oversight

Match of Delaware Death Information Against Social Security Administration Records

Published by the Social Security Administration, Office of Inspector General on 2019-11-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             Audit Report



     Match of Delaware Death
Information Against Social Security
      Administration Records




     A-15-18-50662 | November 2019
MEMORANDUM


Date:      November 27, 2019                                                 Refer To:

To:        The Commissioner
From:      Inspector General
Subject:   Match of Delaware Death Information Against Social Security Administration Records
           (A-15-18-50662)

           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 representative payees who were deceased according to Delaware’s Office of
           Vital Statistics and (2) identify non-beneficiaries who were deceased according to the State file
           but whose death information did not appear in the Agency’s records.

           If you wish to discuss the final report, please call me or have your staff contact Rona Lawson,
           Assistant Inspector General for Audit, at 410-965-9700.




                                                          Gail S. Ennis

           Attachment
Match of Delaware Death Information Against Social Security
Administration Records
A-15-18-50662
November 2019                                                              Office of Audit Report Summary

Objectives                                 Findings

To (1) determine whether the Social        SSA issued approximately $2 million in payments after death to
Security Administration (SSA) made         31 beneficiaries and 2 representative payees whom the State of
payments to beneficiaries and              Delaware recorded as deceased from January 1992 through
representative payees who were             December 2017. Identifying and correcting these discrepancies will
deceased according to Delaware’s           prevent approximately $440,000 in additional improper payments
Office of Vital Statistics and             after death over a 12-month period. We also identified 2,851 non-
(2) identify non-beneficiaries who         beneficiaries who were deceased according to the Delaware Office
were deceased according to the State       of Vital Statistics but whose death information was not in SSA’s
file but whose death information did       Numident.
not appear in SSA’s records.
                                           We did not determine why the deaths were not in SSA’s Numident
Background                                 or whether the State reported the deaths to SSA. However, SSA
                                           rejects EDR death reports that do not pass its formatting and
To identify and prevent payments after     identification tests to prevent posting erroneous death data to its
death, SSA established a program           records. We have a separate ongoing review that will assess the
under which States can voluntarily         effectiveness of the EDR process.
contract with SSA to provide it with
death data to match against its records.   The Numident contained death information for the two
SSA and the States developed the           representative payees; however, SSA had not replaced the
Electronic Death Registration (EDR)        representative payees at the time of our data match. As of
process to improve the accuracy and        October 2019, SSA had taken action to replace one of the two
timeliness of death information.           representative payees we identified.
Through EDR, States electronically
submit death records to SSA, and SSA       Agency Actions Resulting from the Audit
completes an online, real-time
verification of the Social Security        As of October 2019, SSA had terminated benefits to 11 of the
number. If the numberholder’s data         31 deceased beneficiaries and 1 of 2 representative payees. It also
match SSA records, SSA posts the           initiated recovery of $550,000 in improper payments.
State death information to its
                                           Recommendations
Numident file and terminates payments
to deceased beneficiaries.                 1. Take action on the remaining 20 deceased beneficiaries and
                                              1 deceased representative payee we identified.
We obtained the personally identifiable
information of approximately               2. Take action on the 2,851 deceased non-beneficiaries we
200,000 Social Security                       identified to add their deaths to the Numident, as appropriate.
numberholders the Delaware Office of
Vital Statistics recorded as deceased      SSA agreed with the recommendations.
between January 1992 and December
2017. We matched the data against
SSA payment records and the
Numident.
TABLE OF CONTENTS
Objectives ........................................................................................................................................1
Background ......................................................................................................................................1
Results of Review ............................................................................................................................2
     Payments Issued to Deceased Beneficiaries ..............................................................................3
     Payments to Deceased Representative Payees ...........................................................................4
     Deceased Non-beneficiaries.......................................................................................................5
Conclusions ......................................................................................................................................5
Agency Actions Resulting from the Audit.......................................................................................6
Recommendations ............................................................................................................................6
Agency Comment ............................................................................................................................6
                   – Scope and Methodology ..................................................................................... A-1
                   – Agency Comments .............................................................................................. B-1




