A three-year pilot gave the Treasury Department access to the Social Security Administration’s (SSA) full Death Master File and generated nearly $109 million in net benefits in its first year, but the Government Accountability Office (GAO) says SSA’s approach to paying states and allocating data costs doesn’t meet statutory requirements.
The pilot began in December 2023 after Congress granted SSA temporary authority to share its full death file with Treasury’s centralized Do Not Pay data-matching system. Agencies use the system to verify eligibility before issuing federal payments, GAO said in its new report.
Prior to that authorization, the Treasury Department was able to access a limited amount of information from SSA databases, which notably excluded death data.
In 2025, the Treasury reported that it identified, prevented, or recovered $113.5 million in improper payments across 2024 after integrating the SSA’s death file. The department also cited a 174% increase in death record matches, and improved timeliness and coverage compared with other death data sources in the system, strengthening up-front data verification, GAO said.
However, GAO said SSA more than doubled what it pays states for death data under new contracts that took effect in late 2023, raising payments from $8.8 million in 2023 to $23.8 million in 2024 – a 172% increase.
Under the new agreements, SSA estimates it would pay $132 million to states over five years if all contract options are exercised, GAO reported.
The Social Security Act requires SSA to reimburse states for specific costs, including “(1) a fee for use of the data and (2) the full documented cost of transmitting the data to SSA.” But GAO said it found that SSA did not obtain the required state cost information and instead negotiated a fee structure based on how quickly states submit death records.
Without documented cost data, GAO said SSA “does not know if it is paying too much or too little for states’ data,” limiting its ability to ensure prices reflect statutorily authorized costs and to renegotiate fees if necessary.
GAO also raised concerns about how SSA allocates the cost of obtaining state death data among federal agencies that use the file – a key interoperability issue as more systems rely on shared data.
For 2025, SSA changed its methodology and calculated its share of costs based on its total federal outlays, deciding it would cover 23% of state death data costs, while distributing the remaining 77% to Treasury and other agencies without applying the same approach to them.
GAO found SSA’s allocation method “was not based on considerations related to agencies’ proportional share of costs,” and warned that reimbursement amounts may not accurately reflect each agency’s use of the data.
That lack of a consistent, cost-based methodology may limit agencies’ ability to assess the cost-effectiveness of integrating the full Death Master File into their systems. It also increases the risk that some agencies subsidize others’ access, the federal watchdog said.
GAO recommended that SSA ensure contracts reflect statutorily authorized costs and required documentation, analyze state cost information and determine whether to renegotiate the fee schedule, and revise its methodology for allocating costs to incorporate proportional shares of state death data expenses. SSA agreed with those recommendations.