At Exclusion Screening, we often receive questions about the scope and frequency of an organization’s screening duties and responsibilities. One question in particular that we are regularly asked is whether an organization has an affirmative obligation to screen employees, agents, and contractors against the Social Security Administration’s Death Master File (Death Master File).[1] As in the case of many Medicare and Medicaid regulatory obligations – it’s complicated. In this article, we examine the Death Master File and the role it plays in protecting the financial integrity of federal health benefit programs and the patients they serve.[2]
I. What is the Social Security Administration Death Master File?
The Social Security Administration (SSA) master files contain, among other things, a registry of all Social Security beneficiaries (along with their assigned Social Security Numbers) issued by the government since 1936.[3] The Death Master File is a subset of the files contained in SSA’s “Numerical Identification System” or “Numident” database, which is itself a subset of the entire SSA master file collection. Numident contains the applications for social security numbers (the SS-5s) in addition to death and claim records, and the Death Master File is limited to the death records contained therein.
When an individual who qualifies for Social Security passes away, his or her death is generally reported to the Social Security Administration by either the decedent’s family, a funeral parlor or a government agency. The death record is then made a part of the Numident database and added to the Death Master File.
II. Who Has Access to the Social Security Administration Death Master File?
A. Full Death Master File Information.
The full or complete file of death information maintained by the Social Security Administration (which includes state death records), is not limited to only the information of Social Security Number holders. Importantly, the Social Security Administration only shares the full or complete Death Master File with federal and state agencies that are able to show a legitimate need[4] for the information and can explain how the information will be used. The primary federal agencies receiving a copy of the full Death Master File information include:[5]
- U.S. Government Accountability Office.
- Centers for Medicare & Medicaid Services.
- Department of Defense.
- Department of Veterans Affairs.
- Internal Revenue Service.
- Department of Agriculture.
- Department of Housing and Urban Development.
- Federal Retirement Thrift Investment Board.
- Office of Personnel Management.
- Pension Benefit Guaranty Corporation.
- National Institutes of Health.
- Railroad Retirement Board.[6]
B. Limited or Public Death Master File Information.
An abbreviated set of beneficiary death records maintained by the Social Security Administration has been held to be within the public domain. As such, a limited version of this information has been made available to the public[7] under the Freedom of Information Act (FOIA).[8] The limited Death Master File information available to the public includes only the basic death information associated with individuals who have been assigned a Social Security Number prior to his or her death. This information includes each deceased individual’s:
- Social Security Number.
- First Name.
- Middle Name.
- Surname.
- Date of Birth.
- Date of Death.
The limited version of the Death Master File information that has been made available to the public does not include state death records. Unfortunately, the Social Security Administration does not have a readily accessible database of death records. Instead, it has made this information available through the Department of Commerce’s National Technical Information Service (NTIS). The Social Security Administration makes regular updates to the database on a weekly and monthly basis. The NTIS sells this information to “Certified” public and private subscribers.
C. Exclusion Screening is a “Certified” Subscriber to the Death Master File Database.
Exclusion Screening is one of only a limited number of private entities that have completed the certification program[9] managed by NTIS and have been granted access to the limited Death Master File. As the agency has noted, the certification program (and its associated fees) was established pursuant to Section 203 of the “Bipartisan Budget Act of 2013” (Pub. L. 113-67). As a certified subscriber, Exclusion Screening may only use the information for an approved purpose. In this case, the Death Master File database is used to identify individuals who may be committing identity theft in order to facilitate Medicare or Medicaid fraud.
III. Problems with the Death Master File:
The Social Security Administration’s Death Master File is a critical tool used to identify and/or prevent identity and financial fraud. Unfortunately, over the years, a number of concerns have arisen about the completeness and accuracy of this database. Several of the reasons for the incompleteness and inaccuracies identified with the Death Master File are outlined below.
