IMPROPER 

PAYMENTS

Strategy and 

Additional Actions 

Needed to Help 

Ensure Agencies Use 

the Do Not Pay 

Working System as 

Intended

Accessible Version

Report to the Ranking Member, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

October 2016

GAO-17-15

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-15, a report to the 

Ranking Member, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate

October 2016

IMPROPER PAYMENTS

Strategy and Additional Actions Needed to Help 

Ensure Agencies Use the Do Not Pay Working 

System as Intended

What GAO Found

The Office of Management and Budget (OMB), in coordination with the 

Department of the Treasury (Treasury), developed the Do Not Pay (DNP) 

working system as a data matching service for agencies to use in preventing 

improper payments, but GAO found that the DNP working system offers either 

partial or no access to three of the six databases required by the Improper 

Payments Elimination and Recovery Improvement Act of 2012, as amended. 

Specifically, the DNP working system offers no access to the Social Security 

Administration’s (SSA) prisoner records and partial access to the Credit Alert 

Interactive Voice Response System and SSA’s death records. The death records 

offered through the DNP working system do not include state-reported death 

data. SSA officials stated that sharing its full death file—which includes statereported death data—would require an amendment to the Social Security Act. 

Sharing the full death file through the DNP working system would enhance

efforts to identify and prevent improper payments. 

The 10 agencies GAO reviewed have used the DNP working system in limited 

ways, in part because of a lack of clear OMB strategy and guidance. The most 

common way these agencies used the DNP working system is through its

payment integration process, whereby Treasury compares disbursements it 

makes with DNP databases. However, Treasury matches against only two 

databases, and because the matching is performed simultaneously with 

disbursement, agencies generally do not receive the results in time to prevent 

improper payments. Further, because the payment integration process is built 

into Treasury’s payment process, it does not compare payments disbursed 

through other means, such as payments made by the Defense Finance and 

Accounting Service ($477 billion in fiscal year 2015). OMB and Treasury 

guidance do not fully address the limitations of the payment integration process 

or whether its use is required. Aside from payment integration, 6 of the 10 

agencies GAO reviewed used the DNP working system in limited ways, and 9 of 

the 10 agencies used some of the databases outside the DNP working system. 

OMB has not developed a strategy or communicated through guidance how it 

expects agencies to use the DNP working system. As a result, agencies may not 

effectively and efficiently use the system to help reduce improper payments.

Although OMB collects certain information about the use of the DNP working 

system, it has not developed monitoring mechanisms, such as goals or 

performance measures. Reported savings from use of the DNP working system 

have been minimal. OMB reported that the overall DNP Initiative (which 

encompasses the DNP working system and other agency-specific efforts)

prevented over $2 billion in improper payments in fiscal year 2014, but none of 

these savings resulted from use of the DNP working system. Further, while OMB 

has not reported on fiscal year 2015 results, the 24 Chief Financial Officers Act 

agencies reported about $680,000 in improper payments prevented through use 

of the system in fiscal year 2015. However, GAO identified instances in which 

such agency-reported information was not consistent with reports generated by 

the system. Without monitoring mechanisms and reliable data, OMB cannot 

effectively evaluate the DNP working system or identify and address 

performance issues.

View GAO-17-15. For more information, 

contact Beryl H. Davis at (202) 512-2623 or 

davisbh@gao.gov.

Why GAO Did This Study

Improper payments are a longstanding, significant problem in the 

federal government, estimated at 

nearly $137 billion in fiscal year 2015. 

GAO previously reported that one 

strategy to help prevent improper 

payments is up-front verification of 

eligibility through data sharing and 

matching. Established by OMB in 2011

and hosted by Treasury, the DNP 

working system is a web-based, 

centralized data matching service.

GAO was asked to review the DNP

working system. This report examines 

the extent to which (1) OMB and 

Treasury developed the DNP working 

system and obtained access to 

relevant databases, (2) selected 

agencies used the DNP working 

system to help review eligibility, and 

(3) OMB monitored the use of the 

system. GAO reviewed relevant laws

and guidance; interviewed officials at

OMB, Treasury, and 10 user agencies

selected in part based on size and 

reported improper payment estimates, 

including those with the largest 

reported estimates; and analyzed DNP 

working system documentation.

