Social Security Death Data:
Additional Action Needed to Address Data Errors and Federal Agency Access
GAO-14-46: Published: Nov 27, 2013. Publicly Released: Dec 27, 2013.
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.
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.
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Recommendations for Executive Action
Comments: The Social Security Administration (SSA) has begun planning and analysis for phase one of its death processing system redesign, which will continue through the end of fiscal year 2014. For GAO to close this recommendation, SSA will need to ensure that it includes a risk assessment as part of the redesign project.
Recommendation: In order to enhance the accuracy of and ensure appropriate agency access to SSA's death data, and to be more informed about ways to improve the accuracy and completeness of its death information, the Social Security Administration's Acting Commissioner should direct the Deputy Commissioner of Operations to 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.
Agency Affected: Social Security Administration
Comments: The Social Security Administration (SSA) disagreed with this 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.
Recommendation: In order to enhance the accuracy of and ensure appropriate agency access to SSA's death data, and to clarify how SSA applies the eligibility requirements of the Social Security Act and enhance agencies' awareness of how to obtain access, the Social Security Administration's Acting Commissioner should direct the Deputy Commissioner of Operations to develop and publicize guidance it will use to determine whether agencies are eligible to receive SSA's full death file.
Agency Affected: Social Security Administration
Comments: The Social Security Administration (SSA) reported 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.
Recommendation: In order to enhance the accuracy of and ensure appropriate agency access to SSA's death data, and to increase transparency among recipient agencies, the Social Security Administration's Acting Commissioner should direct the Deputy Commissioner of Operations to share a more detailed explanation of how it determines reimbursement amounts for providing agencies with death information.
Agency Affected: Social Security Administration