Audit Report
Match of Puerto Rico Death
Information Against Social Security
Administration Records
A-08-14-14013 | August 2019
MEMORANDUM
Date:
August 26, 2019
Refer To:
To:
The Commissioner
From:
Inspector General
Subject:
Match of Puerto Rico Death Information Against Social Security Administration Records
(A-08-14-14013)
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 (SSA) made payments to
beneficiaries and representative payees who were deceased according to Puerto Rico Department
of Health vital records and (2) identify non-beneficiaries who were deceased according to
Puerto Rico vital records but whose death information did not appear in SSA records.
If you wish to discuss the final report, please call me or have your staff contact Rona Lawson,
Assistant Inspector General for Audit, 410-965-9700.
Gail S. Ennis
Attachment
Match of Puerto Rico Death Information Against Social
Security Administration Records
A-08-14-14013
August 2019 Office of Audit Report Summary
Objectives
To (1) determine whether the Social
Security Administration (SSA) made
payments to beneficiaries and
representative payees who were
deceased according to Puerto Rico
Department of Health vital records and
(2) identify non-beneficiaries who
were deceased according to
Puerto Rico vital records but whose
death information did not appear in
SSA records.
Background
To identify and prevent payments after
death, SSA established a program
under which States (and U.S.
territories) can voluntarily contract
with SSA to provide it with death data
to match against SSA’s records. SSA
and the States developed the Electronic
Death Registration (EDR) process to
improve the accuracy and timeliness of
death information. States
electronically submit death reports to
SSA, and, if the numberholder data
match SSA records, SSA systems
automatically post the State death
information and terminate payments to
deceased beneficiaries. Puerto Rico
does not have EDR in place.
Puerto Rico Department of Health
provided us a vital records data file of
the personally identifiable information
of approximately 568,000
numberholders who died in Puerto
Rico from January 1992 through
December 2016. We matched the data
against SSA payment records and
Numident.
Findings
SSA issued approximately $11.6 million in payments after death to
149 beneficiaries and 4 representative payees who died in Puerto
Rico from January 1992 through December 2016. Identifying and
correcting these discrepancies will prevent approximately
$1.4 million in additional improper payments after death over the
next 12 months. We also identified 33,258 non-beneficiaries who
were deceased according to Puerto Rico Department of Health vital
records but whose death information was not in SSA’s Numident.
We could not determine why the deaths were not in SSA’s
Numident or whether Puerto Rico reported the deaths to SSA.
Implementing EDR should help ensure Puerto Rico deaths are
properly and timely reported to SSA.
The Numident contained death information for two of the four
representative payees; however, SSA had not replaced the
representative payees. In several prior audits, we found SSA did
not always replace representative payees after it posted death
information to their Numident records.
Recommendations
We recommend SSA:
1. Take action on the 149 deceased beneficiaries we identified.
2. Take action on the four deceased representative payees we
identified.
3. Take action on the 33,258 deceased non-beneficiaries we
identified to add their deaths to the Numident, as appropriate.
SSA agreed with our recommendations.
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013)
TABLE OF CONTENTS
Objectives ........................................................................................................................................1
Background ......................................................................................................................................1
Results of Review ............................................................................................................................2
Payments Issued to Deceased Beneficiaries ..............................................................................3
Payments to Deceased Representative Payees ...........................................................................5
Deceased Non-beneficiaries .......................................................................................................6
Conclusions ......................................................................................................................................6
Recommendations ............................................................................................................................7
Agency Comments ...........................................................................................................................7
– Scope and Methodology ..................................................................................... A-1
– Agency Comments .............................................................................................. B-1
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013)
ABBREVIATIONS
C.F.R. Code of Federal Regulations
EDR Electronic Death Registration
NAPHSIS National Association for Public Health Statistics and Information Systems
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 Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) 1
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
Puerto Rico Department of Health vital records and (2) identify non-beneficiaries
2
who were
deceased according to Puerto Rico vital records but whose death information did not appear in
SSA records.
BACKGROUND
To identify and prevent payments after death, section 205(r) of the Social Security Act requires
that SSA establish a program under which States (and U.S. territories) can voluntarily contract
with SSA to provide it with death data to match against its records.
