the NTIS list of approximately 800 

DMF subscription customers one-by-one and determining, for each one, 

whether it represented a federal customer by looking at the name and 

email address. Officials then sent us a list of 27 federal customers.4

Our primary criterion for selecting six of the seven agencies to interview 

was whether they administered programs that pay benefits. We selected 

the following four benefit-paying agencies that obtain SSA’s full death file 

because we wanted to gain an understanding of agencies’ experience 

with accessing and using the full death file:

 3 In 16 cases, SSA was only able to determine beneficiary/non-beneficiary status.

4 This list represented fewer than 27 federal agencies, as multiple offices or bureaus that 

fall under the same federal agency appeared in several cases. For example, two entities 

within the Department of Homeland Security—Customs and Border Protection and 

Citizenship and Immigration Services—were included in the list.
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-14-46 Social Security Death Data

• Centers for Medicare & Medicaid Services (CMS)

• Department of Defense/Defense Manpower Data Center (DMDC)

• Internal Revenue Service (IRS)

• Office of Personnel Management (OPM)

We based this selection of four agencies on their reported improper 

payment amounts from 2012, focusing on those with higher amounts, 

such as CMS and IRS. We also selected one program within a benefitpaying agency—Department of Labor’s Division of Energy Employees 

Occupational Illness Compensation within the Office of Workers’ 

Compensation Programs—that was purchasing the DMF rather than 

obtaining the full file directly from SSA. We sought to understand this 

agency’s general experience using the DMF, as well as whether it had 

ever tried to obtain the full file from SSA. Additionally, we selected the 

Pension Benefit Guaranty Corporation (PBGC) for interviews because it 

transitioned from purchasing the DMF to obtaining SSA’s full death file 

during the course of our review, so officials had the unique perspective of 

receiving both files. For the seventh agency, we interviewed officials from 

the U.S. Department of Treasury’s (Treasury) Do Not Pay Business 

Center, even though it does not pay benefits, because of its program goal 

to prevent improper payments. Also, we had learned that Do Not Pay 

officials had previously requested—and were denied—access to SSA’s 

full death file, and we wanted to better understand the circumstances of 

that interaction.

One limitation of the approach we used to identify all federal users of 

SSA’s death data is the subjectivity with which NTIS officials judged its 

customers to be associated with federal agencies. As a result, the list we 

obtained of federal DMF customers may have been incomplete. However, 

based on our review of reports on improper federal payments and 

interviews with SSA officials, we are confident that the information we 

collected from officials at the agencies we selected accurately represents 

federal customers’ experience obtaining and using SSA death data.

We conducted this performance audit from November 2012 to November 

2013 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 II: Comments from the Social 

Security Administration

Page 35 GAO-14-46 Social Security Death Data

Appendix II: Comments from the Social 

Security Administration
Appendix II: Comments from the Social 

Security Administration

Page 36 GAO-14-46 Social Security Death Data
Appendix II: Comments from the Social 

Security Administration

Page 37 GAO-14-46 Social Security Death Data
Appendix II: Comments from the Social 

Security Administration

Page 38 GAO-14-46 Social Security Death Data
Appendix II: Comments from the Social 

Security Administration

Page 39 GAO-14-46 Social Security Death Data
Appendix II: Comments from the Social 

Security Administration

Page 40 GAO-14-46 Social Security Death Data
Appendix II: Comments from the Social 

Security Administration

Page 41 GAO-14-46 Social Security Death Data
Appendix III: GAO Contact and 

Staff Acknowledgments

Page 42 GAO-14-46 Social Security Death Data

Dan Bertoni, Director (202) 512-7215 or bertonid@gao.gov

In addition to the contact named above, Lori Rectanus, Acting Director; 

Jeremy Cox, Assistant Director; Keira Dembowski; Joel Marus; and Sara 

Pelton made significant contributions to this report. Also contributing to 

this report were Sarah Cornetto, Holly Dye, Justin Fisher, Alex Galuten, 

Mitch Karpman, Mimi Nguyen, Almeta Spencer, Walter Vance, Michelle 

Loutoo Wilson, and Amber Yancey-Carroll.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 43 GAO-14-46 Social Security Death Data

GAO, Farm Programs: USDA Needs to Do More to Prevent Improper 

Payments to Deceased Individuals, GAO-13-503 (Washington, D.C.: 

June 28, 2013).

GAO, Management Report: Improvements Are Needed to Enhance the 

Internal Revenue Service’s Internal Controls, GAO-13-420R (Washington, 

D.C.: May 13, 2013).

GAO, Social Security Administration: Preliminary Observations on the 

Death Master File, GAO-13-574T (Washington, D.C.: May 8, 2013).

Related GAO Products

(131218)
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