Section 44104 of the “Big Beautiful Bill”: Master Death File

Imagine your billing office closing the books for the quarter. One report shows that Medicaid still lists Mr. Thompson as an active beneficiary, even though your hospice team certified his passing six months ago. Because the state never updated its eligibility file, you continued to send claims against a policy that, on paper, still covered a living person. Today’s payment will be deposited into your account, but next winter, an audit could demand repayment, trigger interest charges, and require staff to spend hours gathering medical records. Section 44104 of the “Big Beautiful Bill” exists to stop that cycle before it starts. Starting in 2028, every state Medicaid agency must cross-check its enrollment roster against the Social Security Administration’s Death Master File (DMF) at least four times a year. The DMF is the federal government’s definitive ledger of individuals reported deceased, compiled from funeral home filings, family notifications, and, in most cases, coroner or medical examiner certificates. Whenever a Social Security number appears in that file, the agency treating the person as alive must investigate and, if warranted, close the case immediately. From your vantage point, the most apparent benefit is revenue certainty. You rely on accurate eligibility responses at registration and clean payments on the back end. When a state removes a deceased member promptly, three good things happen:

a) Cleaner eligibility checks: The front-desk staff no longer face the awkward moment of explaining to a grieving spouse that the system still shows coverage, then hunting for a supervisor who can override the account. A live quarterly sweep reduces those mismatches.

b) Fewer post-payment recoupments: Each time a service date lands after the patient’s date of death, the claim becomes an automatic target in program-integrity reviews. Getting the policy terminated within weeks — rather than years — saves the finance team from future claw-backs.

c) Lower administrative drag: When Medicaid pursues an improper-payment recovery, you must supply chart notes, physician signatures, and sometimes copies of nursing logs to prove that care was appropriate. Every hour spent gathering that paperwork is an hour not spent optimizing throughput or negotiating commercial contracts.

States already receive periodic DMF extracts; however, the timetables vary, and resource constraints often result in backlogs. Section 44104 forces discipline:

  • A quarterly cadence ensures that no enrollee remains on the active list for more than three months after death, except in cases where data-entry lag on the SSA side occurs.
  • Automation pushes the heavy lifting to software. Medicaid eligibility systems will ingest the DMF file, flag matches, and queue them for case-worker verification.
  • Hard deadlines tie state compliance with federal funding. If a state ignores the rule, it risks financial penalties that far outweigh the cost of running the match.

The electronic health record system regularly pings state eligibility portals to verify coverage. Once the quarterly match becomes routine, you can expect:

  • Fewer false positives in real-time eligibility (RTE) pings — reducing manual overrides.
  • Tighter coordination with hospice providers — because death records and eligibility files will reconcile faster, hospice claims stand a much smaller chance of bouncing.
  • Improved key-performance indicators — days in accounts receivable drop, and denial rates tied to eligibility shrink.

Even before the rule takes effect, you can align hospital processes by:

  • Ask your EHR vendor whether the system can automatically check a patient’s reported date of death against claim dates, then hold mismatched encounters for review.
  • Work with your state hospital association to ensure the Medicaid agency offers a fast lane for submitting death certificates or hospice discharge summaries.
  • Train registration staff to confirm identity details — such as Social Security number, address, and date of birth — so the eventual DMF match has clean data to compare.

The Bottom line. Section 44104 turns death-record reconciliation from a sporadic housekeeping task into a calendar-driven, system-wide requirement. When the state updates its rolls every quarter, your organization receives more precise eligibility data, fewer recoupment letters, and a smoother revenue cycle.

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