3
Accordingly, SSA and the
States developed the Electronic Death Registration (EDR) process to improve the accuracy and
timeliness of death information. Through EDR, 48 States and jurisdictions electronically submit
death reports to SSA,
4
and SSA completes an online, real-time verification of the Social Security
number. If the numberholder data match SSA records, SSA systems automatically post the State
death information to the Numident, an SSA database that stores personally identifiable
information for all Social Security numberholders,
5
and terminate payments to deceased
beneficiaries. EDR is not the only way SSA receives death information; it also receives 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. Puerto Rico does not have EDR in place.
When a representative payee
6
dies, SSA must replace the payee or send payments directly to the
beneficiary.
7
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
1
We use the term “beneficiary” throughout this report in reference to Old-Age, Survivors and Disability Insurance
beneficiaries (OASDI) and/or Supplemental Security Income (SSI) recipients in current payment status.
2
This refers to deceased individuals who were not in current or suspended payment status at the time of our review.
3
Social Security Act, 42 U.S.C. § 405(r)(1) (govinfo.gov 2017). The term “State” includes the Commonwealth of
Puerto Rico. Social Security Act, 42 U.S.C. § 1301(a)(1) (govinfo.gov 2017).
4
National Association for Public Health Statistics and Information Systems (NAPHSIS), Information Systems for
Vital Records Stewardship, naphsis.org (last visited June 27, 2019). NAPHSIS reports that 49 States and
jurisdictions are using EDR, including Puerto Rico. However, as of May 2019, the Puerto Rico Department of
Health stated it is working towards the EDR implementation requirements, but the system is not yet implemented.
5
See SSA, POMS, GN 02602.050, A (October 30, 2017).
6
SSA appoints a representative payee to receive and manage benefit payments for individuals unable to manage
their own finances because of their youth or mental and/or physical impairments. Social Security Act, 42 U.S.C.
§§ 405(j), 1383(a)(2)(A)(ii) (govinfo.gov 2017).
7
20 C.F.R. §§ 404.2050; 416.650 (govinfo.gov 2018).
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) 2
own benefits.
8
The Social Security Act requires that SSA establish a system of accountability for
monitoring representative payees.
9
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.
10
Additionally, if another individual acts as a representative payee
without SSA’s knowledge, that person is not subject to SSA’s financial oversight and reporting
responsibilities—such as reporting events to SSA that may affect the individual’s entitlement or
benefit payment amount.
11
Puerto Rico Department of Health provided us a vital records data file of the personally
identifiable information of approximately 568,000 Social Security numberholders who died in
Puerto Rico from January 1992 through December 2016. 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 deceased individual in the Puerto Rico data file. We also identified individuals
who were not receiving OASDI benefits or SSI payments (that is, non-beneficiaries) 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 $11.6 million in payments after death to 149 beneficiaries and
4 representative payees who died in Puerto Rico from January 1992 through December 2016.
12
Identifying and correcting these discrepancies will prevent approximately $1.4 million in
additional improper payments after death over the next 12 months. We also identified
33,258 non-beneficiaries who were deceased according to Puerto Rico Department of Health
vital records but whose death information was not in SSA’s Numident.
8
20 C.F.R. §§ 404.2050(d), 404.2055 (govinfo.gov 2018). 20 C.F.R. §§ 416.650(d), 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 alternative representative payee before
the next payment is due.
9
Social Security Act, 42 U.S.C. §§ 405(j)(3)(A), (6)(A)-(B), 1383(a)(2)(C)(i), (F)(iv), (G)(ii) (govinfo.gov 2017).
10
20 C.F.R. §§ 404.2040(a); 416.640(a) (govinfo.gov 2018).
11
20 C.F.R. §§ 404.2035; 416.635 (govinfo.gov 2018).
12
At the time of our review, 1 of the 149 beneficiaries’ and 2 of the 4 representative payees’ death information
appeared in the Numident. Therefore, we obtained death certificates for 150 beneficiaries. While we took steps to
ensure the death certificates 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.
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) 3
We could not determine why the deaths were not in SSA’s Numident or whether Puerto Rico
reported the deaths to SSA. Puerto Rico does not have EDR. Implementing EDR should help
ensure Puerto Rico deaths are properly and timely reported to SSA.