What GAO Recommends

Congress should consider amending 

the Social Security Act to allow SSA to 

share its full death file through the DNP 

working system. GAO is making two

recommendations to Treasury and 

seven to OMB, including for OMB to 

develop and communicate a strategy 

and guidance and develop monitoring 

mechanisms. Treasury agreed. OMB 

agreed with two and agreed or 

generally agreed with the concepts 

behind the remaining five. GAO 

believes that it is important to fully 

implement all of the recommendations.
Letter 1

Page i GAO-17-15 Do Not Pay Working System

Background 4

OMB and Treasury Have Developed the DNP Working System, 

but Access to Certain Data Is Limited 9

Selected Agencies Have Used the DNP Working System in 

Limited Ways in Part Because of a Lack of Clear Strategy and 

Guidance 14

OMB Does Not Sufficiently Monitor Agency Use of the DNP 

Working System 22

Conclusions 25

Matter for Congressional Consideration 26

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 28

Appendix I: Objectives, Scope, and Methodology 31

Agencies Selected for Review 31

Methodology 32

Appendix II: Comments from the Office of Management and Budget 34

Appendix III: Comments from the Department of the Treasury 37

Appendix IV: Comments from the Social Security Administration 39

Appendix V: GAO Contact and Staff Acknowledgments 41

GAO Contact 41

Staff Acknowledgments 41

Appendix VI: Accessible Data 42

Agency Comment Letter 42

Tables

Table 1: List of 10 Agencies and Relevant Components Selected 

for Review 2

Table 2: Databases Required to Be Included in the Do Not Pay 

Working System 5

Table 3: Availability of Required Databases through the Do Not 

Pay Working System 9

Contents
Table 4: List of 10 Agencies and Relevant Components Selected 

for Review 31

Figure

Page ii GAO-17-15 Do Not Pay Working System

Figure 1: Payments Reviewed through Do Not Pay’s Payment 

Integration Process 17

Abbreviations

AFR agency financial report

CAIVRS Credit Alert Interactive Voice Response System

CMS Centers for Medicare & Medicaid Services

DMF Death Master File

DNP Do Not Pay

DOJ Department of Justice

Education Department of Education

FIPCA Federal Improper Payments Coordination Act of 2015

GSA General Services Administration

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development

IPERIA Improper Payments Elimination and Recovery 

Improvement Act of 2012

IRS Internal Revenue Service

LEIE List of Excluded Individuals and Entities

MOU memorandum of understanding

OIG Office of Inspector General

OMB Office of Management and Budget

RRB Railroad Retirement Board

SAM System for Award Management

SBA Small Business Administration

SORN system of records notice

SSA Social Security Administration

Treasury Department of the Treasury

USDA Department of Agriculture

VA Department of Veterans Affairs

VBA Veterans Benefits Administration
Page iii GAO-17-15 Do Not Pay Working System

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Page 1 GAO-17-15 Do Not Pay Working System

441 G St. N.W.

Washington, DC 20548

October 14, 2016

The Honorable Thomas R. Carper

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Senator Carper:

Improper payments are a long-standing, widespread, and significant 

problem in the federal government.1In fiscal year 2015 alone, improper 

payment estimates totaled almost $137 billion government-wide. While 

strategies for reducing improper payments include both prevention and 

detection techniques, proactively preventing improper payments avoids 

the difficulties associated with the “pay and chase” aspects of recovering 

overpayments.2 We previously reported that one strategy to help prevent 

improper payments is up-front verification of eligibility through data 

sharing and matching, such as use of the Do Not Pay (DNP) working 

system.3 Established by the Office of Management and Budget (OMB) 

and hosted by the Department of the Treasury (Treasury), the DNP 

working system is a web-based, centralized data matching service that 

allows agencies to review multiple databases—such as data on deceased 

individuals and entities barred from receiving federal awards—before 

making payments.

 

1Under the Improper Payments Information Act of 2002, as amended, an improper 

payment is statutorily defined as any payment that should not have been made or that 

was made in an incorrect amount (including overpayments and underpayments) under 

statutory, contractual, administrative, or other legally applicable requirements. It includes 

any payment to an ineligible recipient, any payment for an ineligible good or service, any 

duplicate payment, any payment for a good or service not received (except for such 

payments where authorized by law), and any payment that does not account for credit for 

applicable discounts. Office of Management and Budget guidance also instructs agencies 

to report as improper payments any payment for which insufficient or no documentation 

was found. 

2

“Pay and chase” refers to the labor-intensive and time-consuming practice of trying to 

recover overpayments once they have already been made rather than preventing 

improper payments in the first place.

3GAO, Fiscal Outlook: Addressing Improper Payments and the Tax Gap Would Improve 

the Government’s Fiscal Position, GAO-16-92T (Washington, D.C.: Oct. 1, 2015). 

