Audit Report
Match of California Death
Information Against Social
Security Administration Records
A-06-18-50706 | September 2021
MEMORANDUM
Date:
September 24, 2021
Refer To: A-06-18-50706
To:
Kilolo Kijakazi
Acting Commissioner
From:
Gail S. Ennis,
Inspector General
Subject:
Match of California Death Information Against Social Security Administration Records
The attached final report presents the results of the Office of Audit’s review. The objectives
were to (1) determine whether the Social Security Administration made payments to
beneficiaries and/or representative payees who were deceased according to California records
and (2) identify non-beneficiaries in the State files whose death information did not appear in
Agency records.
If you wish to discuss the final report, please contact Michelle L. Anderson,
Assistant Inspector General for Audit.
Attachment
Match of California Death Information Against Social
Security Administration Records
A-06-18-50706
September 2021 Office of Audit Report Summary
Objective
To (1) determine whether the Social
Security Administration (SSA) made
payments to beneficiaries and/or
representative payees who were
deceased according to California
Department of Public Health records
and (2) identify non-beneficiaries in the
State files whose death information did
not appear in Agency records.
Background
To identify and prevent payments after
death, SSA established a program
under which States can voluntarily
contract with SSA to provide it death
data to match against its records.
Through the Electronic Death
Registration (EDR) system, States
electronically submit death reports to
SSA. If the decedent’s data match
SSA records, SSA posts the State
death information to its Numident file
and terminates payments to deceased
beneficiaries. SSA receives death
information from other sources, such
as family members and funeral
directors.
We obtained data files that provided
the personally identifiable information
of 16.1 million individuals the
California Department of Public Health
recorded as deceased from January
1905 through December 2017. We
matched the data against SSA
records.
Findings
We identified 386 beneficiaries whose personally identifiable
information matched that of a deceased individual in the California
death data files. SSA terminated or suspended payments to 245 of
these beneficiaries but issued approximately $21.3 million in
payments after these beneficiaries’ deaths. Identification and
termination or suspension of these payments prevented an
additional $3.3 million in improper payments over 12 months. SSA
also determined that 89 beneficiaries were alive at the time of our
audit.
SSA is reviewing payments to 52 additional beneficiaries who
appear to be deceased. Based on other deceased beneficiary
case referrals, we estimate 38 of the 52 beneficiaries are
deceased, SSA has issued $8.3 million in payments after their
deaths, and identification and termination of these payments will
prevent approximately $600,000 in additional improper payments
over 12 months. We did not identify any deceased representative
payees receiving SSA payments.
We also identified 438,860 non-beneficiaries who were deceased
according to California Department of Public Health records but
whose death information was not in SSA’s Numident. In
September 2020, we provided these records to SSA. Resolving
these discrepancies will improve the accuracy and completeness
of death information the Agency shares with other Federal benefit-
paying agencies.
We did not determine why the death information was not in SSA’s
Numident or whether the State reported the deaths to SSA. SSA
rejects EDR death reports that do not pass its formatting and
identification tests, so it does not post erroneous data to its
records.
Recommendations
We made four recommendations for corrective action. SSA agreed
with our recommendations.
Match of California Death Information Against SSA Records (A-06-18-50706)
TABLE OF CONTENTS
Objective ..................................................................................................................................... 1
Background ................................................................................................................................. 1
Results of Review ....................................................................................................................... 2
Payments Issued After Death ................................................................................................ 2
Death Verification Process Continues ................................................................................... 4
Deceased Non-beneficiaries ................................................................................................. 4
Recommendations ...................................................................................................................... 4
Agency Comments ...................................................................................................................... 5
– Scope and Methodology .................................................................................. A-1
– Agency Comments........................................................................................... B-1
Match of California Death Information Against SSA Records (A-06-18-50706)
ABBREVIATIONS
C.F.R. Code of Federal Regulations
EDR Electronic Death Registration
OIG Office of the Inspector General
POMS Program Operations Manual System
Pub. L. No. Public Law Number
SSA Social Security Administration
Stat. Statues at Large
U.S.C. United States Code
Match of California Death Information Against SSA Records (A-06-18-50706) 1
OBJECTIVE
Our objectives were to (1) determine whether the Social Security Administration (SSA) made
payments to beneficiaries
1
and/or representative payees
2
who were deceased according to
California Department of Public Health records and (2) identify non-beneficiaries
3
in the State
files whose death information did not appear in Agency records.