The Numident contained death information for two of the four representative payees; however,
SSA had not replaced the representative payees. In several prior audits,
13
we found SSA did not
always replace representative payees after it posted death information to their Numident records.
Moreover, in a July 2019 audit, we found SSA did not follow regulations or its policy to evaluate
all beneficiaries’/recipients’ ability to manage their own funds or select new representative
payees, if appropriate, when the Agency was notified the current representative payees died. We
estimated SSA issued approximately $10.7 million in OASDI benefits and SSI payments to
846 deceased representative payees.
14
Payments Issued to Deceased Beneficiaries
We identified 149 current pay beneficiaries whose personally identifiable information matched
that of a deceased individual in the Puerto Rico death data.
15
Based on our results, SSA issued
these beneficiaries approximately $11.5 million in payments after their deaths. Examples follow.
A beneficiary receiving retirement benefits died in December 2005. SSA records did not
contain a date of death and therefore retirement benefits continued. As of February 2019,
SSA had issued approximately $377,000 in payments after death.
A beneficiary receiving retirement benefits died in June 2003. SSA records did not contain a
date of death and therefore retirement benefits continued. As of February 2019, SSA had
issued approximately $315,000 in payments after death.
A widow receiving survivor benefits died in December 1992. SSA records did not contain a
date of death and therefore the survivor benefits continued. As of February 2019, SSA had
issued approximately $255,000 in payments after death.
Puerto Rico does not report deaths to SSA through the EDR process. According to the Registrar
of the Puerto Rico Department of Health, Puerto Rico cannot make its death data available to
SSA as quickly as jurisdictions with EDR systems.
16
In addition, NAPHSIS stated that
13
SSA, OIG, Deceased Representative Payees, A-01-14-34112, p. 2 (June 2015); Follow up on the Social Security
Administration’s Procedures to Identify Representative Payees Who Are Deceased, A-01-06-16054, p. 3
(October 2006); and The Social Security Administration’s Procedures to Identify Representative Payees Who Are
Deceased, A-01-98-61009, p. 4 (September 1999).
14
SSA, OIG, Follow-up on Deceased Representative Payees, A-01-18-50350, p. 2 (July 2019).
15
At the time of our review, one beneficiary’s death information appeared in the Numident. Therefore, we obtained
death certificates for the remaining 148 beneficiaries.
16
NAPHSIS, Hurricane Maria and Puerto Rico Vital Records – The Difficulties of Death Registration During a
Natu [sic], naphsis.org (March 23, 2018).
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) 4
implementing an EDR system is costly.
17
While EDR is voluntary, according to the Puerto Rico
Department of Health, it received an award from the Centers for Disease Control and Prevention
and is working towards the EDR implementation requirements. SSA stated that “EDR is highly
accurate . . .” and “Universal implementation of EDR has the potential to virtually eliminate
death reporting errors and would ensure that our death records—whether pertaining to current
beneficiaries or other persons—include the most accurate and most current information.”
18
In
2004, SSA began receiving and processing EDR reports of death from several States,
19
and EDR
had slowly expanded to include 48 States and jurisdictions.
20
As illustrated in Table 1,
approximately 75 percent of the beneficiaries SSA improperly paid in Puerto Rico died between
2007 and 2016—several years after SSA first began receiving EDR reports from other States.
Table 1: Beneficiaries Whose Personally Identifiable Information Matched
that of a Deceased Individual in the Puerto Rico Death Data
Year of Death
Number of
Beneficiaries
Percent of Total
Beneficiaries
1992-1996
3
2.0
1997-2001
8
5.4
2002-2006
27
18.1
2007-2011
56
37.6
2012-2016
55
36.9
Total
149
100.0
Source: OIG Analysis of Puerto Rico Death Data.
Of the 149 beneficiaries, 9
21
(6 percent) were receiving SSI payments and died in Puerto Rico.
Under the SSI program, individuals are not eligible to receive SSI payments while living in
17
SSA, OIG, State Use of Electronic Registration Reporting, A-09-15-50023, pp. 6 and A-1 (July 2017). The
Department of Health and Human Services, through the Centers for Disease Control and Prevention, funds States to
assist them in establishing EDR. NAPHSIS, an association of State vital records directors and registrars, worked
with SSA to develop standards and guidelines for a nation-wide EDR system. SSA, OIG, State Use of Electronic
Registration Reporting, A-09-15-50023, p. 2 (July 2017).