Match of Delaware Death Information Against SSA Records (A-15-18-50662)
ABBREVIATIONS
C.F.R.              Code of Federal Regulations

EDR                 Electronic Death Registration

OASDI               Old-Age, Survivors and Disability Insurance

OIG                 Office of the Inspector General

POMS                Program Operations Manual System

Pub. L. No.         Public Law Number

SSA                 Social Security Administration

SSI                 Supplemental Security Income

Stat.               Statutes at Large

U.S.C.              United States Code




Match of Delaware Death Information Against SSA Records (A-15-18-50662)
OBJECTIVES
Our objectives were to (1) determine whether the Social Security Administration (SSA) made
payments to beneficiaries 1 and representative payees who were deceased according to
Delaware’s Office of Vital Statistics and (2) identify non-beneficiaries who were deceased
according to the State file but whose death information did not appear in SSA’s records.

BACKGROUND
To identify and prevent payments after death, the Social Security Act 2 requires that SSA establish
a program under which States can voluntarily contract with SSA to provide it with death data to
match against their 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 completes an online,
real-time verification of the Social Security number. If the numberholder 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
terminates payments to deceased beneficiaries. EDR is not the only way SSA receives death
information; it also posts death information to its records based on death reports 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.

When a representative payee 4 dies, SSA must replace the payee or send payments directly to the
beneficiary. SSA may pay the beneficiary directly on an interim basis until it finds a suitable
payee or on a permanent basis if it determines the beneficiary is capable of managing his/her
own benefits. 5 The Social Security Act requires that SSA establish a system of accountability for
monitoring representative payees. 6 If a representative payee dies and is not replaced, SSA
cannot be sure the funds are being used to meet the beneficiary’s needs, such as food, clothing,
shelter, and medical care. 7



1
 We use the term “beneficiary” throughout this report in reference to Old-Age, Survivors and Disability Insurance
(OASDI) beneficiaries and/or Supplemental Security Income (SSI) recipients in current payment status.
2
    Social Security Act, 42 U.S.C. § 405(r)(1) (govinfo.gov 2017).
3
    SSA, POMS, GN 02602.050, A (September 3, 2019).
4
  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 2017).
5
 20 C.F.R. §§ 404.2050(d), 416.650(d), 404.2055, and 416.655 (govinfo.gov 2018). SSA may suspend payment
under 20 C.F.R. §§ 404.2011(b) and 416.611(b) if it finds that paying the beneficiary directly would cause
substantial harm, and the Agency cannot find a suitable representative payee before the next payment is due.
6
    Social Security Act, 42 U.S.C. §§ 405(j)(3)(A) and (6), and 1383(a)(2)(C)(i), (F)(iv) and (G) (govinfo.gov 2017).
7
    20 C.F.R. §§ 404.2040(a) and 416.640(a) (govinfo.gov 2018).



Match of Delaware Death Information Against SSA Records (A-15-18-50662)                                                 1
We obtained the personally identifiable information of approximately 200,000 Social Security
numberholders the Delaware Office of Vital Statistics recorded as deceased between
January 1992 and December 2017. Our match of the data against SSA payment records and the
Numident identified OASDI beneficiaries and SSI recipients who were in current payment status
and representative payees whose personally identifiable information matched that of a decedent
in the Delaware data. We also identified decedents who were not receiving OASDI or SSI
benefits and whose death information did not appear in SSA’s Numident. We obtained death
certificates for the OASDI beneficiaries, SSI recipients, and representative payees in current
payment status and provided the certificates to SSA. See Appendix A for information on our
scope and methodology.

RESULTS OF REVIEW
SSA issued approximately $2 million in payments after death to 31 beneficiaries and
2 representative payees who were deceased according to the Delaware Office of Vital Statistics 8
between January 1992 and December 2017. 9 Identifying and correcting these discrepancies
would prevent approximately $440,000 in additional improper payments after death over a
12-month period. We also identified 2,851 non-beneficiaries who were deceased according to
the Delaware Office of Vital Statistics but whose death information was not in SSA’s Numident.

