Audit Report
Numident Death Alerts
A-06-21-51086 |September 2022
MEMORANDUM
Date:
September 30, 2022
Refer to:
A-06-21-51086
To:
Kilolo Kijakazi
Acting Commissioner
From:
Gail S. Ennis,
Inspector General
Subject:
Numident Death Alerts
The attached final report presents the results of the Office of Audit’s review. Our objective was
to determine whether the Social Security Administration effectively managed the Numident
death alert process.
Please provide within 60 days a corrective action plan that addresses each recommendation. If
you wish to discuss the final report, please call me or have your staff contact
Michelle L. Anderson, Assistant Inspector General for Audit.
Attachment
Numident Death Alerts
A-06-21-51086
September 2022 Office of Audit Report Summary
Objective
To determine whether the Social
Security Administration (SSA)
effectively managed the Numident
death-alert process.
Background
To identify and prevent payments after
death, the Social Security Act requires
that SSA establish a program under
which states can voluntarily contract to
provide SSA with death data to match
against SSA’s 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
SSA database that stores personally
identifiable information for all Social
Security numberholders and should
terminate payments to deceased
beneficiaries.
When death data are present on the
Numident, but there are no
corresponding death data on a
beneficiary’s payment record,
SSA’s Death Alerts Tracking System
produces a Numident death alert and
routes the alert to the beneficiary’s
servicing field office for review.
Findings
SSA did not always effectively manage the Numident death alert
process. SSA continued issuing payments to 1,300 beneficiaries
for months or years after it received and recorded their death
information on the Numident. This included 1,224 cases with
Numident death alerts generated in June 2021 or earlier that
remained pending in September 2021 and 76 cases with no
Numident death alert pending. We estimate SSA issued
$14 million in payments after these beneficiaries’ deaths.
Correcting these errors will prevent an estimated $6 million in
additional improper payments over 12 months.
Recommendations
We made seven recommendations for corrective action including
that SSA resolve all pending Numident death alerts generated from
June 2013 through August 2022, terminate benefits, and recover
improper payments, as appropriate. We also recommended that
SSA terminate payment records and recover improper payments
issued after death for the cases that did not generate alerts.
Agency Comments
SSA agreed with four recommendations and disagreed with three.
Agency Actions Resulting from the Audit
As of August 27, 2022, SSA had resolved 941 of the 1,224 pending
alerts. During the resolution process, SSA removed death
information from 68 beneficiaries’ Numident records, indicating
SSA determined the beneficiaries were alive. We excluded the
68 cases from the estimated improper payments/payments after
death presented in the report. We reviewed and summarized the
payment status of the beneficiaries associated with the remaining
1,156 alerts and 76 beneficiaries whose Numident records
contained a date of death in May 2021 or earlier but had no
Numident death alert pending.
Numident Death Alerts (A-06-21-51086)
TABLE OF CONTENTS
Objective ..................................................................................................................................... 1
Background ................................................................................................................................. 1
Results of Review ....................................................................................................................... 2
Numident Death Alerts with Proven Death Information .......................................................... 2
Numident Death Alerts with Non-EDR:Y Death Information................................................... 3
No Timeliness Goals for Resolving Numident Death Alerts ............................................. 4
Deceased Beneficiaries with No Numident Death Alerts Pending.......................................... 4
Best Practices ............................................................................................................................. 5
Recommendations ...................................................................................................................... 5
Agency Actions Resulting from the Audit..................................................................................... 6
Agency Comments and OIG Response....................................................................................... 6
– Scope and Methodology .................................................................................. A-1
– Agency Comments........................................................................................... B-1
Numident Death Alerts (A-06-21-51086)
ABBREVIATIONS
DATS Death Alerts Tracking System
DIPS Death Information Processing System
EDR Electronic Death Registration
LEERS Louisiana Electronic Event Registration System
OIG Office of the Inspector General
POMS Program Operations Manual System
SSA Social Security Administration
U.S.C. United States Code
Numident Death Alerts (A-06-21-51086) 1
OBJECTIVE
Our objective was to determine whether the Social Security Administration (SSA) effectively
managed the Numident death alert process.
BACKGROUND
To identify and prevent payments after death, the Social Security Act requires that SSA
establish a program under which states can voluntarily contract to provide SSA with death data
to match against SSA’s records.
1
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.
2
If the decedent’s data match SSA records, SSA
automatically posts the state death information to the Numident, an SSA database that stores
personally identifiable information for all Social Security numberholders,
3
and should terminate
payments to deceased beneficiaries.
