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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

November 2013: 

Social Security Death Data: 

Additional Action Needed to Address Data Errors and Federal Agency 
Access: 

GAO-14-46: 

GAO Highlights: 

Highlights of GAO-14-46, a report to congressional requesters. 

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 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. 

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. 

View [hyperlink, http://www.gao.gov/products/GAO-14-46]. For more 
information, contact Dan Bertoni at (202) 512-7215 or bertonid@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

SSA Receives Death Reports from a Number of Sources, but Its 
Procedures for Handling Them Allow for Erroneous, Incomplete, and 
Delayed Death Information: 

Access to Death Data Varies and SSA Lacks Transparency in 
Communicating How it Determines Agency Eligibility and Reimbursement 
Costs: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Social Security Administration: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: Projected Reimbursement Amounts for Federal Agencies 
Receiving SSA's Full Death Data: 

Figures: 

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

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

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

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: 

[End of section] 

GAO:
United States Government Accountability Office: 
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.[Footnote 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.[Footnote 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.[Footnote 
3] 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 Control in the Federal Government.[Footnote 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. 

Background: 

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.[Footnote 5] 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. 

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.[Footnote 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.[Footnote 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.[Footnote 8] 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. 

Various entities, including federal agencies, can obtain SSA's death 
data. The complete file, which we refer to as "SSA's full death file," 
[Footnote 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.[Footnote 10] However, SSA may not 
include death data received from states in the DMF, which can be 
accessed publicly.[Footnote 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.[Footnote 12] 

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.[Footnote 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. 
[Footnote 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.[Footnote 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. 

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: 

SSA receives death reports from a variety of sources, including 
states, family members, funeral directors, post offices, financial 
institutions, and other federal agencies.[Footnote 16] According to 
agency officials, SSA received about 7 million death reports in 2012. 
[Footnote 17] However, except for reports submitted by states, it does 
not collect data identifying how many reports come from each source. 
[Footnote 18] Officials also said nearly all death reports are 
received within 30 days of the date of death. 

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. 
[Footnote 19] 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.[Footnote 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 figure 1).[Footnote 21] Among 
other purposes, DACUS is intended to ensure that death information is 
correctly recorded 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. 

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

[Refer to PDF for image: process illustration] 

SSA receives death information: 

Sources: 

EDRS states: 
Online verification system: 
SSA front-end processing: 
Death Alert, Control and Update System (DACUS). 

Non-EDRS states: 
SSA front-end processing: 
Death Alert, Control and Update System (DACUS). 

VA: 
SSA front-end processing: 
Death Alert, Control and Update System (DACUS). 

[End of figure] 

Families; Financial Institutions, Funeral directors; 
Post offices: 
Field offices: 
Death Alert, Control and Update System (DACUS). 

CMS: 
Death Alert, Control and Update System (DACUS). 

SSA claim systems: 
Death Alert, Control and Update System (DACUS). 

SSA matches and verifies death reports: 

Death Alert, Control and Update System (DACUS): 
Matches with social security benefit payment system; 

Matches with Numident: 
* No match: Additional checks;
* No match: Death report not processed; 
* Verified: Death records in Numident; 
* Not verified[A]: Death records in Numident. 

SSA records and shares death information: 

Death records in Numident: 
* Full file: Federal benefit paying agencies; 
* DMF (public file): NTIS. 

EDRS: Electronic Death Registration System; 
VA: Department of Veterans Affairs; 
CMS: Centers for Medicare & Medicaid Services; 
DMF: Death Master File; 
NTIS: National Technical Information Service. 

Source: GAO analysis of SSA data. 

[A] See figure 2 for a description of reports that are not verified and 
those that are verified by SSA. 

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. 

[End of figure] 

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).[Footnote 22] It then matches the information to SSA's 
database of all SSN-holders, known as the Numerical Index File 
(Numident).[Footnote 23] Information in death reports from certain 
sources (see figure 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 Verifies Only Certain Death Reports Before Including Them in Its 
Death Records, and Does Not Include Others: 

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. 

