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RMV Issued 1,905 Licenses After Licensees’ Dates of Death and Did Not Deactivate 4,688 Licenses for Individuals Who Died Before Their Licenses Expired.

Audit calls on the RMV to improve its use of data to identify deceased individuals and ensure licenses are not issued in their names.

Table of Contents

Overview

From the more than 4 million license files we reviewed for licenses that were active during the audit period, we determined that RMV had issued 1,905 licenses to individuals after their dates of death, and 1,840 (97%) of these five-year licenses were still listed as active in January 2018.

On December 6, 2016, RMV entered into a partnership with DPH whereby DPH sends RMV a file identifying people who have died and RMV runs a program to check the “deceased indicator” in the RMV master file. If a deceased person is not marked as such, the program updates the deceased indicator that is visible when RMV is preparing to issue a license. If a clerk then processes a license application, the Automated Licensing and Registration System (ALARS) screen alerts the clerk if there are any issues related to the SSN (including the person’s having died) and prevents processing of the license.

The dates of death for 1,862 of these individuals were before the beginning of the audit period, and some were as early as 1962, as indicated in the table below. Most of the death dates (1,548) were between 1988 and 2010. Because these licenses appeared to have been issued to individuals who were attempting to obtain false identification, there is a significant risk that they could be used for malicious purposes (e.g., fraud).

Licenses Issued after Death

Year of Death

Number of Individuals Deceased

Percentage of Total

1960–1965

3

0.2%

1966–1971

21

1.1%

1972–1976

24

1.3%

1977–1982

6

0.4%*

1983–1987

16

0.8%

1988–1993

294

15.4%

1994–1999

403

21.1%*

2000–2004

448

23.5%

2005–2010

403

21.1%*

2011–2016

287

15.1%

Total

1,905

100%

*    Discrepancies in percentages are due to rounding.

 

In addition, from 4 million license files active during the audit period, we determined that 17,427 license holders died after the issue date and at least 45 days before the expiration date. Although 11,598 of these licenses were listed as expired in January 2018, 4,688 of these individuals were still listed as having an active license at that time.

Authoritative Guidance

RMV’s License Policy Training Manual states,

Every customer over the age of 18 must present the following core documents when applying for a permit, license, or ID . . .

  • Verifiable SSN or Denial Notice with visa, I-94, and current non-U.S. Passport
  • Document Proving Massachusetts Residency
  • Document Proving Signature
  • Document Proving Date of Birth

Further, according to this manual, RMV’s policy is to run various background checks on any person who has applied for a new license, a license renewal, or a license upgrade and to deny the requested transaction if the check identifies specific problems. Such problems might include applicant information indicating that the applicant is deceased. RMV management is responsible for establishing adequate controls over this process to ensure compliance.

Reasons for Noncompliance

RMV did not adequately cross-check license holders’ dates of death listed in the DPH Vital Statistics File with any other valid database attesting to the dates of death, such as the Death Master File, before issuing a license or deactivating a license for an individual who died before the license expiration date. Although RMV obtained a Death Master File monthly, the file was often not up to date; sometimes it did not show a date of death until four to six months after the death. Although RMV began receiving the DPH Vital Statistics File weekly on December 6, 2016, that file is limited to deaths in Massachusetts. Some licenses were still issued in late December 2016 for individuals listed in the Death Master File, which suggests that the control is not operating effectively.

Recommendations

  1. Rather than using the DPH Vital Statistics File to provide a notification of death, RMV should use another source, such as the Death Master File, to verify death dates for individuals who die before license expiration and immediately change their license status to expired.
  2. RMV should strengthen controls to verify that people named on license applications are not deceased, perhaps by instituting a check against the Death Master File that does not limit the list to individuals in Massachusetts.

Auditee's Response

The RMV used during the audit period and continues to use the Social Security Administration’s Death Master File, which it supplemented in 2016 by adding the Massachusetts DPH Vital Statistics File including death records.

