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Quality Control Systems Corporation
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Important Changes to the SSA's
Death Master File
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Expanding Secrecy Propagates Errors in the Death Master File In a very remarkable change in policy, the Social Security Administration (SSA) has indicated it will now keep secret errors in the historical, public Death Master File (DMF) that has been widely available to the public for decades. These now-secret mistakes were made on the basis of "protected" data submitted to the agency by states. Apparently, the new, official position of the SSA is that such information is exempt from disclosure under the Freedom of Information Act (FOIA). Some of these errors in the DMF 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 because the DMF publicly declares them as dead. Among the worst consequences, these errors can also result in the targeting of innocent victims in investigations of potential fraud. Breaking with past practice, persons affected by these errors should no longer expect corrections by the SSA through automatic file updates to the public version of the DMF, even though the SSA might acknowledge such mistakes to these persons individually. Subscribers to updates of the public DMF should not depend on the SSA to identify such errors for correction through file updates, even though the SSA itself would be aware of the mistake and would correct its own internal version of the file. Updating the Death Master File Since the 1930s, deaths of Social Security number holders have been reported to the SSA. These reports are compiled in a version of the DMF that is widely available from the National Technical Information Service by subscription. This database's principal function is to terminate benefits. Because the DMF is a public resource, it has numerous secondary uses. Pension funds, financial institutions, and law enforcement agencies rely on it extensively to detect fraud. The SSA faces difficult challenges to the accuracy of the DMF from a large population of people who move, change names, change the spelling of their names, or misreport their dates of birth. The SSA recognizes these problems and has detailed procedures for deleting records from its own, internal version of the DMF when it determines persons are incorrectly included. The policy to keep some of these errors secret and uncorrected in the public version of the DMF is recent and unprecedented. On-going DMF subscribers receive regular updates to the file, including listings of records to be deleted. For the last quarter of 2010 and the first three quarters of 2011, 2,749,774 updates to the file (as accumulated on a quarterly basis from monthly updates) were distributed to subscribers: 1,840,347 of these were additions of new records; 899,033 were corrections to existing records; and 10,394 updates indicated deletions to the file. The later category covers 10,329 unique cases of individuals incorrectly reported as deceased in one year. 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 exposed 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 as soon as they are known. SSA's Shifting Legal Position The SSA now plans to eliminate more than a third of the records in the periodic additions, corrections, and deletions to the DMF it issues for subscribers, beginning on November 1, 2011. It is stated that this change was brought about by a recent review of the public DMF and a subsequent determination that the SSA can no longer disclose "protected State records," which are a source of some of the updates to the file. This change will make it impossible for private users of the DMF to correct this category of errors in the existing, historical database, since these errors will not be included in the updates to the file that are sent to private subscribers. This is a surprising revision to a long-standing, public policy to share these data. According to Congressional testimony in 2001, it was then the SSA's position that the public DMF never disclosed protected State records, only SSA data: "The publicly available DMF, which is the version that has no state data, is provided monthly to the Department of Commerce, National Technical Information Service (NTIS) which in turn makes it available to the public under the Freedom of Information Act... Once death reports received from States are verified, the state data is then considered SSA data... Therefore, if SSA is providing death information to other parties we are careful that the information that we release is SSA data." Living with The Consequences Fixing errors in the widely used, public version of the DMF depends on the continued, timely, public availability of all DMF records needing corrections and deletions. If the announced policy is implemented without change, future deletions to the public DMF through updates to DMF subscribers will not include an unknown number of records for persons who are actually living or whose records would otherwise be corrected. Keeping the identities of living persons listed in the historical, public Death Master File permanently secret will guarantee them a lifetime of adverse consequences. The change will also have a large impact on the effectiveness of the DMF as a tool to detect the fraudulent use of SSNs of persons known to be deceased. It is planned that new additions to the DMF beginning in November, 2011 will shrink by more than a third. This means that the identities of about 1 million persons annually whose deaths become known to the SSA on the basis of the "protected State records" will be kept secret by the SSA and not made part of the public DMF. Not only new additions will be affected. The SSA also plans to establish a new version of the full, public DMF in which about 5 percent of the previously available records will have been removed. The coverage of the DMF and, therefore, its effectiveness as a tool in combating fraud and identity theft will be correspondingly diminished. We have been officially informed by SSA that the change in policy will have "no impact on the capability of anyone to correct errors in the Public DMF." The risk is that decision-makers in the SSA will continue to act as if this official statement were true. Email inquiries or questions: [Updated November 20, 2011 - See our web page, Risk Management At Risk, for a partial solution to problems caused through the loss of coverage by the new version of the Death Master File.] |
Link to:
Fraud Detection and Identify Validation Simulation Studies of Social Security Number Validation
The American Financial |
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