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

[Refer to PDF for image: process illustration] 

Social Security Program Beneficiary? 
No: Not verified by SSA staff; 
Yes: 
* Source of death report: 
Financial institutions; 
Post offices; 
CMS; 
Department of Veterans Affairs; 
Non-EDRS State vital record agencies: 
Verified by SSA staff. 
* Source of death report: 
Families; 
Funeral directors; 
EDRS State vital record agencies: 
Not verified by SSA staff. 

CMS — Centers for Medicare and Medicaid Services; 
EDRS — Electronic Death Registration System 

Source: GAO analysis of SSA data. 

[End of figure] 

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.[Footnote 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.[Footnote 25] 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). 

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

[Refer to PDF for image: illustration] 

Death records in Numident: 

Full death file (over 98 million records): Contains deaths as reported 
by: 
* States; 
* Family members; 
* Financial institutions; 
* Post offices; 
* Funeral directors; 
CMS and VA. 
Federal benefit paying agencies with an agreement with SSA. 

DMF (over 87 million records): Contains deaths as reported by: 
* Family members; 
* Financial institutions; 
* Post offices; 
* Funeral directors; 
* CMS and VA. 
NTIS: Examples of users: 
* Individual members of the public; 
* Other federal agencies; 
* State government agencies; 
* Financial institutions; 
* Life insurance companies; 
* Credit reporting organizations; 
* Medical researchers; 
* Investigative firms; 
* Law enforcement. 

CMS: Centers for Medicare & Medicaid Services; 
VA: Department of Veterans Affairs; 
DMF: Death Master File; 
NTIS: National Technical Information Service. 

Source: GAO analysis of SSA data. 

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. 

[End of figure] 

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. 

SSA's Verification and Other Procedures Do Not Ensure Accurate, 
Complete, or Timely Death Data For Federal Users: 

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. 
[Footnote 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.[Footnote 27] Nine of the 
46 cases involved non-beneficiaries, which are also not verified. 
[Footnote 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.[Footnote 29] As a result of this practice, other 
federal benefit-paying agencies relying on these data could make 
improper benefit payments. 

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.[Footnote 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.[Footnote 31] 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. 

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 
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 
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. 

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. 
[Footnote 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,[Footnote 33] 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. 

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: 

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.[Footnote 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: [Footnote 35] 

* Centers for Medicare & Medicaid Services (CMS)[Footnote 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 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.[Footnote 37] 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.[Footnote 38] 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.[Footnote 39] 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: [Footnote 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. 
[Footnote 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 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.[Footnote 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. 

Reimbursement Amounts Vary and SSA Does Not Share How They are 
Calculated: 

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: Projected[A] Reimbursement Amounts for Federal Agencies 
Receiving SSA's Full Death Data: 

Agency: Centers for Medicare & Medicaid Services; 
Projected fiscal year 2013 reimbursement amount: $9,900; 
Frequency of receipt: Weekly updates. 

Agency: Department of Defense/DMDC; 
Projected fiscal year 2013 reimbursement amount: $44,554; 
Frequency of receipt: Monthly updates, plus the fully file annually. 

Agency: Department of Veterans Affairs; 
Projected fiscal year 2013 reimbursement amount: $0[B]; 
Frequency of receipt: Weekly updates, plus the fully file annually. 

Agency: Internal Revenue Service; 
Projected fiscal year 2013 reimbursement amount: $87,156; 
Frequency of receipt: Weekly updates, plus the fully file annually. 

Agency: Office of Personnel Management; 
Projected fiscal year 2013 reimbursement amount: $0[C]; 
Frequency of receipt: Weekly updates, plus the fully file annually. 

Agency: Pension Benefit Guaranty Corporation; 
Projected fiscal year 2013 reimbursement amount: $70,000 (projected 
for FY2014)[D]; 
Frequency of receipt: Weekly updates, plus the fully file annually. 

Agency: Railroad Retirement Board; 
Projected fiscal year 2013 reimbursement amount: $9,000; 
Frequency of receipt: Monthly updates. 

Source: GAO compilation of agency data. 

Note: GAO receives SSA's full death file for audit purposes pursuant 
to our authority under 31 U.S.C. § 716. 