A. Reporting Delays.
One significant factor contributing to the Death Master File’s incompleteness is the delayed reporting of deaths. The Social Security Administration relies on various sources to update its death records, including funeral homes, family members, and government agencies. Unfortunately, not all deaths are promptly reported, leading to gaps in the database. Delays can occur due to bureaucratic processes, clerical errors, or family members’ failure to report deaths in a timely manner.
B. Inconsistent and Inaccurate Reporting.
Deaths may be reported differently from jurisdiction to jurisdiction. State, county and city reporting practices may vary. Not surprisingly, this can lead to reporting inaccuracies and can make it difficult to verify specific cases which must be researched by law enforcement in fraud cases. Additionally, data entry errors can occur at various stages of the reporting process, from the initial documentation of a death to the submission of information to the Social Security Administration. Simple mistakes such as typographical errors or transposition of digits of an individual’s Social Security Number can lead to inaccuracies in the database. These errors can go unnoticed for an extended period, further compromising the database’s accuracy.
C. Data Quality and Verification
Maintaining accurate and complete records in the Death Master File requires stringent data quality checks and verification processes. Errors in the reporting of deaths, misspelled names, incorrect Social Security Numbers, and other discrepancies can lead to inaccuracies in the database. The Social Security Administration must invest significant resources in verifying and correcting data, but these efforts have not been sufficient to ensure the file’s accuracy.
D. Privacy Concerns.
Privacy concerns may also impact the Death Master File’s completeness. In response to privacy issues, the Death Master File was temporarily closed to the public in 2013. Access to the full file was restricted due to concerns about identity theft and fraud, preventing certain individuals and organizations from accessing up-to-date information. While this was a necessary measure to protect individuals’ personal information, it has hindered the Death Master File’s ability to serve its intended purposes effectively. Additionally, citing “personal reasons,” some families have requested that a deceased individual’s death not be included in the database. Finally, certain states have enacted laws limiting access to death records, which can hinder the Social Security Administration’s ability to maintain an accurate and comprehensive death database.
E. Incomplete Reporting of Non-U.S. Residents.
The Death Master File primarily focuses on tracking deaths of U.S. residents who are eligible for Social Security benefits. Deaths of non-U.S. residents, including tourists, foreign workers, and undocumented immigrants, may not be consistently reported or included in the database. This incomplete reporting skews the overall picture of mortality within the country, leading to gaps in the Death Master File.
IV. General Uses of the Death Master File:
The Death Master File serves as a vital resource for both public and private research purposes, but its completeness and accuracy have been an ongoing concern. Delayed reporting of deaths, variability in reporting methods, privacy concerns, data entry errors, administrative backlogs, and a lack of resources have all contributed to database inaccuracies. Despite these limitations, the Death Master File is regularly used by genealogists, health care providers and supplier organizations, insurance payors, medical researchers, financial institutions, credit firms, and fraud prevention entities.
V. The Death Master File as a Health Care Compliance Tool:
Despite its limitations, the Social Security Death Master File can be exceptionally useful from a healthcare compliance standpoint. There are two primary ways that the identities of deceased individuals can be used:
A. Provider Fraud Identification and Prevention.
In some cases, wrongdoers have improperly assumed the identity of a deceased healthcare provider. In others, wrongdoers have enlisted the assistance of another provider in order to improperly use his or her identity in order to illegally bill for services. In an effort to prevent these fraudulent schemes, a wide variety of health care related organizations (providers, suppliers, insurance payors, state board licensing officials, law enforcement agencies, etc.) currently utilize the Death Master File to screen for individuals who may be attempting to impersonate the identity of a deceased provider. Examples of fraudulent behavior that has occurred include, but are not limited to:
- Obtain employment using the Social Security Number, National Provider Identification (NPI) number or other information to assume the identity of a deceased healthcare provider.
- Seek credentialing with one or more public or private insurance payor plans using the identification information of a deceased provider.
- Bill for services, prescribe medications, or order durable medical equipment, etc. using the NPI or payor identification number of a deceased provider.
