The Death Master File (DMF), a file extracted from the Social Security Administration’s (SSA) database of Social Security number holders, contains the death reports that SSA collects to administer its programs; the DMF has been a lightning rod for criticism for nearly a decade.1 SSA uses the death data it receives to determine eligibility for and termination of benefit payments . However, errors in the death-reporting process cause severe disruptions to the financial lives of those who are mistakenly reported as dead.
SSA shares the death data it collects with federal partners consistent with statutory requirements that are designed to improve program integrity and administration across the government . It also shares these data with the public following settlement in 1980 of a lawsuit against the agency.2 By spending significant amounts of its limited administrative budget to make its data collection more efficient and accurate, SSA has sought to protect the public from the adverse outcomes of reporting errors . Unfortunately it has been unable to guarantee accuracy in the deaths that it records, in part because of limitations on activities outside its mission of payment of benefits.3
Federal benefit-paying agencies, banks, identity authentication companies, and others rely on the death data SSA provides through the DMF, even though the agency obtains proof for only some of the death reports that it receives.4 Users of the DMF must sign an agreement with the National Technical Information Service (NTIS) that outlines SSA requirements designed to reduce the likelihood that erroneous death reports cause harm to living people,5 but not all signatories adhere to the rules . Occasionally, an erroneous death report wherein a living person is mistakenly reported to SSA as dead is entered into the DMF . The consequences for that person can be severe, including bank account closure, denial of credit or employment, and other actions causing significant economic hardships.
SSA pays state vital records agencies millions of dollars each year to obtain their automated death data.6 State-generated death data are generally viewed as more accurate7 and efficient for SSA to process and record than death reports from federal agencies and other sources. But SSA interprets Section 205(r) of the Social Security Act as barring it from sharing the costs it pays for state data (paid for from the trust funds) with other federal partners,8 and the same law prohibits SSA from sharing state data with the private sector and most non-benefit-paying federal agencies.9
Given the significant demands placed on SSA to administer its programs and the agency’s limited resources, as well as the limitations on its ability to share death data more broadly, SSA should not be responsible for collecting and disseminating death data to the entire federal government when there is another, better option.
The U.S. Department of the Treasury (Treasury) operates an online portal dedicated to preventing and detecting improper federal payments and is designed to provide such data—in real time— across the federal government.10 Congress created Treasury’s Do Not Pay (DNP) portal as a consolidated program-integrity tool to ensure the accuracy of all types of federal payments—not just federal benefit payments. Congress should shift responsibility for collection and dissemination of death data from SSA to Treasury’s DNP portal . It is appropriate to use general revenues, including those expended by DNP to fund the purchase of death data, because the data are useful across the government. In contrast, it is inappropriate to use revenues dedicated to paying Social Security cash benefits and covering the administrative costs of paying such benefits to fund an activity of general utility across the federal government.11
1 Joint Hearing before House Committee on Financial Services, Subcommittee on Oversight and Investigations and Committee on Ways and Means, Subcommittee on Oversight, Preventing Identity Theft by Terrorists and Criminals (prepared statement of the Honorable Sue W. Kelly, Chair, Subcommittee on Oversight and Investigations), Serial No. 107–50, 107th Congress, November 8, 2001, https://www.govinfo.gov/content/pkg/CHRG-107hhrg76259/html/CHRG-107hhrg76259.htm .
2 Hearing before House Committee on Ways and Means, Subcommittee on Social Security, Social Security’s Death Records (answer to question posed from Sam Johnson, Chair, Subcommittee on Social Security to Michael Astrue, Commissioner, Social Security Administration), Serial No. 112-SS13, 112th Congress, February 2, 2012, p. 10 https://www.govinfo.gov/content/pkg/CHRG-112hhrg78179/html/CHRG-112hhrg78179.htm .
3 Conference call with the Office of the Commissioner, October 25, 2017, meeting notes on file with the Social Security Advisory Board.
4 Social Security Administration, Program Operations Manual System, GN 02605.050.E. Reports of Death for Non-Beneficiaries, October 30, 2017 https://secure.ssa.gov/apps10/poms.nsf/lnx/0202602050.
5 Department of Commerce, National Technical Information Service, Limited Access Death Master File Non-Federal Subscriber Agreement Attachment B, March 25, 2014 https://classic.ntis.gov/assets/pdf/dmf-subscribeagrmt.pdf .
6 Email from Office of Retirement and Disability Policy, Social Security Administration, November 20, 2017. Email on file with the Social Security Advisory Board.
7 Social Security Administration, Office of the Inspector General, State Use of Electronic Death Registration Reporting, A-09-15-50023, July 2017, p. A-1 https://oig.ssa.gov/sites/default/files/audit/full/pdf/A-09-15-50023.pdf .
8 The Social Security Administration interprets “…the reasonable cost of carrying out such arrangement…” to mean that it is only allowed to seek reimbursement of the costs it incurs to create the extracted file for an agency, not for the cost of purchasing the data that makes up the file. The Social Security Act §205(r)(3)(A) https://www.law.cornell.edu/uscode/text/42/405.
9 The Social Security Act §205(r)(3)(A); 42 U.S.C. https://www.law.cornell.edu/uscode/text/42/405.
10 Department of Treasury, Bureau of the Fiscal Service, Do Not Pay Fact Sheet, August 7, 2018, p. 1, https://fiscal.treasury.gov/files/dnp/ DoNotPayFactSheet.pdf.
11 William R. Morton, “The Social Security Disability Insurance (DI) Trust Fund: Background and Current Status,” Library of Congress, Congressional Research Service, R43318, January 19, 2016, p. 3 https://greenbook-waysandmeans.house.gov/sites/greenbook.waysandmeans.house.gov/files/R43318%20-%20The%20Social%20Security%20Disability%20Insurance%20(DI)%20Trust%20Fund%20-%20Background%20and%20Current%20Status_1.pdf.