SSA also receives death information from other sources, such as family members or funeral
directors. SSA employees can add this death information to the Numident using SSA’s Death
Information Processing System (DIPS). DIPS death inputs should also automatically post the
death information to the decedent’s payment record if a payment record exists. The employee
who inputs the death information must control and monitor the decedent’s record to ensure
correct posting to both the Numident and applicable payment record(s).
4
When death data are present on the Numident, but there are no corresponding death data on a
beneficiary’s
5
payment record, SSA’s Death Alerts Tracking System (DATS) produces a
Numident death alert and routes the alert to the beneficiary’s servicing field office for review.
SSA performs this match to reduce improper payments (if death information does not make it to
the payment records, a beneficiary or recipient could continue receiving payments until the
alerts are resolved) and remove erroneous death information from the Numident if the individual
is alive.
6
When the source of Numident death information is a verified EDR death report,
7
SSA employees can terminate benefits without additional death development.
8
1
Social Security Act, 42 U.S.C. § 405(r)(1).
2
State agencies can also report death information to SSA outside the EDR process.
3
SSA, POMS, GN 02602.050, A (September 3, 2019).
4
SSA, POMS, GN 02602.051.A. (February 22, 2017).
5
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.
6
SSA, POMS, GN 02602.065.B.4. (January 15, 2016).
7
The Numident death record is coded “EDR:Y” when the death information source is a verified EDR report.
8
SSA, POMS, GN 02602.070. C. Step 5 (September 27, 2021). SSA employees must first determine whether SSA
reinstated benefits due to an incorrect death, but the death information was not removed from the Numident.
Numident Death Alerts (A-06-21-51086) 2
When the Numident contains unproven death information,
9
SSA field office staff must attempt to
contact the alleged decedent, or family of the decedent, by telephone.
10
If employees cannot
make telephone contact, they send a letter and follow up in 45 days (45-day letter). If the
beneficiary does not contact the SSA field office or respond to the letter, policy instructs staff to
consider the person deceased and terminate benefits.
In prior audits,
11
we estimated that SSA improperly paid approximately 4,000 beneficiaries
about $91 million after it received notification the beneficiaries were deceased.
RESULTS OF REVIEW
SSA did not always effectively manage the Numident death alert process. SSA continued
issuing payments to 1,300 beneficiaries for months or years after it received and recorded their
death information on the Numident. This included 1,224 cases with Numident death alerts
generated in June 2021 or earlier that remained pending in September 2021 and 76 cases with
no Numident death alert pending. As a result, we estimate SSA issued $14 million in payments
after these beneficiaries’ deaths. Correcting these errors will prevent an estimated $6 million in
additional improper payments over 12 months.
12
Numident Death Alerts with Proven Death Information
SSA issued approximately $8.2 million in payments to 816 beneficiaries after it received and
recorded their proven (EDR:Y) death information on the Numident. SSA employees could have
terminated these payments without additional death development. SSA systems generated
Numident death alerts in each of these cases that dated as far back as Calendar Year 2014 and
remained pending as of September 2021.
Table 1: Death Alerts Generated in June 2021 or Earlier with EDR:Y
Death Information that Remained Pending as of September 2021
Number of Alerts
Year Generated
2014 – 2016
8
2017 – 2019
72
2020
216
2021
520
Total
816
9
Death verification is required for Numident death alerts that are not coded EDR:Y (non-EDR:Y). Examples include
unverified EDR death reports (coded EDR:N) and death inputs processed by SSA employees.
10
SSA, POMS, GN 02602.070, C. (September 27, 2021).
11
SSA, OIG, Payments to Individuals Whose Numident Record Contains a Death Entry, A-06-08-18095 (June 2009);
Payments to Individuals Whose Numident Record Contained a Death Entry, A-06-12-11291 (June 2013);
and Follow-up: Payments to Individuals Whose Numident Record Contained a Death Entry, A-06-17-50232
(May 2018).
12
We based this estimate on January 2022 payment amounts and assumed conditions remained the same for
12 months.
Numident Death Alerts (A-06-21-51086) 3
To illustrate, an individual who applied for disability benefits in July 2016 died in August 2016.
