GAO has noted  the value of using this information for guarding against improper  payments. Recent legislative proposals have also sought to  encourage federal agencies to use SSA’s death information. 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. 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. 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. They did not think these types of  errors would have resulted in improper benefit payments because they  involved persons recorded as deceased. 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. 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. 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. Agencies can purchase a DMF subscription  through the Department of Commerce’s National Technical Information  Service (NTIS), which reimburses SSA for the cost of providing the file.In accordance with the Act, SSA excludes state-reported death records  from the DMF. 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. 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). 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. 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. 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. 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. 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. 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. 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. To evaluate SSA’s processes for  obtaining, processing, and sharing death information, we reviewed  standard criteria, such as the Standards for Internal Controls in the   We performed independent testing of SSA’s death  Federal Government.data to identify specific types of errors such as dates of birth that followed  dates of death. 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).
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.