GAO Report on Do Not Pay System Benefits and SSA Death Data Costs
Summary
A GAO report highlights that the Treasury's Do Not Pay system, using SSA death data, is projected to yield $337 million in benefits over three years. However, increased SSA costs for state death records and improper cost allocation among agencies require attention.
What changed
The Government Accountability Office (GAO) has released a report detailing the significant benefits of the Department of the Treasury's "Do Not Pay" system, which leverages Social Security Administration (SSA) death data. A pilot program has already identified $113.5 million in improper payments, with projections of over $337 million in net benefits over three years. This access to state death records, previously limited, is now being made permanent through proposed legislation.
However, the report also identifies issues with SSA's cost management for state death records. New contracts have substantially increased SSA's expenses, and the agency has not appropriately allocated these costs to other federal agencies, including Treasury, that utilize the data. GAO recommends addressing these cost allocation and data acquisition issues to ensure proper financial stewardship. Agencies that use the data must be aware of potential adjustments to their cost-sharing obligations.
What to do next
- Review GAO recommendations regarding SSA cost allocation for state death records.
- Assess agency's share of SSA death data costs and ensure proper reimbursement.
- Monitor legislative developments regarding permanent access to the Death Master File.
Source document (simplified)
GAO-26-107181 Published: Feb 12, 2026. Publicly Released: Feb 12, 2026.
Fast Facts
The Department of the Treasury administers the "Do Not Pay" system, which agencies use to verify if people are eligible for certain payments.
The Social Security Administration pays for death data from states to know when to stop its benefit payments. Treasury recently gained access to this data for the Do Not Pay system, and it projects benefits of approximately $337 million for the first 3 years.
New data contracts with states have increased SSA's costs. Treasury and other agencies that use the data must reimburse SSA for a share of the costs. But SSA didn't appropriately determine the agencies' share. We recommended addressing this and more.
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Highlights
What GAO Found
Under a 3-year pilot program, the Department of the Treasury’s Do Not Pay system has temporary access to the Social Security Administration’s (SSA) full Death Master File. Prior to the pilot, the system had access to a less-comprehensive version of the file which excluded state death records. In January 2026, Congress passed a bill that, if enacted, would make access permanent.
In April 2025, Treasury reported that the first year of this pilot (calendar year 2024) resulted in identification and prevention or recovery of $113.5 million in improper payments. This amount, offset by $4.6 million in costs, represented a return on investment of about 23 times Treasury’s pilot costs. Treasury projects that the pilot will result in over $337 million in net benefits over 3 years.
Death data collected by states are their property, and statute requires SSA to pay states for use of these data. In September 2023, SSA concluded negotiations on new contracts to obtain states’ death data. Under these contracts, SSA paid states $23.8 million in 2024, a significant increase from 2023.
SSA’s Actual and Estimated Future Costs for State Death Records, 2023–2028
The Social Security Act, as amended, specifies that SSA shall reimburse states for specific costs associated with death data, including (1) a fee for use of the data and (2) the full documented cost of transmitting the data to SSA. However, GAO found that SSA did not obtain the required state cost information and therefore did not consider it during negotiations. Instead, SSA and the states agreed on a fee structure based on the timeliness of submission of death records.
Agencies receiving state death data must pay SSA a proportional share of its costs in obtaining the data from states. Of the $25.9 million in estimated state death record costs for 2025, SSA’s proportional share is projected to decline, from 42 percent in 2024 to 23 percent in 2025, due to a methodology change. Specifically, SSA calculated its 2025 share based on the percentage of SSA’s total federal outlays rather than on costs of obtaining data. SSA estimated that its outlays were about 23 percent of the federal total, so it decided that would be its cost share for 2025. For the remaining 77 percent, SSA distributed 36 percent to Treasury and 41 percent to other agencies without regard to cost (each of the other agencies is to contribute the same amount, approximately $1.533 million).
Why GAO Did This Study
Improper payments remain a long-standing and significant problem in the federal government. GAO previously reported that one strategy to help prevent improper payments is up-front verification of eligibility through data sharing and matching. Agencies can verify the eligibility of applicants through Treasury’s Do Not Pay system—a centralized data-matching service for agencies to use in preventing and detecting improper payments. This service currently includes the full Death Master File, SSA’s compilation of deceased Social Security number holders, to help agencies prevent improper payments.
This report (1) describes the first-year results of the 3-year pilot to include SSA’s full Death Master File in Treasury’s Do Not Pay system, (2) evaluates the extent to which SSA’s payments for state death data are based on states’ documented costs, and (3) evaluates the extent to which SSA is charging agencies a proportional share of its costs. GAO analyzed SSA and Treasury documentation and interviewed federal and state agency officials.
Recommendations
GAO is making three recommendations to SSA to (1) ensure that contracts for state death data reflect statutorily authorized costs and include necessary documentation required by law; (2) conduct an analysis of state cost information, including its availability, and determine whether renegotiating the fee schedule accordingly is necessary; and (3) revise its methodology to incorporate costs for calculating proportional shares of state death data costs. SSA agreed with GAO’s recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
| --- | --- | --- |
| Social Security Administration | The SSA Commissioner should ensure that contracts for state death data reflect statutorily authorized costs and include necessary documentation required by law. (Recommendation 1) | Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information. |
| Social Security Administration | The SSA Commissioner should ensure that SSA conducts an analysis of state cost information, including its availability, and determine whether renegotiating the fee schedule for state death data is necessary to ensure that prices reflect statutorily authorized costs. (Recommendation 2) | Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information. |
| Social Security Administration | The SSA Commissioner should ensure that SSA revises its methodology for allocating costs to obtain state death data to incorporate costs for calculating proportional shares of state death data costs. (Recommendation 3) | Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information. |
Full Report
GAO Contacts
Hannah Padilla Director Financial Management and Assurance padillah@gao.gov
Media Inquiries
Sarah Kaczmarek Managing Director Office of Public Affairs media@gao.gov
Public Inquiries
Topics
Retirement Security Death data Deaths Improper payments Claims payments Federal agencies Pay systems Unemployment insurance Cost allocation Social security numbers Contract payments
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