BACKGROUND
In May 2021, SSA paid 70 million beneficiaries approximately $98 billion under the Old-Age,
Survivors and Disability Insurance and Supplemental Security Income programs.
4
Under these
programs, payment to a beneficiary terminates when the individual dies.
5
To identify and prevent payments after death, the Social Security Act
6
requires that SSA
establish a program under which States can voluntarily contract with SSA to provide it death
data to match against its records. Accordingly, SSA and the States developed the Electronic
Death Registration (EDR) process to improve the accuracy and timeliness of death information.
Through EDR, States electronically submit death reports to SSA, and SSA verifies the Social
Security number online and in real-time. If the decedent’s data match SSA records, SSA
automatically posts the State death information to the Numident, an electronic data file that
contains information for each individual issued a Social Security number, and terminates
payments to deceased beneficiaries. In addition to EDR, SSA receives death information from
other sources, such as family members and funeral directors. SSA uses Numident information
to create a file of death information it shares with other Federal benefit-paying agencies.
7
We obtained data files that provided the personally identifiable information of 16.1 million
individuals the California Department of Public Health recorded as deceased from January 1905
through December 2017. We matched the death data against SSA’s payment records to
identify beneficiaries and a representative payee whose personally identifiable information
matched that of deceased individuals. We obtained death certificates, as needed, for these
beneficiaries and provided the certificates to our Office of Investigations and SSA, as
appropriate. We also matched the death data against the Numident to identify non-beneficiaries
whose death information was not in SSA’s system. See Appendix A for information on our
scope and methodology.
1
We use the term “beneficiary” throughout this report in reference to Old-Age, Survivors and Disability Insurance
beneficiaries and/or Supplemental Security Income recipients in current payment status.
2
SSA appoints a representative payee to receive and manage benefit payments when SSA determines it serves the
individual’s best interest regardless of legal competency or incompetency of the individual. Social Security Act,
42 U.S.C. §§ 405(j) and 1383(a)(2)(A)(ii) (govinfo.gov 2018).
3
“Non-beneficiaries” refers to deceased individuals who were not in current payment status as of June 2019.
4
SSA, Monthly Statistical Snapshot, May 2021.
5
20 C.F.R. §§ 404.311(b), 404.316(b)(1), and 416.1334 (govinfo.gov 2020).
6
42 U.S.C. § 405(r)(1) (govinfo.gov 2018).
7
Examples of other Federal agencies include the Railroad Retirement Board, Centers for Medicare & Medicaid
Services, Internal Revenue Service, Department of Veterans Affairs, and Office of Personnel Management.
Match of California Death Information Against SSA Records (A-06-18-50706) 2
RESULTS OF REVIEW
We identified 386 beneficiaries whose personally identifiable information matched that of a
deceased individual in the California death data files.
8
SSA
Determined 89 beneficiaries were alive at the time of our audit.
9
Terminated or suspended payments to 245 beneficiaries whose personally identifiable
information matched that of deceased individuals in the California death data. SSA issued
approximately $21.3 million in payments after these beneficiaries’ deaths. Identification and
termination/suspension of these payments prevented an additional $3.3 million in improper
payments over 12 months.
Is reviewing payments to 52 beneficiaries. Based on SSA’s experience with the other
deceased beneficiary case referrals, we estimate 38 of the 52 beneficiaries are deceased,
10
SSA issued $8.3 million in payments after their deaths, and identification and termination of
these payments will prevent approximately $600,000 in additional improper payments over
12 months.
