Social Security Death Data: Additional Action Needed to Address Data Errors and Federal Agency Access
Published: 2013-11-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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. 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. 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.  Such inaccuracies could adversely affect the usefulness of SSA’s death  information in helping agencies combat improper payments.
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   We performed independent testing  Control in the Federal Government.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.
subsections: section_title: Background
paragraphs: 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  Act), as amended.(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.
In addition, SSA issues the Social Security Number  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.  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. 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.matches that information against corresponding information in its  databases, verifies the information for certain cases, and records the  individual as deceased.
When SSA receives a report of death it  Various entities, including federal agencies, can obtain SSA’s death data.  The complete file, which we refer to as “SSA’s full death file,” 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. However, SSA  may not include death data received from states in the DMF, which can  be accessed publicly. 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.
Given the focus on guarding against improper payments, there has been  new emphasis on how agencies access critical data, such as death  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. 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. 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. 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.
section_title: SSA Receives Death Reports from a Number of Sources, but Its Procedures for Handling Them Allow for Erroneous, Incomplete, and Delayed Death Information
subsections: section_title: SSA Receives Death Reports From Multiple Sources to Create Its Set of Death Records
paragraphs: SSA receives death reports from a variety of sources, including states,  family members, funeral directors, post offices, financial institutions, and  other federal agencies. According to agency officials, SSA received  about 7 million death reports in 2012. However, except for reports  submitted by states, it does not collect data identifying how many reports  come from each source.received within 30 days of the date of death.
Officials also said nearly all death reports are  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  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. 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 pre- verified 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.
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.
Death reports from sources other than states and federal agencies are generally  provided to SSA field offices. 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.
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). It then matches the information to SSA’s database of all  SSN-holders, known as the Numerical Index File (Numident).  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.
section_title: SSA Verifies Only Certain Death Reports Before Including Them in Its Death Records, and Does Not Include Others
paragraphs: 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  death to confirm the fact and date of death and confirm the decedent’s  SSN.
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.
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. 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.  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.
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).
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  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.
section_title: SSA’s Verification and Other Procedures Do Not Ensure Accurate, Complete, or Timely Death Data For Federal Users
paragraphs: 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  was able to identify a reason for deletion. 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. Nine of the 46  cases involved non-beneficiaries, which are also not verified.
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   As a result of this  been deceased for an average of nearly 17 years. practice, other federal benefit-paying agencies relying on these data  could make improper benefit payments.
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.
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. 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   They informed us that SSA payment systems would identify  benefits.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.
We found other instances of potentially erroneous information in the  death data that raise questions about its accuracy and usefulness. These  included:
130 records where the recorded date of death was before the date of  birth;
1,941 records where the recorded age at death was between 115 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 mid- 1970’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  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.
section_title: Access to Death Data Varies and SSA Lacks Transparency in Communicating How it Determines Agency Eligibility and Reimbursement Costs
subsections: section_title: SSA Lacks Written Guidance on Its Process for Determining Agency Access to Full Death Data
paragraphs: 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. 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:
Centers for Medicare & Medicaid Services (CMS)
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, 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). 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.  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  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. 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.
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.In accordance with the Act, SSA excludes state-reported death records  from the DMF. Federal entities that purchase the DMF from NTIS include,  among others:
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.
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  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. 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.
section_title: Reimbursement Amounts Vary and SSA Does Not Share How They are Calculated
paragraphs: 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).
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. However, SSA officials were unable to point to any  reciprocity study supporting this decision.
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.
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  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.
section_title: Conclusions
paragraphs: 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  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.
section_title: Recommendations for Executive Action
paragraphs: 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.
section_title: Agency Comments and our Evaluation
paragraphs: 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  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  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 of this report. GAO staff who made major contributions to this report  are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: 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   We performed independent testing of SSA’s death  Federal Government.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.
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.
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   If all cases in this sample were  February 2012 through January 2013. 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 non- generalizable. 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  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.
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.
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:
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 benefit- paying 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.
section_title: Appendix II: Comments from the Social Security Administration
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.
section_title: Related GAO Products
paragraphs: 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).