A recent audit from the U.S. Department of Health and Human Services Office of Inspector General (OIG) highlights a costly and persistent issue: payments continuing after a recorded mortality event.
The numbers are significant. Medicaid agencies made an estimated $207.5 million in unallowable capitation payments to managed care organizations on behalf of deceased enrollees in a single year¹.
This is not a new problem. Since 2016, audits have identified approximately $289 million in improper payments tied to individuals whose mortality events had already occurred¹.
Together, these figures point to a broader issue across systems that rely on accurate and timely mortality data.
The Problem: Delayed and Disconnected Data
At its core, this is not a lack-of-data problem, it’s a timing and integration problem.
The audit found that 99 out of 100 sampled payments were made after the individual had already passed¹, highlighting how frequently systems fail to act on available mortality information.
In many cases, mortality data existed but was not reflected in the systems responsible for stopping payments. This disconnect creates a gap between when a mortality event occurs and when organizations can act on it.
Where the Breakdown Happens
The report outlines several common failure points that lead to improper payments:
Mortality data is not always captured or updated in internal systems in a timely manner.
Information may exist in external datasets, such as the Social Security Administration’s Death Master File (DMF), but access can vary and is often limited for non-federal entities².
Even when mortality data is available, delays in reconciliation and system updates allow payments to continue.
These challenges demonstrate that having access to data is not enough, organizations must be able to validate and act on that data quickly.
A Broader Industry Challenge
While this audit focuses on Medicaid, the implications extend well beyond healthcare.
Pension plans, insurance carriers, and financial institutions all face similar risks when managing ongoing payments tied to individuals. Without timely mortality verification, organizations may experience:
- Continued payments after a mortality event
- Increased compliance and audit exposure
- Operational inefficiencies driven by manual reconciliation
The underlying issue remains consistent across industries: delayed data leads to overpayments and audit risk.
Increasing Regulatory Pressure
Regulators are taking steps to address the issue. Beginning in 2027, Medicaid programs will be required to check the Social Security Administration’s Death Master File at least quarterly to identify deceased enrollees and discontinue payments¹.
However, the requirement to use the DMF does not guarantee access to the full dataset. In practice, access to the complete file remains restricted, and many organizations rely on limited versions that may exclude certain records. More information on access requirements can be found through the Social Security Administration and the National Technical Information Service (NTIS)².
Additionally, the inclusion of supplemental data sources in regulatory guidance reinforces a key reality: compliance with a single data source does not ensure complete coverage.
In environments where payments are processed continuously, relying on periodic checks or incomplete datasets can leave critical gaps.
Moving Toward Ongoing Mortality Tracking
To reduce risk, organizations are shifting toward more proactive approaches to mortality verification.
This includes:
- Ongoing or frequent verification instead of periodic checks
- Integrating multiple data sources to improve accuracy and coverage
- Automating updates to ensure systems reflect the most current available information
While reporting timelines can vary by source, improving both the speed and quality of mortality data can significantly reduce financial exposure and improve compliance outcomes.
Why Organizations Choose Abacus Intel
Closing the gap between mortality events and system updates requires more than access to data, it requires actionable intelligence.
Abacus Intel provides:
- 99% accuracy mortality verification in the US
- Multi-source data integration for 97% coverage
- Ongoing mortality tracking to support timely updates
- Automated workflows that reduce manual intervention
- Transparent, audit-ready reporting
The result is a more proactive approach to managing risk, improving operational efficiency, and maintaining data integrity.
The OIG report makes one thing clear: the cost of delayed mortality data is measurable and preventable.
Click here to see how Abacus Intel helps organizations reduce improper payments and strengthen data accuracy.
Sources:
¹ U.S. Department of Health and Human Services, Office of Inspector General (2025).
Medicaid Agencies Made Millions in Unallowable Capitation Payments to Managed Care Organizations on Behalf of Deceased Enrollees.
https://oig.hhs.gov/reports/all/2025/medicaid-agencies-made-millions-in-unallowable-capitation-payments-to-managed-care-organizations-on-behalf-of-deceased-enrollees/
² Social Security Administration / National Technical Information Service (NTIS).
Death Master File (DMF) Access & Certification Requirements.
https://www.ssa.gov