We did not determine why the deaths we identified were not in SSA’s Numident or whether
Delaware reported the deaths to SSA. However, SSA rejects EDR death reports that do not pass
its formatting and identification tests to prevent posting erroneous death data to its records. We
have a separate ongoing review that will assess the effectiveness of the EDR process. 10

The Numident contained death information for both representative payees; however, SSA had
not replaced the representative payees at the time of our data match. In several prior audits, 11 we
found SSA did not always replace representative payees or assess the continuing need for a
representative payee after it posted death information to the payees’ Numident records.




8
  The Delaware Department of Health retains death data for individuals who die in the State as well as Delaware
residents who die outside the State, either domestically or abroad, where possible.
9
  While we took steps to ensure the death certificates for all 31 deceased beneficiaries belonged to the true
numberholder, the true numberholder could be alive. See Appendix A for more information about the steps we took
to determine whether the true numberholder was deceased.
10
     We do not assert the EDR process is the exclusive cause of unrecorded deaths on SSA records.
11
  SSA, OIG, Follow-up on: Deceased Representative Payees, A-01-18-50350 (July 2019); Deceased Representative
Payees, A-01-14-34112, (June 2015); Follow up on the Social Security Administration’s Procedures to Identify
Representative Payees Who Are Deceased, A-01-06-16054, (October 2006); and The Social Security
Administration’s Procedures to Identify Representative Payees Who Are Deceased, A-01-98-61009,
(September 1999).


Match of Delaware Death Information Against SSA Records (A-15-18-50662)                                           2
Payments Issued to Deceased Beneficiaries
SSA issued approximately $1.8 million in payments after death to 31 beneficiaries the State of
Delaware recorded as deceased between January 1992 and December 2017. Examples follow.

   A retirement beneficiary died in May 2016. SSA records did not contain a date of death and
    therefore SSA issued approximately $28,000 in payments after death. We referred this case
    to SSA in July 2018. The beneficiary’s representative payee concealed the death and was
    subsequently assessed an overpayment for the full amount, which has been repaid.

   A disability beneficiary died in April 2016. SSA records did not contain a date of death and
    therefore SSA issued approximately $33,000 in payments after death. We referred this case
    to SSA in July 2018. As of October 2019, SSA had recovered $10,000.

   A retirement beneficiary died in March 2006. SSA records did not contain a date of death
    and therefore SSA issued approximately $178,000 in payments after death. We referred this
    case to SSA in July 2018. As of October 2019, SSA had not recovered any of the improper
    payments.

   A retirement beneficiary died in April 2005. When Delaware reported the death to SSA, it
    transposed a digit of the decedent’s Social Security number. SSA records did not contain a
    date of death and therefore SSA has issued approximately $234,000 in payments after death.
    We referred this case to SSA in August 2019. As of October 2019, SSA had not recovered
    any of the improper payments.

In January 2009, Delaware began reporting deaths to SSA through the EDR process. Yet, as
illustrated in Table 1, 80.6 percent of the beneficiaries SSA had improperly paid died after the
State began reporting death information to SSA via EDR.

         Table 1: Beneficiaries Whose Personally Identifiable Information Matched
                   that of a Deceased Individual in Delaware Death Data
                         Year of             Number of        Percent of Total
                          Death             Beneficiaries      Beneficiaries
                        1992-2000                 3                 9.7
                        2001-2008                 3                 9.7
                        2009-2017                25                80.6
                           Total                  31                 100




Match of Delaware Death Information Against SSA Records (A-15-18-50662)                            3
In August 2019, we provided SSA the death certificates for the 31 beneficiaries to take
appropriate actions. We estimate identifying and correcting these discrepancies will prevent
approximately $410,000 in additional payments after death over a 12-month period. 12

Payments to Deceased Representative Payees
We identified two deceased representative payees to whom SSA had issued over $220,000 in
payments after death. When a representative payee dies, SSA must replace the payee or send
payments directly to the beneficiary. SSA may pay the beneficiary directly on an interim basis
until it finds a suitable payee or on a permanent basis if it determines the beneficiary is capable
of managing his/her own benefits. 13 The Social Security Act requires that SSA establish a system
of accountability for monitoring representative payees. 14 If a representative payee dies and is not
replaced, SSA cannot be sure the funds are being used to meet the beneficiary’s needs, such as
food, clothing, shelter, and medical care. 15

The Numident contained death information for the two representative payees; however, SSA had
not replaced them. In several prior audits, 16 we found SSA did not always replace representative
payees after it posted death information to their Numident records.