B. Improperly Using the Identification of a Beneficiary.
The Death Master File can also be helpful in identifying and preventing the misuse of a beneficiary’s Social Security Number or payor identification. This form of potentially fraudulent conduct can occur in multiple ways. For example:
- A number of providers have been accused of billing for services not rendered after submitting claims for services allegedly provided to deceased beneficiaries.
- There have also been instances where beneficiaries were incorrectly reported as deceased, when in fact, they are still alive. As you can imagine, such as mistake can impact the individual’s access to financial accounts and to health care.
- Individuals have been accused of impersonating the identity of a deceased relative or friend in order to qualify for medical care.
VI. Screening Against the Social Security Death Master File Reduces Your Level of Risk:
Regardless of whether you are affiliated with an insurance payor, a health plan, a state licensing body, a credentialing organization or a participating provider or supplier organization, screening against the Social Security Death Master File is yet another step you can take to enhance your overall regulatory compliance efforts. Coupled with your ongoing federal and state screening obligations, checking the Death Master File can add an entirely new dimension to your regulatory compliance efforts.
From a practical standpoint, it is next to impossible for you to monitor and screen providers and beneficiaries against the Social Security Death Master File. The government has readily recognized that healthcare providers may seek to delegate their screening obligation to a qualified vendor such as Exclusion Screening. For most healthcare providers, this is a cost-effective way of fulfilling their screening obligations. Having Exclusion Screening regularly screen your list can also provide a strong defense against the imposition of any penalties and damages associated with the submission of improper claims for services and supplies.
Need help? Call the experienced professionals at Exclusion Screening for a complimentary consultation to discuss your sanction monitoring needs. Exclusion Screening is the ONLY screening company developed by nationally recognized former Federal prosecutors[10] with your regulatory compliance needs in mind. We can be reached at: 1 (800) 294-0952.
[1] The Social Security Administration Death Master File is also commonly referred to as the Social Security Death Index (SSDI).
[2] The OIG describes a federal health care program as: “. . . any plan or program that provides health benefits, whether directly, through insurance, or otherwise, which is funded directly, in whole or in part, by the United States Government or a State health care program (with the exception of the Federal Employees Health Benefits Program) (section 1128B(f) of the Act). The most significant Federal health care programs are Medicare, Medicaid, Tricare and the Veterans programs.”
[3] The Social Security Act was enacted into law on August 14, 1935. Among its provisions, the Social Security Act created a new “Social Security Board.” Initially, the Social Security Board contracted with approximately 45,00 post offices around the country to distribute specific forms to employers in their district. These forms requested that employers complete a list of all of their employees and return the completed forms to their local post office. The completed employee lists were then used to assign a specific Social Security Number (SSN) to each individual.
[4] In order to share the information, the qualifying federal or state agency must meet the requirements set out under Section 205(r) of the Social Security Act. See 42 U.S.C. §405(r).
[5] A number of other federal agencies have obtained access to the limited version of the Death Master File from NTIS.
[6] Congressional Research Service, “The Social Security Administration’s Death Data: In Brief.” R46640 (December 15, 2020).
[7] It is worth noting that the publicly available, limited version of the Death Master File came about as a result of a court-mandated settlement in 1980. See Perholtz v. Ross, Civ. No. 78-2385 and 78-2386 (U.S. District Court for the District of Columbia 1980).
[8] The legislative and litigation history of the Freedom of Information Act (FOIA) is both extensive and complicated. A deeper dive into this statute will be covered in a separate, future article. The current amended codification of the Act is located at 5 U.S.C. Subchapter II, §552.
[9] NTIS established a certification program for those seeking access to the limited access Death Master File pursuant to §203 of the “Bipartisan Budget Act of 2013” (Pub.L.113-67).
[10] Both Robert W. Liles and Paul Weidenfeld (the founders of Exclusion Screening) served as Assistant U.S. Attorneys and were appointed to serve in Washington, DC as “National Health Care Fraud Coordinator” for the Executive Office for U.S. Attorneys, U.S. Department of Justice.