Statutory Changes to the SSA's Death Master File
Ensure Permanent, Damaging Data Errors
Download part of a related
Expanding Secrecy Freezes Errors in Existing Versions of the Death Master File
Since the 1930s, deaths of Social Security number holders have been reported to the Social Security Administration (SSA) from a variety of sources. These reports are compiled in a "Death Master File" (DMF) that is available from the National Technical Information Service (NTIS) by subscription.
The principal function of the DMF is to terminate benefits. Because the DMF was a widely available, public resource until 2014, it has had numerous secondary uses. Pension funds, financial institutions, and law enforcement agencies rely on it extensively to detect fraud.
Through enactment of the Bipartisan Budget Act of 2013, reports of deaths occurring less than three years prior to inclusion in the DMF will only be available to a subset of current subscribers to the DMF beginning in March 2014. These users must be certified to have "appropriate" purposes pursuant to the new statute. Such users must also agree to unscheduled audits by government agents and to pay fees for their certification and for the auditing program itself.
A remarkable side effect of the Bipartisan Budget Act is to deny many existing users of the DMF timely access to notification of errors in the database. These errors include the listing of living persons as deceased. This type of mistake renders such persons vulnerable to the loss of private pension and insurance benefits, an inability to obtain credit, to open financial accounts, or to obtain employment.
Persons affected by these errors can no longer expect corrections by the SSA through automatic file updates to historical, public versions of the DMF, even though the SSA might acknowledge such mistakes to these persons individually. This change represents an expansion of SSA's 2011 policy reversal that reclassified a subset of data in existing versions of the DMF as "protected state records."
The number of persons potentially affected is not inconsequential. For the 90 day period ending on January 3, 2014, publicly available updates to the DMF contained record deletions involving 1,585 persons likely to be alive. What cannot be known with any certainty is the number of queries involving a cohort of about this size that might be run against historical versions of the DMF that cannot be corrected until March, 2017. Over the longer term, many DMF users might never correct their files after being cut off from regular updates to the DMF for a period of three years and if the costs of the updates then become prohibitive.
A Lifetime of Adverse Consequences
The SSA urges DMF subscribers "not to take any adverse action against any individual without further investigation to verify any death listed." However, at the very least, erroneously listed individuals are vulnerable to potential identity theft by the public disclosure of their full name, date of birth, and social security number. It is of great importance that these errors be corrected and made available to all users of the DMF, including users of historical versions of the database, as soon as they become known to the SSA.
The National Technical Information Service has declared that, "It is mandatory that all subscribers of the DMF intending to use its data on a continuing basis must, after receiving an updated complete SSA DMF Full File, keep that file updated by purchasing a subscription." Yet the current law makes it impossible for many existing DMF users to update their files. Epidemiologists are seriously affected. These scientists cannot be certified users of the DMF because lawmakers did not deem science a "legitimate" purpose for the database.
Most remarkably, the NTIS places responsibility for error correction on the victims of the errors. The NTIS envisions a process whereby these persons will present letters from the SSA attesting to the data errors in the DMF to the DMF's users. Yet these victims cannot possibly know all of the users of the DMF who might have versions of the file that have errors involving them personally.
Keeping known errors secret and uncorrected in versions of the DMF that are widely distributed and in long-term use may well result in the targeting of innocent persons in investigations of potential fraud. Many other adverse consequences are easily foreseeable. These damaging effects will last a lifetime without a practical mechanism to correct errors that are known by the Social Security Administration to exist in historical versions of the Death Master File.
Email inquiries or questions:
Copyright © Quality Control Systems Corp. All rights reserved.