Note: 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. 

[End of table] 

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.[Footnote 43] 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. 

Conclusions: 

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. 

Recommendations for Executive Action: 

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. 

Agency Comments and our Evaluation: 

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 [hyperlink, 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. 

Signed by: 

Dan Bertoni: 
Director, Education, Workforce, and Income Security Issues: 

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: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

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.[Footnote 44] 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. 

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 
February 2012 through January 2013. [Footnote 45] 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 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.[Footnote 46] 

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. 
[Footnote 47] 

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. 

[End of section] 

Appendix II: Comments from the Social Security Administration: 

Social Security: 
Office of the Commissioner: 
Social Security Administration: 
Baltimore, MD 21235-0001: 

November 7, 2013: 

Mr. Dan Bertoni, Director: 
Education, Workforce, and Income Security Issues: 
United States Government Accountability Office: 
441 G. Street, NW: 
Washington, DC 20548: 

Dear Mr. Bertoni: 

Thank you for the opportunity to review the draft report, "Social 
Security Death Data: Additional Action Needed to Address Data Errors 
and Federal Agency Access" (GAO-14-46). Our response to the audit 
report contents, findings, and recommendations are enclosed. We also
provided technical comments directly to your staff. 

If you have any questions, please contact me at (410) 966-9014. Your 
staff may contact Gary S. Hatcher, our Senior Advisor for Records 
Management and Audit Liaison Staff, at (410) 965-0680. 

Sincerely, 

Signed by: 

Katherine Thornton: 
Deputy Chief of Staff: 

Enclosure 

Comments On The Government Accountability Office Draft Report, "Social 
Security Death Data: Additional Action Needed To Address Data Errors 
And Federal Agency Access" (GAO-14-46): 

General Comments: 

We appreciate the Government Accountability Office (GAO) study of our 
death data. It is important to us to maintain a high level of accuracy 
in our death data -levels of accuracy that GAO itself has commended. 
[Footnote l] We strive to improve our process for collecting and 
maintaining death information. We believe that the relatively small 
percentage of errors have a minimal impact on the agency or the 
Federal Government. 

We recognize, however, that errors can cause hardships to members of 
the public affected by them. To help reduce errors even further, over 
the years we have used technology to increase the timeliness and 
accuracy of our collection of death information. Since 2002, we have 
worked with the States to increase the use of Electronic Death 
Registration (EDR). EDR automates our receipt of death information and 
is highly accurate because the States first verify the name and Social 
Security number of deceased individuals against our records before 
they issue a death certificate. The use of EDR, currently in 34 
States, New York City, and the District of Columbia, ensures that our 
death records include the most accurate and most current information. 
[Footnote 2] 

We are committed to continuing to share death information with our 
Federal partners to help them make accurate payments and combat fraud. 
However, because we are not the custodians of these data, and are not 
the repository for records of every death that occurs in the United 
States, and because every system of records is subject to human error, 
we require those agencies under our agreements to independently verify 
the information before they take action based on an individual's death 
as reported in our system. 

We are not the custodians of vital statistics records, nor should we 
be as that is the role of the State Bureaus of Vital Statistics. We 
collect death information from a variety of sources - about 2.5 
million reports of death a year from States, funeral homes, family 
members, and others - to administer our programs. We use death 
information to stop benefit payments to beneficiaries who die and pay 
benefits to survivors of insured persons. 

It is important to note that the death information we collect through 
EDR is State information, which, under section 205(r) of the Social 
Security Act (Act), we are authorized to disclose only for specific 
purposes. Under section 205(r)(3), we may provide to Federal benefit-
paying agencies all of our death information, including the death 
information we receive from the States. Like us, these agencies need 
death information to ensure the accuracy of their benefit payments
and prevent fraud, waste, and abuse. 

