Following the Social Security Act, SSA removes the state-reported  records from the full DMF and provides the partial DMF to the Department  of Commerce’s National Technical Information Service (NTIS), which  reimburses SSA for the cost of providing the file and sells it through a  subscription service. SSA’s Procedures May Allow for Erroneous Death Information in the DMF

Our work to date has identified ways in which SSA’s procedures for  compiling and verifying death reports may affect the accuracy of death  reports in the DMF. According to SSA officials, SSA does not collect data on  the number of death reports submitted by each source. For example, if SSA first receives a death report  from a family member and subsequently receives an electronic report  from a state about the same individual, the original report is overridden  and SSA records only the state as the source of the death report. According to SSA officials, the agency only verifies death  reports for individuals currently receiving Social Security program benefits  because it is essential to its mission to stop payments to deceased  beneficiaries. Even then, SSA verifies only those reports from sources it  considers to be less accurate, such as financial institutions and other  federal agencies. Therefore, death reports for non-beneficiaries are not  verified (see table 1). SSA receives a death report from a post office based on a returned  Social Security benefit check noting the addressee is deceased. SSA does not verify  the death before recording it in the Numident record and subsequently  the DMF. Because there are a number of death reports that SSA does not verify,  the agency risks having erroneous death information in the DMF, such as  including living individuals in the file or not including deceased individuals. Specifically, for death reports that are not verified, SSA would not know  with certainty if the individuals reported as dead are, in fact, the ones who  are dead. SSA acknowledges these limitations and does not guarantee  the accuracy of the file. For example, decedents who were never assigned an SSN  cannot be matched to the Numident. Agencies’ Access to the DMF Depends on a Variety of Factors

A number of federal agencies access the DMF, but the conditions of  access vary widely due to legal and administrative factors. Currently, SSA shares the full DMF with six federal benefit- paying agencies which have requested access and which it has  determined meet the relevant legal requirements:
Centers for Medicare & Medicaid Services
Department of Defense (Defense Manpower Data Center)
Department of Veterans Affairs
Internal Revenue Service
Office of Personnel Management
Railroad Retirement Board  To address administrative conditions of access, these agencies have  established information exchange agreements to receive the full DMF. The Office of  Personnel Management similarly does not reimburse SSA because it  provides other data to SSA, and the agencies have agreed that the  expenses involved in the exchanges are reciprocal. A number of other federal agencies purchase only the partial DMF that is  publicly available from NTIS. Several of these pay federal benefits,  including the Department of Labor’s Energy Employees Occupational  Illness Compensation Program, which provides compensation and health  benefits to eligible Department of Energy workers and certain survivors. According to SSA officials, the  partial DMF has about 10 percent fewer records than the full DMF due to  the removal of state-reported deaths. As a  result, any benefit-paying agency relying on the partial DMF to help  identify deceased program participants may be missing death records for  some of its beneficiaries because it has access to only about 87 million of  the 98 million records in the full DMF. In response to agencies’ requests, SSA makes determinations  about agencies’ statutory eligibility on a case-by-case basis. However,  SSA officials said they were not aware of written standards or guidelines  to follow in determining which federal agencies meet statutory  requirements. In contrast, SSA  officials said that the agency has determined that the Department of the  Treasury would not be eligible to receive the full DMF for the purposes of  administering the Do Not Pay Initiative. In summary, SSA’s death information can serve as a helpful tool in  preventing improper payments, but can only do so if it is accurate and  accessible to federal agencies that need it.
Why GAO Did This Study

As the steward of taxpayer dollars, the federal government is accountable for safeguarding against improper payments--those that should not have been made or that were made in an incorrect amount. One tool federal agencies can use to do this is the DMF, which is a file containing records of deceased individuals who are SSNholders. Through data matching, federal benefit-paying agencies can use the DMF to alert them of deceased benefit recipients. However, the SSA Office of Inspector General and others have identified inaccuracies in the DMF, including deceased individuals who were not listed in the file. Such inaccuracies could adversely affect its usefulness to federal agencies.
This testimony addresses preliminary observations on (1) SSA's process for handling death reports for inclusion in the DMF, and (2) federal agency access to the DMF. In addressing these objectives, we interviewed SSA officials regarding how the agency obtains death reports and maintains the DMF; reviewed applicable federal laws, SSA procedures, and reports; interviewed representatives of organizations that report deaths to SSA; and interviewed officials at other federal agencies that use the DMF.

What GAO Found

The Social Security Administration's (SSA) procedures for handling and verifying death reports may allow for erroneous death information in the Death Master File (DMF) because SSA does not verify certain death reports or record others. SSA officials said, in keeping with its mission, the agency is primarily focused on ensuring that it does not make benefit payments to deceased Social Security program beneficiaries. As a result, it only verifies death reports received for individuals who are current program beneficiaries, and even then, only for those reports received from sources it considers to be less accurate. For example, SSA officials consider death reports from states that have pre-verified decedents' name and SSN to be highly accurate, so SSA does not verify that the subjects of these reports are actually deceased. It would, however, verify a report received from a source such as a post office. SSA verifies no death reports for individuals who are not beneficiaries, regardless of source. Because there are a number of death reports that SSA does not verify, the agency risks including incorrect death information in the DMF, such as including living individuals in the file or not including deceased individuals. Specifically, for death reports that are not verified, SSA would not know with certainty if the individuals are correctly reported as dead. SSA also does not record some deaths because incorrect or incomplete information included in death reports generally prevents SSA from matching decedents to SSA records. For example, if SSA is unable to match a death report to data in its records such as name and Social Security Number (SSN), it generally does not follow up to correct the non-match and does not record the death.
A number of federal agencies access the DMF for the purpose of matching it against data in their files, but the conditions of access depend on a variety of legal and other factors. Currently SSA shares a full version of the DMF with six federal agencies that it has determined meet legal requirements for accessing the file, which include being an agency that pays federal benefits. By law, SSA can require reimbursement for the cost of sharing the data, however various factors affect what the agencies actually pay. The Department of Veterans Affairs and the Office of Personnel Management pay nothing to receive the file, whereas the Department of Defense annually pays more than $40,000. A number of other federal agencies--including several that administer programs that pay benefits-- purchase a partial version of the DMF that is publicly available through the Department of Commerce's National Technical Information Service (NTIS). NTIS reimburses SSA for receipt of the file. The partial DMF does not include statereported data and, according to SSA officials, has about 10 percent fewer records than the full DMF (roughly 87 million, compared to 98 million). Thus, agencies accessing this version of the file, such as the Department of Labor's Energy Employees Occupational Illness Compensation Program, may be missing deceased program participants. If agencies want access to the full DMF, they must formally request it. SSA makes determinations about their eligibility on a case-by-case basis. SSA officials said they were not aware of written standards or guidelines to follow in making these determinations.

What GAO Recommends

The work is ongoing and GAO has no recommendations at this time. GAO plans to issue its final report later in 2013.