SSA received the individual’s electronic death notification from the State of Arizona in
September 2016 and posted the date of death, death certificate number, and proven death code
to the Numident. In November 2016, SSA systems erroneously effectuated the disability claim
13
and began issuing payments to the deceased individual. The same month, SSA’s systems
identified this discrepancy and generated a Numident death alert, which remained pending at
the time of our review. In February 2022, SSA staff mailed the “alleged” decedent a 45-day
letter and, in March 2022, obtained the beneficiary’s paper death certificate. Because SSA had
already obtained the beneficiary’s proven death information, field office staff should have
terminated the payments without mailing a 45-day letter or obtaining a paper copy of the
beneficiary’s death certificate.
14
SSA determined it issued approximately $143,000 in payments
after death before it terminated the payments in April 2022.
Numident Death Alerts with Non-EDR:Y Death Information
SSA issued approximately $4.9 million in payments to 408 beneficiaries after it received and
recorded their non-proven (non-EDR:Y) death information on the Numident. SSA requires that
employees verify these beneficiaries’ death information and clear the alerts as appropriate.
15
SSA systems generated Numident death alerts dating as far back as Calendar Year 2013 that
remained pending in September 2021.
Table 2: Death Alerts Generated in June 2021 or Earlier with Non-EDR:Y
Death Information that Remained Pending as of September 2021
2013 – 2016
141
Number of Alerts
Year Generated
2017 – 2020
123
Total
408
2021
144
For example, a New York retirement beneficiary died in November 2014. In December 2014,
SSA recorded the date of death and death certificate number on the beneficiary’s Numident
record; however, SSA systems did not terminate the benefit payments. In December 2014,
SSA’s system produced a Numident death alert that remained pending until SSA terminated the
payments in December 2021 and determined it issued $134,474 in payments after death. SSA
recovered the entire amount from the beneficiary’s financial institution through the Treasury
reclamation process.
In 158 cases, SSA employees input in the Numident the beneficiary’s death information
provided by the beneficiary’s family member or funeral home. After completing death inputs,
SSA employees are required to monitor the individual’s record to ensure the information is
13
SSA stated that system upgrades would prevent this error from occurring presently.
14
SSA, POMS, GN 02602.070, C. Step 5 (September 27, 2021).
15
SSA, POMS, GN 02602.070, C. (September 27, 2021).
Numident Death Alerts (A-06-21-51086) 4
correctly posted to Numident and payment records.
16
However, SSA employees did not monitor
the records in these instances.
No Timeliness Goals for Resolving Numident Death Alerts
SSA had established a 60-day goal
17
for employees to resolve third-party death alerts
18
that
required death verification. However, SSA had not established timeliness goals for resolving
Numident death alerts or implemented effective management controls to ensure the Numident
death alerts were resolved in a timely manner.
19
Timely resolving these Numident death alerts
will prevent an estimated $5.6 million in additional improper payments over 12 months.
Deceased Beneficiaries with No Numident Death Alerts Pending
SSA issued approximately $900 thousand in payments to 76 beneficiaries
20
whose Numident
record contained a date of death in May 2021 or earlier; however, no Numident death alert was
pending. We requested SSA analysis on 68 cases:
In two cases, SSA systems generated Numident death alerts; however, SSA employees
erroneously cleared the alerts without terminating the benefit payments. For unknown
reasons, SSA systems did not generate subsequent Numident death alerts.
In 37 cases, the system identified the deceased beneficiaries’ non-pay or terminated
payment records but did not identify their current pay records. For example, a widow
receiving survivors benefits died in August 2016. SSA received an electronic death
notification in August 2016 and posted the widow’s date of death, death certificate number,
and proven death code (EDR:Y) on her Numident record. SSA’s system identified her
terminated Supplemental Security Income record; however, SSA systems did not terminate
her widow’s benefits or generate a Numident death alert. In February 2022, we sent SSA
the Social Security number and proof of death. SSA determined it issued $71,625 in
payments after death before it terminated the payments in August 2022.
In 29 cases, we did not determine why SSA systems failed to generate Numident death
alerts.
Correcting these errors will prevent an estimated $392,000 in additional improper payments
over 12 months.
16
SSA, POMS, GN 02602.051 (February 2, 2017).
17
Through Fiscal Year 2021, SSA had established a public service indicator timeliness goal to maintain pending
third-party death alert cases over 60-days-old at 10 percent or less of total pending or maintain no more than one
case over 60-days-old if less than 10 total pending cases. SSA suspended this indicator because of the COVID-19
pandemic and does not have timeliness goals for any type of death alerts.
18
SSA generates third-party death alerts based on death information received from reporters include Centers for
Medicare & Medicaid Services, Department of Veterans Affairs, Office of Personnel Management, and state agencies
reporting death information outside the EDR system. SSA, POMS, GN 02602.050, D. (July 15, 2022).