On Page 17 of the draft report, GAO misrepresents our response as to 
why we determined we could not provide the full Death Master File 
(DMF) to the Department of Treasury (Treasury) for the Do Not Pay 
(DNP) initiative. GAO states that our concern with providing Treasury 
the full DMF for DNP was, " ... that Treasury is not authorized to 
distribute the state reported death data to other agencies." In 
January 2013, we explained that, "Section 205(r) of the Act requires 
us to provide State death data to agencies to ensure proper payment of 
federally-funded benefits. Neither the Act nor any other Federal law 
authorizes us to provide State death data to the Department of 
Treasury to disseminate on our behalf. We cannot transfer our statutory
obligation to the Department of Treasury or any other Federal agency 
without legal authority to do so." 

We are concerned with the table shown on page 21 in the draft report. 
It is confusing and misleading to use estimated costs in this table as 
the figures fluctuate throughout the year. The actual closed costs for 
a particular year do not change. The table on page 5 of this document
shows we charged agencies receiving the information at the same 
frequency the same amounts. GAO's table also contains incorrect 
information on the frequency at which various Federal agencies receive 
the file. We strongly urge you to use the chart on page 5 of this 
document, which shows the actual costs charged to the various agencies 
and the correct frequency of receipt for fiscal year (FY) 2012. 

To address transparency and accuracy concerns, in FY 2013 we completed 
an extensive review of our DMF estimating procedures. For FY 2014, we 
implemented improvements to ensure consistent estimating for all 
customers. With this improved process, customers receiving the same 
data at the same frequency received the same estimated costs for FY 
2014. The new process also ensures that the estimated costs will be 
closer to actual costs. It is important to note that we cannot 
determine the actual costs at the beginning of the fiscal year because 
death data volumes fluctuate. The chart on page 6 of our response 
shows we estimate customer costs consistently for identical types of 
services. 

In summary, the death information we collect and our system for 
storing such data, are intended for a single purpose, which is to 
correctly administer our programs. Any other purpose is controlled by 
statute. The expansion of our role regarding death information is an 
important topic for public policy discussion, which should include a 
thorough examination of the availability and appropriate use of 
information collected by the States. 

Responses To The Recommendations: 

Recommendation 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, taking into 
consideration the risk they pose to SSA and other agencies. 

Response: 

We partially agree. We will perform a risk assessment as part of our 
death information processing system redesign project and continue to 
assess risks as part of our routine Federal Information Security 
Management Act review. We created a system to store death records to
support our programmatic needs, i.e., terminating beneficiary payments 
and providing survivor benefits to families of deceased individuals. 
Therefore, our assessments will focus on the risks to us. 

We do not agree to include a risk assessment for other agencies. We do 
not have detailed information on the policies, data requirements, and 
risks of other agencies. Other agencies should evaluate and consider 
the risk of using the data for their own purposes and determine the 
level of risk that is acceptable to their organization. Conducting an 
expanded risk assessment would be an undue burden on our resources and 
would negatively impact our mission-critical work. 

Recommendation 2: 

To clarify how SSA applies the eligibility requirements of the Social 
Security Act and enhance agencies' awareness of how to obtain access, 
the agency should develop and publicize guidance it will use to 
determine whether agencies are eligible to receive SSA's full death 
file. 

Response: 

We disagree. We must review all requests on a case-by-case basis to 
ensure compliance with the Privacy Act, 5 U.S.C. 552a, the Act, and 
other controlling disclosure statutes. Requests for information from 
us are based on the needs of each requester and usually unique. 

The report acknowledges that we recently created a new office to 
review data exchange agreements with other agencies to help unify our 
data exchange activities. The new office, serving as a central point 
of contact for partner agencies, will help ensure our exchanges meet
our program and business needs, and function across governmental 
boundaries. 

Any Federal agency that would like to explore accessing the full DMF, 
which includes State death records, should submit a request to 
[hyperlink, ogc.opd.controls@ssa.gov. We would be happy to
review the request, and if it satisfies the requirements of section 
205(r)(3) of the Act, we will, to the extent feasible, enter into an 
Information Exchange Agreement covering terms, conditions, and 
reimbursement for the exchange. 

In addition, implementing this recommendation would result in agency 
expenditures unrelated to our mission at a time when resources are 
strained. 