We also identified 438,860 non-beneficiaries who were deceased according to California
Department of Public Health records but whose death information was not in SSA’s Numident
and provided these records to SSA in September 2020. Resolving these discrepancies will
improve the accuracy and completeness of death information the Agency shares with other
Federal benefit-paying agencies.
We did not determine why this death information was not in SSA records or whether the State
had previously reported the deaths to SSA. However, SSA rejects EDR reports that do not pass
its formatting and identification tests to prevent posting erroneous death data to its records.
11
We issued a separate report that assessed SSA’s rejection of State-submitted EDR reports.
12
Payments Issued After Death
SSA has suspended or terminated payments to 245 beneficiaries whose personally identifiable
information matched that of deceased individuals in the California death data.
SSA confirmed 196 beneficiaries were deceased, terminated their benefits, and initiated
recovery of $13.6 million in payments issued after the beneficiaries’ deaths. For example, a
8
We did not identify any payments issued to deceased representative payees.
9
In 77 cases, the beneficiaries remained in current payment status after SSA confirmed they were alive. In the other
12 cases, SSA records indicated the beneficiaries were alive at the time of our review but subsequently died. SSA
terminated the beneficiaries’ payments and input more recent dates of death in its records than appeared on
California death certificates.
10
In 89 (26.6 percent) of 334 referrals, SSA determined the beneficiaries were alive. Applying this percentage to the
52 cases under review indicates 14 beneficiaries are alive and 38 beneficiaries are deceased.
11
We do not assert the EDR process is the exclusive cause of unrecorded deaths on SSA records.
12
SSA, OIG, The Social Security Administration’s Rejection of State Electronic Death Registration Reports,
A-08-18-50499 (September 2020).
Match of California Death Information Against SSA Records (A-06-18-50706) 3
retirement beneficiary died in May 2008. SSA records did not contain a date of death and
therefore the benefit payments continued. SSA determined it issued $270,359 in payments
after death before it terminated the payments in August 2020.
SSA or our Office of Investigations verified 16 beneficiaries were deceased, but SSA had
not quantified payments issued after death. This occurred primarily because, after SSA
input the beneficiaries’ date of death on the Numident, SSA suspended benefit payments or
terminated payments for reasons other than the beneficiaries’ death. This prevented SSA
systems from identifying and initiating collection on approximately $1.2 million in payments
after death. At least eight cases appear to have involved identity theft.
13
For example, a
child died in the 1950s. In 2008, SSA approved an SSI claim filed by someone using the
deceased child’s personally identifiable information. SSA issued the recipient approximately
$100,000 in SSI payments before it terminated the payments in January 2021. However, no
overpayment appears on the recipient’s payment record.
SSA suspended payments to 33 beneficiaries up to 19 months ago
14
but did not input the
beneficiaries’ death information in its records, which prevented SSA systems from identifying
and initiating collection on approximately $6.5 million in payments after death. For example,
a retirement beneficiary died in July 2006. The beneficiary’s daughter reported the death to
the State of California. The decedent’s death certificate lists the same residential address
that appears on the beneficiary’s payment record. SSA issued approximately $300,000 in
payments after death before it suspended the benefit payments in July 2020.
We estimate identification and termination or suspension of these payments prevented
approximately $3.3 million in additional improper payments over 12 months.
15
California began reporting death information through the EDR process in December 2005. Yet,
as illustrated in Table 1, approximately 80 percent of the deceased beneficiaries whom SSA
improperly paid died after California began reporting deaths through EDR.
16
Table 1: Beneficiaries Whose Personally Identifiable Information Matched
that of a Deceased Individual in the California Death Data
Year of Death
Number of
Beneficiaries
Percent of Total
Beneficiaries
1940 Through 2005
48
20
2006 Through 2017
197
80
Total
245
100
13
In these cases, individuals applied for benefits using the personally identifiable information of numberholders who
were already deceased (the actual numberholders died from 1944 to 1969).
14
SSA suspended: 8 beneficiaries’ payments from February through September 2020; 1 beneficiary’s payments in
April 2021; and 24 beneficiaries’ payments in August or September 2021.