18
Examining Federal Improper Payments and Errors in the Death Master File: Hearing Before the Senate
Committee on Homeland Security and Governmental Affairs, 114
th
Congress p. 64 (2015) (statement of Sean Brune,
Senior Advisor to the Deputy Commissioner, Office of Budget, Finance, Quality, and Management, U.S. Social
Security Administration).
19
SSA, OIG, State Use of Electronic Registration Reporting, A-09-15-50023, p. 2 (July 2017).
20
NAPHSIS, Information Systems for Vital Records Stewardship, naphsis.org (last visited June 27, 2019).
NAPHSIS reports that 49 States and jurisdictions are using EDR, including Puerto Rico. However, as of May 2019,
the Puerto Rico Department of Health stated it is working towards the EDR implementation requirements, but the
system is not yet implemented.
21
Three of the nine were dually entitled to both OASDI benefits and SSI payments.
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) 5
Puerto Rico.
22
While we could not determine how long these beneficiaries were in Puerto Rico
before their deaths, each of the nine beneficiaries’ SSI payments went to a U.S. address.
23
In April 2019, we provided SSA the death information for the 149 beneficiaries
24
to terminate
their benefits, initiate recovery of payments made after their deaths, and refer cases with possible
fraud to SSA OIG’s Office of Investigations. As of June 2019, SSA had suspended benefits for
4 of the 149 beneficiaries. Identifying and correcting these discrepancies will prevent
approximately $1.3 million in additional improper payments after death over the next
12 months.
25
Payments to Deceased Representative Payees
We identified four deceased representative payees to whom SSA had issued approximately
$136,000 in payments after their deaths. 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.
26
The Numident contained death information for two of the four representative payees; however,
SSA had not replaced the representative payees. In several prior audits,
27
we found SSA did not
always replace representative payees after it posted death information to their Numident records.
In April 2019, we provided SSA with information on each of the four deceased representative
payees. As of June 2019, SSA had not taken any action on these cases. Identifying and
correcting discrepancies will prevent approximately $25,000 in additional payments after death
over the next 12 months.
28
22
Section 1611(f) of the Social Security Act indicates that, with limited exceptions, no individual shall be considered
eligible for SSI payments for any month throughout which the individual is outside the United States. 42 U.S.C.
§§ 1382(f), 1382c(e) (govinfo.gov 2017).
23
One of the three dually entitled beneficiaries changed her address from Florida to Puerto Rico approximately
3 weeks before her death.
24
At the time of our review, one beneficiary’s death information was in the Numident. Therefore, we obtained
death certificates for the remaining 148 beneficiaries.
25
We based this estimate on the assumption that conditions will remain the same for the next 12 months.
26
20 C.F.R. §§ 404.2050(d), 404.2055, 416.650(d), 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 paying the beneficiary directly would cause substantial
harm, and the Agency cannot find a suitable alternative representative payee before the next payment is due.
27
SSA, OIG, Deceased Representative Payees, A-01-14-34112, p. 2 (June 2015); Follow up on the Social Security
Administration’s Procedures to Identify Representative Payees Who Are Deceased, A-01-06-16054, p. 3
(October 2006); and The Social Security Administration’s Procedures to Identify Representative Payees Who Are
Deceased, A-01-98-61009, p. 4 (September 1999).
28
We based this estimate on the assumption that conditions will remain the same for the next 12 months.
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) 6
Deceased Non-beneficiaries
We identified 33,258 non-beneficiaries
29
who were deceased according to Puerto Rico
Department of Health vital records but who did not have death information in SSA’s Numident.
As illustrated in Table 2, less than 10 percent of these non-beneficiaries died between 2012 and
2016.
Table 2: Non-beneficiaries by Year of Death
Year of Death
Number of
Non-beneficiaries
Percent of Total
Non-beneficiaries
6,870
20.7
8,076
24.3
8,771
26.4
6,302
18.9
3,239
9.7
Total
33,258
100.0
Source: OIG Analysis of Puerto Rico Death Data.
