Update: Death Master File — Request for Comments on Proposed Final Rule

Yesterday, I published an announcement from Fred Moss of the Records Preservation and Access Committee, a joint committee of the Federation of Genealogical Societies, the National Genealogical Society, and the International Association of Jewish Genealogical Societies/ Today, Jan Meisels Allen, Chairperson of the IAJGS Public Records Access Monitoring Committee added some more details:

… the National Technical Information Service (NTIS) Notice of Proposed Rulemaking (Notice) describing a rule that would, if implemented, establish, pursuant to Section 203 of the Bipartisan Budget Act of 2013 (Pub. L. 113-67), a certification program to replace the temporary certification program currently in place for access to the Death Master File (DMF). While the NTIS expected the Federal Register to publish the Notice of Proposed Rulemaking on December 24, the Federal Register published it today, December 30. The deadline for comments to be submitted is January 29, 2015. To read the proposed rule see: http://www.gpo.gov/fdsys/pkg/FR-2014-12-30/pdf/2014-30199.pdf.

The purpose is to reduce opportunities for identity theft and restrict information sources used in filing fraudulent tax returns. The requirements spelled out in the proposed rule follow the requirements established last year in Congress’ s passage of Section 203 of the Bipartisan Budget Act of 2013 (Pub. L. 113-67). The rule establishes those who can have immediate access to the Limited Access Death Master File for those users who demonstrate a legitimate fraud prevention interest of a legitimate business purpose for the information.

One of the “positive” changes is the provision if someone provides the data element(s) that are included in the DMF (name, social security number, date of birth, or date of death) whether that person is certified or not, and the information is obtained independent of the Limited DMF, the information is not considered part of the Limited Access DMF. However, if a certified person receives this information independent from the Limited Access DMF it is not considered part of the DMF if the NTIS source information is replaced with the newly provided information. This is one area the proposed rule is requesting the public to comment.

One of the more onerous provisions, especially for genealogists, is the required security audits by independent third party assessment bodies and requirements to meet those standards. These assessments are required to become certified. The person must submit a written attestation from an Accredited Certification Body that the applicant has information security systems, facilities, and procedures in place to protect the security of the DMF information.

There are penalties ranging from $1,000 to $250,000 for the certified person unauthorized disclosure of the information.

There is no specific mention of the charges that NTIS will impose for accessing the data once the person is certified. However, the current fees are substantial. These are fees in addition to the certification fee—which the proposed rule states NTIS will charge but not what they charge. Currently they are charging $200 for the certification fee only.

For those who are considering applying for certification I suggest you read Dee Dee King’s article on her experience of becoming certified. Not only is the access to the information very costly, the restricted database no longer provides many of the data elements we were used to in the Social Security Death Index (SSDI)—the commercial version of the DMF, nor does it have a search engine that the genealogical firms used that facilitated the search.
Dee Dee’s article : http://tinyurl.com/kr9g48z (Original url:

IAJGS along with other members of the Records Preservation and Access Committee will be submitting our comments by the designated January 29, 2015 deadline.

Jan Meisels Allen
Chairperson, IAJGS Public Records Access Monitoring Committee


Our government – by the people and for the people????


May I suggest that these silly people go back and read Megan Smolenyak’s excellent articles on SSDI and identity theft?

Liked by 1 person

This is idiocy! The easiest way to prevent fraud is to allow TOTAL access to everyone so any financial institution can check against the listing anyone trying to commit fraud!!!


Absolute idiocy!
Prevent fraud by allowing EVERYONE access to the information so that financial institutions and government agencies can check applicant info against the data of all those deceased. Simple!


What would be a good letter to send? Is there a petition that states the requirements and desires of the average amateur genealogists?


I deeply regret the loss of the SSDI which among things I have used as a tool to determine the whereabouts of members of my lineage organization. However for genealogical purposes, although it was a wonderful tool in its time, and indeed I did use it to order the records to establish the names of my great grandparents, to a large degree that information is now available through many other sources. The one place where it really cannot be duplicated with online sources is in “jumping the pond,” ie identifying ancestors in a foreign country whose records are not on line, who never came to the U.S. Fortunately for most of those, the time frame is far enough back that the Social Security applications are still available.


While we need to secure the identity of living individuals, providing security for dead individuals can be done top down–but not in such an onerous manner. Simply leave the SSN off the Social Security Death Index sold to genealogical data suppliers.

The other thing is for people to NEVER use the SSN as part of genealogical proof. Refer to the data and the supplier, but leave off the number.


I have used the SSDI for genealogical purposes for many years. But I have also used it for another purpose. As an officer of a non-profit organization, I have used it to check and see if a member with whom we have lost contact has died. If we can’t determine the death, we must pay state and national per-capita fees and insurance on them, even when they are not active. This is very hard on small organizations, so the SSDI was a wonderful tool for this purpose.


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