"The CDC Does Not Maintain Complete Death Certificate Collections"
A good reminder about where U.S. deaths are documented and the records kept - plus some basic facts about how death recording works in America.
I learned something obvious today that I should have realized & articulated much sooner:
States don’t submit death certificates to the CDC or other federal entity — they submit death certificate data.
Responding to an inquiry I submitted about WONDER, the federal death database, a CDC staffer wrote,
"The CDC does not maintain complete death certificate collections, instead it relies on reports of the data associated with them provided by the 50 states and the District of Columbia to publish in WONDER."
There is no central U.S. agency that systematically validates deaths which occur each state/territory. Like births, deaths in most states are recorded at the city or county level and then reported to the state. It is usually the local entity (not the state) which issues a death certificate to the next-of-kin.1
The 2023 edition of the NCHS/NVSS Physician’s Handbook on Medical Certification of Death provides an overview of death certification and processing in the United States. Information from pages 3-5 copied below (citation numbers removed).
U.S. Standard Certificate of Death
The registration of deaths is a state or local function supported by individual state or local laws and regulations. The original death certificates are registered in the states and stored according to state practice. Each state has a contract with NCHS that allows the federal government to use information from that state’s records to produce national vital statistics. NCHS compiles the data collected by the states through the National Vital Statistics System.
To ensure consistency in the National Vital Statistics System, NCHS provides leadership and coordination in the development of a standard certificate of death for the states to use as a model. The standard certificate is revised periodically to ensure that the data collected relate to current and anticipated needs. During the revision process, a review panel evaluates each item on the standard certificate for its registration, legal, genealogical, statistical, medical, and research value. The panel that recommended the current U.S. Standard Certificate of Death includes the American Medical Association, National Association of Medical Examiners, College of American Pathologists, and American Hospital Association.
Most state certificates are similar to the standard certificate in content and arrangement. Minor changes are sometimes made to comply with a state’s laws or regulations or to meet specific information needs. Having similar forms promotes consistent data and comparable national statistics. This also allows for comparison of an individual state’s data with national data and with data from other states. Uniform death certificates also increase their acceptability as legal records.
Electronic death registration
Many states now use electronic death registration systems (EDRS), which are typically secure web-based systems for registering deaths electronically. These systems are designed to simplify the data collection process and enhance communication between medical certifiers, medical examiners and coroners, funeral directors, and local registrars as they work together to register deaths. EDRS are generally similar to the standard certificate in content and structure. The example certifications shown in this guidance are consistent with a generic EDRS, but systems can vary by state. Minor modifications are sometimes needed to meet the specific needs of a state. Some EDRS have built-in edits, prompts, or alerts to improve data quality. Regardless, many of the principles of reporting cause of death on a paper certificate apply to reporting cause of death in EDRS.
The process of submitting a death certificate varies by state, so information on the proper procedure for submitting a death certificate in a given state can be obtained from the state or local registrar.
Confidentiality of vital records
To encourage appropriate access to vital records, NCHS promotes the development of model vital statistics laws concerning confidentiality. A state’s laws and supporting regulations define which people have authorized access to vital records. Some states have few restrictions on access to death certificates. However, most states have restrictions on access to death certificates. Additionally, legal safeguards protecting the confidentiality of vital records have been strengthened over time in some states.
Constitutionally-speaking, the recording of deaths (and births) should of course be done on the local level and the records handled by counties and states, not the federal government. Guidelines, models, and basic requirements for what must be recorded are fine, but I oppose the idea of a national death certificate form.
I’m concerned that direct electronic death registration obscures, changes, and/or circumvents the historical meaning and understanding of a “death certificate.” This 1918 New York death certificate is not data entry, but data can be recorded or entered from this certificate and aggregated with data from other death certificates.
It’s hard to imagine electronic death registration systems are necessarily less prone to error, completion issues, or manipulation - even with data-quality safeguards in place - although the kinds of accuracy issues may change.
Last thought: The NCHS/NVSS/CDC position apparently wants all vital records in every state to be confidential. I strongly disagree.
Public officials/staff are elected and appointed to steward those records on behalf of We the People. Using the New York death certificate above, why would the fact that Vincenza Abbate died at age 57 in Brooklyn on October 17, 1918 need to be a secret? Presumably, those who knew her knew she died. I wouldn’t characterize the causes to which the doctor attributed Vincenza’s death “private medical information”. It’s in the public’s interest to know that the doctor determined she died from bronchiolar pneumonia, with acute cardiac dilation and bronchial asthma as contributory causes.
If the past four years have taught us anything, it’s that government has every incentive to lie about death — i.e., number of deaths that occurred in a period, from an event or cause, and/or in a place.
Automatic public disclosure of — or unmitigated access to — death certificates is critical to holding officials at every level of U.S. government accountable for their claims about deaths. ⬇️
I haven’t conducted a review of how this works in every state and am speaking generally.
Confidential death certificates make it much easier to keep dead people on voter rolls. This can come in handy for governments at all levels.
I would assert that anything that falls under HIPPAA can be kept private and all other information can be available to the public. The government has proven that they are very adept at redaction. Most people publish announcements of a loved ones death in local papers or on websites. Not to mention all the information now published through census and ancestry websites.