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.
30
In April 2019, we provided SSA with data that identified all
33,258 non-beneficiaries to take necessary action. SSA stated that, because these types of cases
do not involve improper payments, their cleanup is a low priority and resource-dependent. SSA
stated the earliest it could consider posting death information for these cases via the Continuing
Death Data Improvement project under its Information Technology Modernization is Fiscal Year
2020.
CONCLUSIONS
We determined SSA issued improper payments after death or had not recorded death information
on its Numident on a small percentage of approximately 568,000 decedents in the Puerto Rico
Department of Health vital records data file. However, based on our results, we determined SSA
issued approximately $11.6 million in payments after death to 149 beneficiaries and
4 representative payees who died in Puerto Rico from January 1992 through December 2016.
29
We matched Puerto Rico 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.
30
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 Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) 7
Identifying and correcting these discrepancies will prevent approximately $1.4 million in
additional improper payments after death over the next 12 months.
31
In addition, posting death
information to the Numidents of the individuals 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.
We could not determine why the deaths were not in SSA’s Numident or whether Puerto Rico
reported the deaths to SSA. While 48 States and jurisdictions report deaths to SSA through the
EDR process,
32
Puerto Rico does not have this process in place. However, as of May 2019, it
had received an award from the Centers for Disease Control and Prevention and was working
toward implementing EDR. Implementing EDR should help ensure Puerto Rico deaths are
properly and timely reported to SSA. For two of the four deceased representative payees, the
Numident contained death information, but SSA had not replaced the representative payees.
RECOMMENDATIONS
We recommend SSA:
1. Take action on the 149 deceased beneficiaries we identified.
2. Take action on the four deceased representative payees we identified.
3. Take action on the 33,258 deceased non-beneficiaries we identified to add their deaths to the
Numident, as appropriate.
AGENCY COMMENTS
SSA agreed with our recommendations. The Agency’s comments are included in Appendix B.
Rona Lawson
Assistant Inspector General for Audit
31
We based this estimate on the assumption that conditions will remain the same for the next 12 months.
32
NAPHSIS, Information Systems for Vital Records Stewardship, naphsis.org (last visited June 27, 2019).
NAPHSIS reports that 49 States and jurisdictions are using EDR, including Puerto Rico. However, as of May 2019,
the Puerto Rico Department of Health stated it was working towards the EDR implementation requirements, but the
system is not yet implemented.
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013)
APPENDICES
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) A-1
– SCOPE AND METHODOLOGY
To accomplish our objectives, we:
Reviewed Federal laws and regulations related to death matches with State
1
agencies; the
Social Security Administration’s (SSA) policies and procedures; and prior Office of the
Inspector General reports.
Obtained a Puerto Rico Department of Health vital records data file and identified
approximately 568,000 individuals recorded as having died in Puerto Rico from
January 1992 through December 2016. We matched these records against SSA’s
Enumeration Verification System and payment records and identified:
149 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 Puerto Rico death data.
2
Reviewed SSA’s systems, Puerto Rico death data, and LexisNexis, as necessary.
Determined whether SSA (a) documented contact with the beneficiary
3
after the date
of death in Puerto Rico 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 Puerto Rico death certificates for 148 of these 149 beneficiaries (one
already had a date of death on SSA’s Numident) and referred them to SSA.
4 deceased representative payees, with beneficiaries in current payment status as of
April 2019, whose Social Security numbers, names, and dates of birth matched those of
deceased individuals in the Puerto Rico death data. We obtained Puerto Rico death
certificates for two of these four payees as these two did not have a date of death on
SSA’s Numident. We referred these four cases to SSA.
33,258 non-beneficiaries
4
whose Social Security numbers, names, and dates of birth
matched those of deceased individuals in the Puerto Rico death data but whose death
information was not in SSA’s Numident as of March 2019. We referred these cases to
SSA.
1
The term “State” includes the Commonwealth of Puerto Rico. Social Security Act, 42 U.S.C. § 1301(a)(1)
(govinfo.gov 2017).
2
We matched the Social Security number, name, and date of birth on the Puerto Rico Department of Health vital
records data file with SSA’s Numident for the 149 deceased beneficiaries.