In July 2018, we provided our Office of Investigations information on one of the two deceased
representative payees. By January 2019, SSA had replaced the deceased representative payee,
which prevented $15,000 in additional improper payments after death over a 12-month period.
In August 2019, we provided SSA with information on the remaining representative payee,
which is pending further action. If the Agency does not take action on the remaining case, we
estimate it will pay approximately $15,000 in additional payments after death over a 12-month
period. 17




12
  We based this estimate on the assumption that conditions would remain the same over the 12 months. To estimate
the annual amount of overpayments that would occur without corrective action, we identified the most recent
payment before referral/corrective action for each record and multiplied it by 12 months.
13
   20 C.F.R. §§ 404.2050(d), 416.650(d), 404.2055, and 416.655 (govinfo.gov 2018). SSA may suspend payment
under 20 C.F.R. §§ 404.2011(b) and 416.611(b) if it finds that paying the beneficiary directly would cause
substantial harm, and the Agency cannot find a suitable representative payee before the next payment is due.
14
     Social Security Act, 42 U.S.C. §§ 405(j)(3)(A) and (6), 1383(a)(2)(C)(i), (F)(iv) and (G) (govinfo.gov 2017).
15
     20 C.F.R. §§ 404.2040(a) and 416.640(a) (govinfo.gov 2018).
16
     See Footnote 11.
17
     See Footnote 12.



Match of Delaware Death Information Against SSA Records (A-15-18-50662)                                              4
Deceased Non-beneficiaries
We identified 2,851 non-beneficiaries 18 who were deceased according to Delaware Department
of Health vital records but who did not have death information in SSA’s Numident. As shown in
Table 2, 83.6 percent of these individuals died before the State began reporting death information
to SSA via EDR in January 2009.

 Table 2: Non-beneficiaries Whose Personally Identifiable Information Matched that of a
                   Deceased Individual in the Delaware Death Data
                                             Number of                Percent of Total
                      Year of Death        Non-beneficiaries          Non-beneficiaries
                       1992-2008                  2,383                     83.6
                       2009-2017                    468                     16.4
                           Total                      2,851                    100

Resolving these discrepancies will reduce SSA’s exposure to future improper payments and
improve the accuracy and completeness of the death information it shares with other Federal
benefit-paying agencies. 19 In August 2019, we provided SSA with data that identified 2,851 non-
beneficiaries for it to take the necessary action. SSA stated that, because these types of cases do
not involve improper payments, their cleanup is a low priority and resource-dependent.

CONCLUSIONS
SSA issued approximately $2 million in payments after death to 31 beneficiaries and
2 representative payees who were recorded as deceased by the State of Delaware between
January 1992 and December 2017. Identifying and correcting these discrepancies will prevent
approximately $440,000 in additional improper payments after death over a 12-month period.
We also identified 2,851 non-beneficiaries who were deceased according to Delaware vital
records but whose death information did not appear in SSA records. Posting death information
to the individuals’ Numident records will reduce SSA’s exposure to future improper payments
and improve the accuracy and completeness of the death information the Agency shares with
other Federal benefit-paying agencies.




18
   We matched Delaware 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 OASDI benefits or SSI 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. Also, 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 Delaware Death Information Against SSA Records (A-15-18-50662)                                             5
AGENCY ACTIONS RESULTING FROM THE AUDIT
As of October 2019, SSA had terminated benefits to 11 of the 31 deceased beneficiaries and 1 of
2 representative payees. It also initiated recovery of $550,000 in improper payments.