15
We based this estimate on the assumption that conditions will remain the same for 12 months.
16
SSA issued payments after death to less than .01 percent of the 16 million individuals who were deceased
according to the California Department of Health.
Match of California Death Information Against SSA Records (A-06-18-50706) 4
Death Verification Process Continues
SSA and our Office of Investigations are reviewing the appropriateness of continued payments
to 52 beneficiaries whose personally identifiable information matched that of a deceased
individual in the California death data. Based on SSA’s experience with other deceased
beneficiary case referrals, we estimate 38 of the 52 beneficiaries are deceased,
17
SSA issued
$8.3 million in payments after their deaths, and identification and termination of these payments
will prevent approximately $600,000 in improper payments over 12 months.
Deceased Non-beneficiaries
We identified 438,860 non-beneficiaries
18
who were deceased according to California
Department of Public Health records but who did not have death information in SSA’s Numident.
As shown in Table 2, approximately 99 percent of these individuals died before the State began
reporting death information via EDR in December 2005.
Table 2: Non-beneficiaries by Year of Death
Year of Death
Number of Non-
Percent of Total
Non-beneficiaries
1940 Through 2005
98.9
2006 Through 2017
1.1
Total
100.0
In September 2020, we provided SSA data that identified all 438,860 non-beneficiaries.
Resolving these discrepancies will improve the accuracy and completeness of the death
information SSA shares with other Federal benefit-paying agencies.
19
RECOMMENDATIONS
We recommend SSA:
1. Take action to record deaths on the Numident, terminate payments, and initiate collection of
overpayments, as appropriate, for the 52 cases under review.
2. Take action to terminate payments due to death and initiate collection of overpayments, as
appropriate, for the 16 cases where SSA has already added beneficiary death information to
the Numident.
17
See Footnote 10.
18
We matched California death records that included a validated Social Security number, name, and date of birth
(per Enumeration Verification System process) against SSA’s Numident. We excluded individuals who were
receiving Old-Age, Survivors and Disability Insurance benefits or Supplemental Security Income payments.
19
Although SSA shares its death information with other Federal benefit-paying agencies, those agencies should
independently verify the individual’s death before they take adverse action. In addition, based on January 2013
legislation, SSA was taking steps to improve the accuracy of its death information; Improper Payments Elimination
and Recovery Improvement Act of 2012, Pub. L. No. 112-248, § 5(g)(1), 126 Stat. 2390, p. 2396 (2013).
Match of California Death Information Against SSA Records (A-06-18-50706) 5
3. Take action to record deaths on the Numident, terminate payments, and initiate collection of
overpayments, as appropriate, for the 33 beneficiaries whose payments were suspended
but no death information was input in SSA records.
4. Add death information to the Numident, as appropriate, for the 438,860 non-beneficiaries
with dates of death we identified using California records.
AGENCY COMMENTS
SSA agreed with our recommendations. The full text of SSA’s comments is included in
Appendix B.
Mic
helle L. Anderson
Assistant Inspector General for Audit
Match of California Death Information Against SSA Records (A-06-18-50706)
APPENDICES
Match of California Death Information Against SSA Records (A-06-18-50706) A-1
– SCOPE AND METHODOLOGY
To accomplish our objective, we:
Reviewed Federal laws and regulations related to death matches with State agencies; the
Social Security Administration’s (SSA) policies and procedures; and prior Office of the
Inspector General reports.
Obtained California Department of Public Health records data file and identified
approximately 16.1 million individuals recorded as having died in California from
January 1905 through December 2017. We matched these records against SSA’s
Enumeration Verification System and June 2019 payment records and identified
439 Old-Age, Survivors and Disability Insurance beneficiaries and/or Supplemental
Security Income recipients
1
in current payment status whose names and dates of birth
matched those of deceased individuals in the California death data and appeared to be
deceased.