Recommendation 3: 

To increase transparency among recipient agencies, SSA should share a 
more detailed explanation of how it determines reimbursement amounts 
for providing agencies with death information. 

Response: 

We partially agree. We comply with Office of Management and Budget 
(OMB) Circular A-25, User Charges, and charge "full cost" for goods or 
services we provide. We ensure charges are sufficient to recover the 
full cost to provide goods, resources, or services, as defined by the
Federal Accounting Standards Advisory Board. We provide estimated cost 
information to our Federal partners as part of the reimbursable 
agreement. In FY 2013, we refined our process for death data cost 
estimates and established consistent standardized costs, which we will 
reflect in future reimbursable agreements (see table on page 6). 

Using the OMB Circular A-25 framework, we review all reimbursable 
requests on a case-by-case basis to determine our full costs. Such 
costs include all direct and indirect expenses to any part of the 
Federal Government to provide goods, resources, or services. Our typical
reimbursement cost estimates include categories such as salaries and 
other direct costs (including Information Technology costs), office 
overhead, agency overhead, Information Technology Special Project 
charges, and a contingency amount to cover unforeseen costs. As a
government-wide business practice, Federal agencies do not share 
detailed costs for reimbursable agreements. 

Table: Reimbursement Amounts for Federal Agencies Receiving SSA's Full 
Death Data: 

Agencies that Received the Full File in FY 2012: Centers for Medicare 
& Medicaid Services (CMS); 
FY 2012 Reimbursement Amount (Actual Costs): $32,599; 
Frequency of Receipt: Weekly Updates. 

Agencies that Received the Full File in FY 2012: Department of Defense, 
Defense Manpower Data Center (DoD, DMDC); 
FY 2012 Reimbursement Amount (Actual Costs): $8,225; 
Frequency of Receipt: Full File Annually and Monthly Update. 

Agencies that Received the Full File in FY 2012: Railroad Retirement 
Board (RRB); 
FY 2012 Reimbursement Amount (Actual Costs): $8,225; 
Frequency of Receipt: Monthly Updates. 

Agencies that Received the Full File in FY 2012: Department of 
Veterans Affairs (VA); 
FY 2012 Reimbursement Amount (Actual Costs): See Note 1 below; 
Frequency of Receipt: Full File Annually and Weekly Updates. 

Agencies that Received the Full File in FY 2012: Internal Revenue 
Service (IRS); 
FY 2012 Reimbursement Amount (Actual Costs): $74,751; 
Frequency of Receipt: Full File Annually and Weekly Updates. 

Agencies that Received the Full File in FY 2012: Office of Personnel 
Management (OPM); 
FY 2012 Reimbursement Amount (Actual Costs): See Note 2 below; 
Frequency of Receipt: Full File Annually and Weekly Updates. 

Notes: 

1. Pursuant to section 5106 of title 38, United States Code, we 
provide the full DMF annually and with weekly updates to the VA at no 
cost. 

2. OPM does not pay for access to the full DMF, which we provide 
annually and with weekly updates. Instead, we exchange information in 
a reciprocal relationship using matching agreements. 

3. Pursuant to section 716 of title 31, United States Code, GAO has 
authority to obtain the full file for investigative purposes. We 
provide the file to GAO upon request and without reimbursement. 

4. Our agreement with DoD, DMDC allows it to receive the full file 
annually, plus monthly updates, DoD, DMDC's systems are not configured 
to receive files as large as the annual full file. Once DoD, DMDC is
able to receive the full file, we will begin transmitting it to them 
and will reconcile our estimated and actual costs. 

5. Our Reimbursable Agreements stipulate that we are reimbursed on a 
quarterly basis for the cost incurred for providing the information 
requested. At least quarterly, the parties will reconcile balances 
related to revenue and expenses for work performed. 

[End of table] 

Table: Death Master File Customers FY 2014: 

Customer: RRB; 
Version: Public + State; 
Frequency: Monthly updates; 
Estimated Cost: $8,289. 

Customer: GAO; 
Version: Public + State; 
Frequency: Monthly updates; 
Estimated Value: $8,289; 
No Cost. 