3
We use the term “beneficiary” throughout this report in reference to OASDI beneficiaries and/or SSI recipients in
current payment status.
4
This is in reference to deceased individuals who were not in current or suspended payment status at the time of our
review.
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) A-2
Calculated payments issued after death to the 149 beneficiaries and 4 representative payees.
We conducted our audit in Birmingham, Alabama, between November 2018 and May 2019. 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 that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) B-1
– AGENCY COMMENTS
SOCIAL SECURITY
MEMORANDUM
Date:
August 14, 2019 Refer To: S1J-3
To:
Gail S. Ennis
Inspector General
From:
Stephanie Hall
Acting Deputy Chief of Staff
Subject:
Office of the Inspector General Draft Report “Match of Puerto Rico Death Information Against
Social Security Administration Records” (A-08-14-14013) -- INFORMATION
Thank you for the opportunity to review the draft report. Please see our attached comments.
Please let me know if we can be of further assistance. You may direct staff inquiries to
Trae Sommer at (410) 965-9102.
Sincerely,
Stephanie Hall
Acting Deputy Chief of Staff
Match of Puerto Rico Death Information Against Social Security Administration Records (A-08-14-14013) B-2
SSA COMMENTS ON THE OFFICE OF INSPECTOR GENERAL DRAFT REPORT,
“MATCH OF PUERTO RICO DEATH INFORMATION AGAINST SOCIAL
SECURITY ADMINISTRATION'S RECORDS” (A-08-14-14013)
The receipt of timely and accurate death information greatly reduces the occurrence of improper
payments to deceased beneficiaries. The death information we collect aids us in preventing
approximately $50 million in improper payments each month.
The Electronic Death Registration (EDR) process provides us with timely and accurate death
information, and the current President’s Budget provides funding for expansion of EDR to
provide faster, better quality data on deaths. One of EDR’s key features is the ability to match a
deceased person’s Social Security number and other identifying information to our records to
ensure accuracy before submission. We look forward to working with Puerto Rico as they
prepare for EDR implementation. Additionally, we will continue to make incremental changes
to increase the completeness of death information in our records and promote integrity through
deterring improper payments.
Our responses to the recommendations are below.
Recommendation 1
Take action on the 149 deceased beneficiaries we identified.
Response
We agree.
Recommendation 2
Take action on the four deceased representative payees we identified.
Response
We agree.
Recommendation 3
Take action on the 33,258 deceased non-beneficiaries we identified to add their deaths to the
Numident, as appropriate.
Response
We agree to post death information as resources allow for records that pass our screening
process.
MISSION
By conducting independent and objective audits, evaluations, and investigations, the Office of
the Inspector General (OIG) inspires public confidence in the integrity and security of the Social
Security Administration’s (SSA) programs and operations and protects them against fraud,
waste, and abuse. We provide timely, useful, and reliable information and advice to
Administration officials, Congress, and the public.
CONNECT WITH US
The OIG Website (https://oig.ssa.gov/) gives you access to a wealth of information about OIG.
On our Website, you can report fraud as well as find the following.
• OIG news
• audit reports
• investigative summaries
• Semiannual Reports to Congress
• fraud advisories
• press releases
• congressional testimony
• an interactive blog, “
Beyond The
Numbers” where we welcome your
comments
In addition, we provide these avenues of
communication through our social media
channels.
Watch us on YouTube
Like us on Facebook
Follow us on Twitter
Subscribe to our RSS feeds or email updates
OBTAIN COPIES OF AUDIT REPORTS
To obtain copies of our reports, visit our Website at https://oig.ssa.gov/audits-and-
investigations/audit-reports/all. For notification of newly released reports, sign up for e-updates
at https://oig.ssa.gov/e-updates.
REPORT FRAUD, WASTE, AND ABUSE
To report fraud, waste, and abuse, contact the Office of the Inspector General via
Website: https://oig.ssa.gov/report-fraud-waste-or-abuse
Mail: Social Security Fraud Hotline
P.O. Box 17785
Baltimore, Maryland 21235
FAX: 410-597-0118
Telephone: 1-800-269-0271 from 10:00 a.m. to 4:00 p.m. Eastern Standard Time
TTY: 1-866-501-2101 for the deaf or hard of hearing