For 386 beneficiaries, we did the following:
Reviewed SSA’s systems, and California death data, LexisNexis, and public
records as necessary.
Determined whether SSA (a) documented contact with the beneficiary after the
date of death in California records, (b) had determined the beneficiary was a
victim of identity theft, (c) listed two individuals on the same Numident record and
the deceased individual was not the beneficiary, or (4) had terminated the
beneficiary’s payments due to death and input a date of death in the beneficiary’s
record the occurred after December 2017. If so, we considered the beneficiary
alive, and, if not, we considered the beneficiary deceased.
Obtained California death certificates
2
and referred the cases to either our Office
of Investigations or SSA. As of September 1, 2021, SSA had:
determined 89 beneficiaries were alive;
determined 196 beneficiaries were deceased, terminated their payments and
identified approximately $13.6 million in payments after death;
determined 16 beneficiaries were deceased, input death information on the
Numident, but had not identified payments issued after death;
1
We use the term “beneficiary” in this Appendix in reference to Old-Age, Survivors and Disability Insurance
beneficiaries and/or Supplemental Security Income recipients in current payment status.
2
We did not refer five cases because, during the audit, SSA terminated the beneficiaries’ payments and established
overpayments on their records.
Match of California Death Information Against SSA Records (A-06-18-50706) A-2
suspended 33 beneficiaries’ payments but had not input death information on
the Numident or identified payments issued after death; and
is reviewing the remaining 52 cases.
We previously referred the 53 remaining beneficiaries to SSA as part of our on-going
Match of Centers for Medicare and Medicaid Services Death Information Against
Social Security Administration Records (A-06-18-50653). During the current audit,
SSA had taken action to terminate payments to 29 beneficiaries. We purchased the
other 24 beneficiaries’ death certificates and referred the cases to either our Office of
Investigations or SSA. We excluded the 53 cases from this audit’s results.
438,860 non-beneficiaries
3
whose Social Security numbers, names, and dates of birth
matched those of deceased individuals in the California death data but whose death
information was not in SSA’s Numident as of June 2019. We referred these cases to
SSA.
Identified payments issued after death for 245 beneficiaries
4
whose payments have been
suspended or terminated and estimated overpayments for 52 beneficiaries whose vital
status is under SSA review.
We conducted our audit in Dallas, Texas, from July 2019 to September 2021. We determined
the data used for this audit were sufficiently reliable to meet our audit objectives. We assessed
the significance of internal controls necessary to satisfy our audit objectives. We determined
that internal controls were not significant to our audit objectives; therefore, we did not assess
the design, implementation, or operating effectiveness of internal controls. The primary entities
audited were the Offices of the Deputy Commissioners for Operations and Systems. We
conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on
our audit objectives. We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
3
Refers to deceased individuals who were not in current or suspended payment status at the time of our review.
4
We used the overpayments SSA calculated and input in 196 beneficiaries’ payment records and calculated
overpayments for 49 beneficiaries whose payments had been terminated or suspended.
Match of California Death Information Against SSA Records (A-06-18-50706) B-1
– AGENCY COMMENTS
SOCIAL SECURITY
MEMORANDUM
Date:
September 10, 2021 Refer To: TQA-1
To:
Gail S. Ennis
Inspector General
From:
Scott Frey
Chief of Staff
Subject:
Office of the Inspector General Draft Report "Match of California Death Information Against
Social Security Administration Records" (A-06-18-50706) — INFORMATION
Thank you for the opportunity to review the draft report. We agree with the recommendations.
We are taking action on the remaining cases OIG identified. Additionally, we continue to make
improvements to our death information to promote program integrity and prevent improper
payments.
Please let me know if I can be of further assistance. You may direct staff inquiries to
Trae Sommer at (410) 965-9102.
Mission: The Social Security Office of the Inspector General (OIG) serves the
public through independent oversight of SSA’s programs and operations.
Report: Social Security-related scams and Social Security fraud, waste, abuse,
and mismanagement, at oig.ssa.gov/report
.
Connect: OIG.SSA.GOV
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