Letter
You asked us to examine the DNP working system. This report examines 

the extent to which (1) OMB and Treasury developed the DNP working 

system and obtained access to relevant databases, (2) selected agencies 

used the DNP working system to help review eligibility, and (3) OMB 

monitored the use of the DNP working system.

In addition to OMB and Treasury’s DNP Business Center, we selected a 

nongeneralizable sample of 10 agencies and relevant components for 

review, which are listed in table 1, to get a variety of perspectives on use 

of the DNP working system. To select these agencies and components, 

we reviewed (1) fiscal year 2014 budgetary outlays and net cost 

information to select both large and small agencies and relevant 

components within these agencies, (2) improper payment estimates 

reported in fiscal year 2014 to select agencies and components with high 

improper payment estimates, and (3) information on agencies’ capabilities 

in the DNP working system to select agencies capable of using the 

different functionalities that the system offers. We also selected the Social 

Security Administration (SSA) as one of the 10 agencies because, while it 

is the source of certain data in the DNP working system, the agency does 

not use the system.

Table 1: List of 10 Agencies and Relevant Components Selected for Review

Page 2 GAO-17-15 Do Not Pay Working System

Agency Component

Department of Agriculture Commodity Credit Corporation

Food and Nutrition Service

Risk Management Agency

Rural Development

Department of Health and Human 

Services

Administration for Children and Families

Centers for Medicare & Medicaid Services

Department of the Interior N/Aa

Department of Labor Employment and Training Administration

Office of Workers’ Compensation Programs

Department of the Treasury Internal Revenue Service

Bureau of Engraving and Printing

Department of Veterans Affairs Veterans Benefits Administration

Veterans Health Administration

General Services Administration N/A

a

National Science Foundation N/Aa

Railroad Retirement Board N/Aa
Page 3 GAO-17-15 Do Not Pay Working System

Agency Component

Social Security Administration N/Ab

Legend: N/A = not applicable.

Source: GAO analysis of fiscal year 2014 budgetary outlays, net cost information, and improper payment estimates and information on 

agencies’ use of the Do Not Pay working system. | GAO-17-15

a

This agency uses the Do Not Pay working system centrally, so we did not select components for 

review.

b

This agency does not use the Do Not Pay working system.

To address our objectives, we obtained relevant documentation regarding 

availability of data through the DNP working system and interviewed staff 

from OMB and Treasury. We also reviewed relevant OMB and Treasury 

guidance regarding the DNP working system. We interviewed officials at 

the 10 agencies we selected and reviewed their policies and procedures 

for use of the DNP working system. Additionally, we met with officials at 

shared service providers used by certain of our selected agencies and 

components. We also reviewed the 10 selected agencies’ fiscal year 

2015 agency financial reports (AFR) regarding these agencies’ reporting 

on their use of the DNP working system and interviewed OMB staff 

regarding related monitoring processes. We compared the information we 

obtained to relevant laws, guidance, and federal internal control 

standards. Appendix I provides further details on our scope and 

methodology.

We conducted this performance audit from April 2015 to October 2016 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
In June 2010, the President directed agencies to review their preaward 

and prepayment procedures and ensure that a thorough review of 

applicable databases occurs before the release of any federal funds to 

help verify eligibility and prevent certain improper payments.

Page 4 GAO-17-15 Do Not Pay Working System

4 The 

Presidential Memorandum listed five databases for review and directed 

OMB to develop a plan for integrating these databases so that agencies 

could access them through a single point of entry.5In response to the 

memorandum, OMB and Treasury established the DNP working system 

in 2011.6In April 2012, OMB issued guidance on the DNP working 

system through OMB Memorandum M-12-11 (M-12-11), which required 

the chief financial officer of each agency to submit to OMB a plan for 

using the DNP working system.7

The Improper Payments Elimination and Recovery Improvement Act of 

2012 (IPERIA), as amended by the Bipartisan Budget Act of 2013 and the 

Federal Improper Payments Coordination Act of 2015 (FIPCA), enacted 

into law elements of the Presidential Memorandum by requiring agencies 

to ensure that a thorough review of available databases occurs prior to 

 

4Presidential Memorandum for the Heads of Executive Departments and Agencies on 

Enhancing Payment Accuracy Through a “Do Not Pay List,” 75 Fed. Reg. 35953 

(June 18, 2010).

5The five databases included in the June 2010 Presidential Memorandum were the Social 

Security Administration’s Death Master File, the General Services Administration’s 

Excluded Parties List System, Treasury’s Debt Check Database, the Department of 

Housing and Urban Development’s Credit Alert System (or Credit Alert Interactive Voice 

Response System), and the Department of Health and Human Services’ Office of 

Inspector General’s List of Excluded Individuals/Entities. The General Services 

Administration’s Excluded Parties List System is now called the System for Award 

Management exclusion records.

