The Death Master File Debate — Where Is It Headed?

July 8, 2015

The Social Security Administration’s Death Master File (DMF) and its data have provided hours and hours of conversation and debate within the U.S. Government. With more than 90 million records, the DMF is vital to many industries’ ability to determine whether a person is still eligible to receive benefits or apply and qualify for financial services.

But, the DMF has come under fire for its inaccuracies and the fraudulent activities stemming from its availability. This issue first appeared on the radar in November 2011, and has since rapidly gained momentum.

So, how did all of this start?

At the time, the Death Master File access was not regulated and placed deceased people at a higher risk for identity theft and fraud. No one was really sure where the responsibility for ensuring that the data is accurate really fell. The U.S. Government (more specifically the Department of Homeland Security) started a committee and began to discuss how to prevent the issues caused by the DMF.

Because of the inaccuracies and the detail of the information provided in the DMF, it was thought that by limiting accessibility, the U.S. Government could save a substantial amount of money by cracking down on fraud and mistakenly paid benefits.

The question then became: how to limit the DMF while still ensuring that legitimate businesses could still complete their work? They wanted to ensure that the DMF did not completely go away nor would it end up in the wrong hands.

In March 2014, an interim program was put into place by the National Technical Information Service until a final decision was made. This interim program allows those with legitimate business reasons access to the information after going through an application and certification process. The certification is good for one year and those who have access must maintain strict data security and protection requirements while being subjected to unscheduled audits.

What is Currently Happening with the Death Master File?

The certification process established in 2014 is still in place and discussion in Washington, D.C. continues. We are watching the situation very closely and are providing expert input and information to those involved in these discussions as necessary. LifeStatus360 has been certified to access the DMF since the process was enacted. We have committed to maintaining our certification for as long as necessary. We have been deemed a legitimate business that requires access and have exceeded the expectations of the application process.

There has also been a lot of attention in the general media on the DMF and the inaccuracies (especially on the millions of dollars each year that is mistakenly paid to those who are deceased). There have been numerous articles written criticizing the accuracy of the DMF, and there was even a recent 60 Minutes report that focused on those wrongly labeled as deceased. We expect that with the increased attention and scrutiny turned to the DMF, a quick decision seems highly unlikely.

When will we have a final decision – and what is the likely outcome?

We don’t see any indicators of when a final decision will be made, and the final outcome could be a range of results.

Regardless of the final decision that is handed down, it is our intention to continue to follow through with any certification and maintain all of the qualification and standards that allow for continuous access to the Death Master File.

We understand that the DMF alone isn’t able to give a complete and accurate record of death, considering the variety of restrictions and policies in place. An example of this is the Social Security Act 205(r). Clause 205(r) restricts the ability of the Social Security Administration to disclose death information that has not been corroborated by a secondary source. On the surface, this makes it appear that the SSA is reporting fewer deaths — which creates uncertainty and concern over dependable and consistent data.

This uncertainty and the continuing debate surrounding the DMF is exactly what led us to re-design, re-tool and re-brand Small World Solutions into LifeStatus360. Since we are starting with a clean slate, we can throw out those old and outdated “default standards” and start anew. We have better technology to handle, process, present and secure the data. We are bringing new technology to the Death Audit market — not just add-ons — and innovative ideas that are shattering old mindsets.

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