Human Resources
Aon Hewitt Submits Comments on Certification Program for Access to the Death Master File

Aon Hewitt Submits Comments on Certification Program for Access to the Death Master File


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On March 27, 2015, Aon Hewitt submitted comments to the National Technical Information Service (NTIS) on the proposed rule regarding the permanent Death Master File (DMF) certification program to be established pursuant to Section 203 of the Bipartisan Budget Act of 2013. The proposed rule was published in the Federal Register on December 30, 2014.

In the comment letter to the NTIS, Aon Hewitt provided the following suggestions:

  • Revise the definition of "Limited Access DMF" to also exclude date of death if a Person has all other independently verified information for an individual.
  • Do not eliminate the ability of a Certified Person to disclose Limited Access DMF to a non-Certified Person if a contractual agreement is in place.
  • Eliminate the penalty for disclosure under Section 1110.200(a)(1)(iii) if a contractual agreement exists between the parties to protect the Limited Access DMF.
  • Allow alternate approaches for qualifying as an Accredited Certification Body.
  • Use an effective date allowing sufficient time to implement final regulations causing no interruption to access to Limited Access DMF.

The Aon Hewitt comment letter was authored by Robert Martorano (DB Practice Leadership).

Aon Hewitt Submits Comments on Certification Program for Access to the Death Master File