19
DATS produces monthly listings that identify the number of unresolved Numident death alerts. However, SSA
allowed alerts to remain unresolved for several years.
20
We initially identified 96 cases where beneficiaries had death information on the Numident records but no death
information on their payment records—and no Numident death alert was pending. We sent 96 cases to SSA for
corrective action. Of the 96 cases, we determined 20 cases did not involve improper payments.
Numident Death Alerts (A-06-21-51086) 5
BEST PRACTICES
Some SSA field office management and staff have taken the initiative to obtain access to
available electronic vital records. Five SSA employees in the New Orleans Downtown field
office have read-only access to Louisiana State vital records online via the Louisiana Electronic
Event Registration System (LEERS). We note that, at the time of our review, the field office had
no unresolved/pending Numident death alerts. New Orleans Downtown management believes
LEERS usage contributes to the office’s success in managing the Numident death alert
workload because of the direct access LEERS provides to the State’s death records in cases
where field office staff is required to obtain proof of a beneficiary’s death. About 10 years ago,
the field office manager obtained permission from the Louisiana State Registrar to allow one
SSA employee in each Louisiana field office to have LEERS access at no cost to SSA. The
manager requested the SSA Regional Office’s approval, but SSA officials denied the request.
SSA officials informed us the Agency does not plan to expand the use of LEERS.
We also identified SSA employees in two Texas field offices who have obtained read-only
access to the Texas Electronic Vital Events Registrar. Like LEERS, the Registrar provides the
SSA employees direct access to Texas death records, which greatly reduces the time and effort
required to verify individual’s death information.
We believe it is likely that additional opportunities exist for SSA to expand employee access to
other states’ electronic vital records. Doing so could streamline the process for obtaining and
verifying death certificate information, and enhance other processes, like birth and marriage
certificate verification.
RECOMMENDATIONS
We recommend SSA:
Resolve all pending Numident death alerts generated from June 2013 through August 2022,
terminate benefits, and recover improper payments, as appropriate.
Establish a timeliness goal for resolution of Numident death alerts.
Remind employees that a 45-day letter is not required to resolve Numident death alerts
when the Numident contains proven death information coded EDR:Y and to monitor
payment records after making death inputs in DIPS.
Establish management controls to periodically ensure Numident death alerts are resolved in
a timely manner.
Terminate payment records and recover improper payments issued after death,
when applicable, for the cases not listed on DATS.
Establish management controls to periodically identify and resolve cases where SSA
systems fail to generate Numident death alerts for current beneficiaries with death
information on the Numident.
Consider working with the states to expand access to electronic vital records.
Numident Death Alerts (A-06-21-51086) 6
AGENCY COMMENTS AND OIG RESPONSE
SSA agreed with Recommendations 1, 3, 5, and 6 but disagreed with Recommendations 2, 4,
and 7. The full text of the Agency’s comments is included in Appendix B.
With regard to Recommendations 2 and 4, SSA stated it is not feasible to establish additional
fixed goals without affecting other workloads and its ability to achieve already-established goals.
SSA stated it has an established mechanism through DATS to monitor the age of death alerts,
managers use DATS management information to track death alerts and ensure their
completion, and current DATS data show that only 4 percent of all death alerts are over
60-days-old. We do not agree that Agency managers use DATS information to track Numident
death alerts and ensure their completion. The 4-percent statistic to which SSA refers does not
pertain to Numident death alerts. SSA has established timeliness goals for clearing third-party
death alerts, and DATS Pending Alert Summary dated September 26, 2022 showed that only
4.83 percent of alerts had been pending for longer than 60 days. However, DATS tracks
Numident death alerts separately. As of September 26, 2022, DATS Pending Numident Counts
by Month showed that 1,086 (61 percent) of 1,777 Numident death alerts had been pending
since July 2022 or earlier. Also, 283 (23 percent) of the 1,224 Numident death alerts discussed
in the report remained unresolved in September 2022—longer than 1 year after DATS
generated them. Therefore, we continue to believe SSA should establish Numident death alert
timeliness goals and ensure the alerts are resolved in a timely manner.
Although SSA stated it disagreed with Recommendation 7, it also stated it was premature for it
to work with the states because it was evaluating legal issues to determine whether it can use
electronic vital records to meet evidentiary requirements. Therefore, we believe SSA’s
response satisfies the intent of our recommendation.