Customer: Federal Retirement Thrift Investment Board; 
Version: Public + State; 
Frequency: Monthly updates & 1 full file; 
Estimated Cost: $30,422; 
Comments: Partial Year Estimate. 

Customer: DoD, DMDC; 
Version: Public + State; 
Frequency: Monthly updates & 1 full file; 
Estimated Cost: $31,804. 

Customer: CMS; 
Version: Public + State; 
Frequency: Weekly updates; 
Estimated Cost: $33,740. 

Customer: IRS; 
Version: Public + State; 
Frequency: Weekly updates & 1 full file; 
Estimated Cost: $57,254. 

Customer: Pension Benefit Guaranty Corporation; 
Version: Public + State; 
Frequency: Weekly updates & 1 full file; 
Estimated Cost: $57,254. 

Customer: VA; 
Version: Public + State; 
Frequency: Weekly updates & 1 full file; 
Estimated Value: $57,254; 
Comments: No Cost. 
 
Customer: OPM; 
Version: Public + State; 
Frequency: Weekly updates & 1 full file; 
Estimated Value: $57,254; 
Comments: Reciprocal Exchange. 

Customer: National Technical Information Service; 
Version: Public; 
Frequency: Monthly & weekly updates & 4 full files; 
Estimated Cost: $126,827. 

Notes: 

1. Last updated September 30, 2013. 

2. There are two DMF versions, Public + State and Public. By law, we 
may only disclose death data received from the States to those Federal 
benefit-paying agencies. 

[End of table] 

Appendix II Footnotes: 

[1] GAO, Social Security Administration: Preliminary Observations on 
the Death Master File, [hyperlink, 
http://www.gao.gov/products/GAO-13-574T] (Washington, D.C.: May 8, 
2013) 

[2] Although not a Social Security Administration legislative 
proposal, the President's fiscal year 2014 Budget includes an increase 
of $22 million in Public Health Service Evaluation transfers for the 
Vital Statistics System supported within the Centers for Disease 
Control and Prevention (CDC). The intent of the provision is to allow
CDC to gradually phase in electronic death records in the 21 remaining 
jurisdictions over 4 years. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

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. 

[End of section] 

Related GAO Products: 

GAO, Farm Programs: USDA Needs to Do More to Prevent Improper Payments 
to Deceased Individuals, [hyperlink, 
http://www.gao.gov/products/GAO-13-503] (Washington, D.C.: June 28, 
2013). 

GAO, Management Report: Improvements Are Needed to Enhance the 
Internal Revenue Service's Internal Controls, [hyperlink, 
http://www.gao.gov/products/GAO-13-420R] (Washington, D.C.: May 13, 
2013). 

GAO, Social Security Administration: Preliminary Observations on the 
Death Master File, [hyperlink, 
http://www.gao.gov/products/GAO-13-574T] (Washington, D.C.: May 8, 
2013). 

[End of section] 

Footnotes: 

[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. 

[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. 

[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. 

[5] Unless otherwise specified, in this report we refer to these 
benefits collectively as "Social Security benefits." 

[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). 

[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, [hyperlink, 
http://www.gao.gov/products/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. 

[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). 

[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. 

[19] 42 U.S.C. § 405(r)(1)-(2). 

[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. 

[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. 

[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. 

[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. 

[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. 

[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 non-beneficiary 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. 

[32] [hyperlink, http://www.gao.gov/products/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. 

[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). 

[37] However, the agency determined it would instead seek out less 
costly sources of the data. 

[38] GAO, Social Security Disability: Management Controls Needed to 
Strengthen Demonstration Projects, [hyperlink, 
http://www.gao.gov/products/GAO-08-1053] (Washington, D.C.: Sept. 26, 
2008). 

[39] NTIS distributes a range of federally-funded scientific and 
technical information. 

[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). 

[42] [hyperlink, http://www.gao.gov/products/GAO-13-503]. 

[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 

[44] GAO, Government Operations: Standards for Internal Controls in 
the Federal Government, [hyperlink, 
http://www.gao.gov/products/GAO/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. 

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

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

[47] 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. 

[End of section] 

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