Users of the Social Security Death Master File, including insurers, and employer and retirement industry organizations, are putting on a strong push for interested parties to send letters to the Department of Commerce (DOC) urging prompt action on an interim rule that will ensure access to the DMF for legitimate users while the agency crafts final rules providing a certification process to the data.
In the latest development, the Office of Management and Budget (OMB) has posted a form for public review and comment that would permit access to the DMF through a self-certification form, according to Michael Freedman, founder of Sentinel Solutions in Philadelphia. The form is titled the “Subscriber Certification Form,” and the comment period on the form ends Monday. “This gives only a few days for the tens of thousands of users of the DMF to get the form and send it in,” Freedman said. Sentinel Solutions deals with life settlement and similar solutions.
Freedman also represents the Coalition for Death Master File Implementation and Reform, in conjunction with the American Continental Group, a D.C.-based lobbying firm. This group is amongst the groups leading a strong employer, congressional and insurer initiative aimed at maintaining seamless access to the DMF.
Currently, the recent Budget Act contains a provision limiting public access to the DMF effective March 26. It requires the DOC to develop a certification program to allow persons meeting certain criteria to have continued access to the DMF. Industries involved in this initiative want the DOC’s National Technical Information Service (NTIS) to impose an interim rule by the 26th to ensure continued access while a final certification process is crafted.
Freedman cites a March 14 letter on the issue to OMB signed by 19 senators and two ranking members of the House – Rep. Paul Ryan, R-Wis., chairman of the House Budget Committee, and Rep. Richard Neal, D-Mass., a member of the House Democratic leadership and a ranking member of the House Ways and Means Committee.