AGENCY ACTIONS RESULTING FROM THE AUDIT
As of August 27, 2022, SSA had resolved 941 (77 percent) of the 1,224 alerts generated in
June 2021 or earlier that remained pending in September 2021. During the resolution process,
SSA removed death information from 68 beneficiaries’ Numident records, indicating SSA
determined the death information originally added to the Numident was erroneous, and the
beneficiaries were alive. We excluded the 68 cases from the estimated improper
payments/payments after death presented in the report. We reviewed the payment status of the
beneficiaries associated with the remaining 1,156 alerts
21
and determined that 7 beneficiaries
remained in current payment status. SSA had terminated 855 beneficiaries’ payments due to
death and suspended 166 beneficiaries’ payments. The other 128 beneficiaries were in various
other non-current payment statuses.
21
This number includes the 1,224 initially identified alerts less the 68 alerts where it appeared SSA determined the
beneficiaries were alive. The 1,156 alerts include the 810 EDR:Y and 346 non-EDR:Y cases discussed in the report.
Numident Death Alerts (A-06-21-51086) 7
We also reviewed the payment status of the 76 beneficiaries whose Numident records
contained a date of death in May 2021 or earlier but had no Numident death alert pending and
determined that 50 beneficiaries remained in current payment status. SSA had terminated
21 beneficiaries’ payments due to death, terminated 3 beneficiaries’ payments for reasons other
than death, and suspended 2 beneficiaries’ payments.
Mich
elle L. Anderson
Assistant Inspector General for Audit
Numident Death Alerts (A-06-21-51086)
APPENDICES
Numident Death Alerts (A-06-21-51086) A-1
– SCOPE AND METHODOLOGY
To accomplish our objective, we:
Reviewed the Social Security Administration’s (SSA) Program Operations Manual System,
Federal regulations, and prior Office of the Inspector General reports related to Numident
death alerts.
Contacted SSA officials to gain an understanding of the Death Alerts Tracking System
(DATS) and metrics in place to resolve death alerts.
Obtained a data file from SSA of 1,224 unresolved Numident death alert cases pending on
DATS as of June 2021. From this data set, we identified:
816 beneficiaries whose Numident death entry also contained a proven death
(coded EDR:Y) and
408 beneficiaries whose Numident death entry did not contain an Electronic Death
Registration-proven death.
Identified 96 current pay cases not located on DATS as of July 2021 although the
beneficiaries’ Numident records contained death information.
We performed the audit work between August 2021 and May 2022. The entities audited were
the Offices of Operations and Systems under the Office of the Deputy Commissioners for
Operations and Systems. We determined the computer-processed data was sufficiently reliable
for our intended use. We conducted tests to determine the completeness and accuracy of the
data primarily by tracing information in the data to SSA payment and Numident records. In
some cases, we verified the accuracy of death information by obtaining corroborative
documentation like obituary notices and reports of death from funeral homes. These tests
allowed us to assess the reliability of the data and achieve our audit objective.
We assessed the significance of internal controls necessary to satisfy the audit objective.
This included an assessment of the five internal control components, including control
environment, risk assessment, control activities, information and communicating,
and monitoring. In addition, we reviewed the principles of internal controls associated with the
audit objectives. We identified the following component and principles as significant to the audit
objective.
Component 3: Control Activities
Principle 10: Design control activities
Principle 12: Implement control activities
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 objective. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objective.
Numident Death Alerts (A-06-21-51086) B-1
– AGENCY COMMENTS
SOCIAL SECURITY
MEMORANDUM
Date:
September 27, 2022 Refer To: TQA-1
To:
Gail S. Ennis
Inspector General
From:
Scott Frey
Chief of Staff
Subject:
Office of the Inspector General Draft Report, “Numident Death Alerts” (A-06-21-51086) —
INFORMATION
Thank you for the opportunity to review the draft report. We agree with recommendations 1, 3,
5, and 6. We disagree with recommendations 2, 4, and 7.
We disagree with recommendation 2 because it is not feasible to establish additional fixed goals
without affecting other workloads and our ability to achieve already-established goals.
We disagree with recommendation 4 because we have an established mechanism through the
Death Alerts Tracking System (DATS) to monitor the age of death alerts. Managers use the
DATS management information to keep track of the death alerts and ensure their completion.
Our current DATS data show that only 4 percent of all death alerts are over 60 days old.
We disagree with recommendation 7 because we are evaluating legal issues to determine if we
can use electronic vital records to meet evidentiary requirements. It is premature for us to work
with the States.
Please let me know if I can be of further assistance. You may direct staff inquiries to Trae
Sommer at (410) 965-9102.
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