RECOMMENDATIONS
We recommend SSA:

1. Take action on the remaining 20 deceased beneficiaries and 1 deceased representative payee
   we identified.

2. Take action on the 2,851 deceased non-beneficiaries we identified to add their deaths to the
   Numident, as appropriate.

AGENCY COMMENT
SSA agreed with the recommendations; see Appendix B.




                                                 Rona Lawson
                                                 Assistant Inspector General for Audit




Match of Delaware Death Information Against SSA Records (A-15-18-50662)                           6
                                      APPENDICES




Match of Delaware Death Information Against SSA Records (A-15-18-50662)
                       – SCOPE AND METHODOLOGY
To accomplish our objectives, 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 Delaware Department of Health vital records death data and identified
    approximately 200,000 recorded death events between January 1992 and December 2017.
    We matched these records against SSA’s Enumeration Verification System and payment
    records and identified the following:
       31 Old-Age, Survivors and Disability Insurance (OASDI) beneficiaries and/or
        Supplemental Security Income (SSI) recipients in current payment status whose names
        and dates of birth matched those of deceased individuals in the Delaware death data. 1
            Reviewed SSA’s systems, Delaware death data, LexisNexis, and public records, as
             necessary.
            Determined whether SSA (a) documented substantive contact with the beneficiary
             after the date of death in Delaware records, (b) had previously determined the
             beneficiary was a victim of identity theft, or (c) listed two individuals on the same
             Numident record and the deceased individual was not the beneficiary. If so, we
             considered the beneficiary to be alive, and if not, we considered the beneficiary to be
             deceased.
            Obtained death certificates from Delaware, Maryland, and New Jersey and referred
             the 31 cases to SSA.
       2 deceased representative payees with beneficiaries in current payment status as of
        April 2018 whose Social Security numbers, names, and dates of birth matched those of
        deceased individuals in the Delaware death data. We obtained Delaware death
        certificates for these two payees and referred the cases to SSA.
       2,851 individuals 2 whose Social Security numbers, names, and dates of birth matched
        those of deceased non-beneficiaries in the Delaware death data but whose death
        information was not in SSA’s Numident as of June 2019. We referred these cases to
        SSA.



1
  We matched the Social Security number, name, and date of birth on the Delaware Department of Health vital
records death data with SSA’s Numident for 20 of the 31 deceased beneficiaries. For the remaining 11 deceased
beneficiaries, the name and date of birth on the Delaware Department of Health vital records death data matched
SSA’s Numident. However, we matched additional identifying information from the death data with SSA records to
confirm the death data belonged to the true numberholder.
2
  This is in reference to deceased individuals who were not in current payment status at the time of our review. Of
the 2,851 non-current pay records, 1,271 never applied for benefits, and the remaining 1,580 had either applied and
were denied or were in a non-pay status.


Match of Delaware Death Information Against SSA Records (A-15-18-50662)                                         A-1
   Calculated payments issued after death to the 31 beneficiaries and 2 representative payees.

We conducted our audit from July to October 2019 at SSA Headquarters in Woodlawn,
Maryland. We determined the data used for this audit were sufficiently reliable to meet our audit
objectives. 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 the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.




Match of Delaware Death Information Against SSA Records (A-15-18-50662)                           A-2
                       – AGENCY COMMENTS




                                  SOCIAL SECURITY

MEMORANDUM


Date:       November 22, 2019                                                       Refer To:   S1J-3

To:         Gail S. Ennis
            Inspector General


From:       Stephanie Hall
            Chief of Staff

Subject:    Office of the Inspector General Draft Report, “Match of Delaware Death Information
            Against Social Security Administration Records” (A-15-18-50662) -- INFORMATION

           Thank you for the opportunity to review the draft report. We agree with the
           recommendations. We continue to make incremental changes to increase the
           completeness of death information in our records and promote program integrity by
           preventing improper payments.

           Please let me know if we can be of further assistance. You may direct staff inquiries to
           Trae Sommer at (410) 965-9102.




Match of Delaware Death Information Against SSA Records (A-15-18-50662)                            B-1
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