During the audit period, the RMV was using the 30-year-old ALARS system as the system of record for driver licensing. Upon notification of a customer’s death (via the Social Security Administration’s Death Master File or the Massachusetts Department of Public Health’s Vital Statistics File including death records), the customer record was marked “Deceased.” The RMV did not alter the record by marking the license as expired. A customer record marked “Deceased” was a systematic stopper preventing any further transactions from taking place.

The RMV has been unable to recreate the Auditor’s finding of 1,905 licenses issued after date of death. We reviewed a subset of 105 licenses from this file. All 105 individuals were positively identified as currently alive. Furthermore, on January 17, 2018, the Auditor and the RMV met to conduct an informal exit conference prior to the issuance of this report. At that time, the Auditor had reviewed 662,000 license applications and identified 36 records as potentially issued after the licensee’s date of death. The RMV referred those 36 records to the Massachusetts State Police for further investigation. Subsequently, the Auditor requested access to the entire database of licenses active during the audit period (July 1, 2014–December 31, 2016), which is over 4 million records. Based on the initial finding, one might expect something on the order of 200 licenses to be identified as potentially issued after the licensee date of death. The Auditor’s finding of 1,905 records is not in line with its own review. The RMV will continue reviewing the records, along with the [Social Security Administration, or SSA] and DPH death file records for any inconsistencies. Any anomalies will be referred to the Massachusetts State Police for investigation.

With regard to the 4,688 licenses that were not “deactivated” after the death of the licensee, the ALARS system, which is no longer used for driver licensing, marked a customer record as “Deceased” upon notification that a customer had died. The RMV did not alter the record by changing the license status as expired. The ALARS system did not have a function to deactivate a license. A customer record marked “Deceased” was a systematic stopper preventing any further transactions from taking place.

The RMV’s new ATLAS system also uses the SSA Death Master File data and the Massachusetts Department of Public Health’s Vital Statistics File to identify customers as deceased and mark their records accordingly. ATLAS has the capability to mark the customer and the license status as “Deceased” and stop all transactions from that record.

Auditor's Reply

During our audit, RMV management told us that the agency had previously employed the Death Master File during the audit period but transitioned to the DPH system. Given the large number of licenses issued after death during the audit period, it appears that information from these sources had not been properly updated in RMV’s ALARS database during the audit period and that this allowed valid licenses to be issued to individuals after the date the Death Master File indicated that they had died.

In its response, RMV states that it reviewed a subset of 105 licenses from our sample of 1,905 and found that all 105 individuals were alive. Since we do not know what type of analysis RMV used to conduct its testing on these data, and this information was not provided to us during our audit, we cannot comment on RMV’s stated results. However, for our analysis, we queried all people who were license holders during our audit period and, when they had SSNs, compared them with the Death Master File and produced a file that listed all individuals who were issued licenses by RMV at least 30 days after their dates of death. It should be noted that this is the same analysis we used to identify the 36 initial records that indicated that a deceased person had been issued a license by RMV, which RMV ultimately confirmed to be a potential problem and referred to the State Police.

Contrary to what RMV asserts, the 36 questionable licenses did not come from a population of 662,000 license applications but from a population of 1,686,045 licenses issued during the audit period. We obtained the 1,905 licenses issued after death from a population of more than 4 million individuals who held licenses during the audit period. Since a license is valid for 5 years, many of the licenses in this population had issue dates as early as July 2009. The majority (1,862) of the death dates were before the beginning of the audit period, which means the licenses were issued between 2009 and 2014.

We understand that setting the record to “deceased” for these 4,688 license files prevents further processing of the license. However, the status code (active, suspended, or expired) in ALARS for these licenses was still listed as active; this was visible on a routine inquiry. This active status code for a deceased person could remain for over 4 years if the person died shortly after the license issue date. We observed that an additional 11,598 licenses whose holders died after the license issue dates were, in fact, listed as expired. It is reasonable to OSA that if RMV can use this status code in some instances, it could use it in any instance where the license holder has died.

Date published: September 6, 2018

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