6The DNP working system was originally called the DNP solution.

7Office of Management and Budget, Reducing Improper Payments through the “Do Not 

Pay List,” OMB Memorandum No. M-12-11 (Washington, D.C.: Apr. 12, 2012).

Background

June 2010 Presidential 

Memorandum

Improper Payments 

Elimination and Recovery 

Improvement Act of 2012
the release of federal funds.

Page 5 GAO-17-15 Do Not Pay Working System

8

IPERIA, as amended, requires (1) the DNP 

working system to include six databases, as well as other databases 

designated by the Director of OMB in consultation with agencies, and 

(2) agencies to review—at a minimum—those six databases as 

appropriate before issuing any payment or award to help verify eligibility.9

The required databases are listed in table 2.

Table 2: Databases Required to Be Included in the Do Not Pay Working System

Database Source Function

System for Award Management 

exclusion records

GSA To verify whether individuals or entities are debarred from receiving new federal 

awards, including contracts, grants, and other financial assistance

Debt Check Treasury To verify whether an individual or entity owes delinquent child support or nontax 

debt to the federal government or participating states

List of Excluded Individuals and 

Entities

HHS OIG To verify whether individuals or entities are excluded from participating in federal 

health care programs

Credit Alert Interactive Voice 

Response System

Multiple 

agencies

To verify whether an individual or entity has delinquent federal debt incurred with 

either HUD, VA, Education, USDA, DOJ, or SBA

SSA’s prisoner data SSA To verify whether an individual is incarcerated

SSA’s death recordsaSSA To verify whether a payee is deceased

Legend: DOJ = Department of Justice; Education = Department of Education; GSA = General Services Administration; HHS = Department of Health and 

Human Services; HUD = Department of Housing and Urban Development; OIG = Office of Inspector General; SBA = Small Business Administration; 

SSA = Social Security Administration; Treasury = Department of the Treasury; USDA = Department of Agriculture; VA = Department of Veterans Affairs.

Source: GAO analysis of the Improper Payments Elimination and Recovery Improvement Act of 2012, as amended, and Treasury information. | GAO-17-15

a

The Improper Payments Elimination and Recovery Improvement Act of 2012, as amended, requires 

the Do Not Pay working system to include the “death records maintained by the Commissioner of 

Social Security.” For purposes of this report, we refer to the “death records maintained by the 

Commissioner of Social Security” as SSA’s death records. SSA shares two sets of death data. SSA 

shares its full death file with certain agencies that pay federally funded benefits. For other users of its 

death data, SSA shares the Death Master File. The Death Master File is a subset of the full death file, 

as it contains about 10 percent fewer death records than the full death file and does not include statereported death data. The Death Master File is distributed by the Department of Commerce’s National 

Technical Information Service.

 

8

IPERIA, Pub. L. No.112-248, 126 Stat. 2390 (Jan. 10, 2013), codified at 31 U.S.C. 3321 

note, as amended by the Bipartisan Budget Act of 2013, Pub. L. No. 113-67, § 204, 127 

Stat. 1165, 1181 (Dec. 26, 2013), and FIPCA, Pub. L. No. 114-109, §§ 2-4,129 Stat. 2225, 

2225-27 (Dec. 18, 2015). 

9

IPERIA, as amended, did not change eligibility criteria for any program. Instead, it 

requires agencies to review certain databases that may help determine eligibility prior to

making an award or payment.
In August 2013, OMB issued guidance through OMB Memorandum M-13-

20 (M-13-20) to help agencies protect privacy while reducing improper 

payments with the DNP Initiative.

Page 6 GAO-17-15 Do Not Pay Working System

10 According to OMB, the DNP Initiative 

encompasses multiple databases and analytics resources to support 

agencies as they verify entity eligibility for awards or payment. This 

includes centralized data portals (such as the DNP working system) and 

agency-specific initiatives that serve particular program needs (such as 

the Centers for Medicare & Medicaid Services’ (CMS) Fraud Prevention 

System). According to OMB, the DNP working system is one element of 

the DNP Initiative that agencies can use to meet the requirements set out 

in IPERIA.

The DNP working system offers user agencies four different 

functionalities by which they can perform searches of databases at 

various times during the award or payment process.

· The payment integration functionality matches agency payment files 

that are sent to Treasury at the time of payment. The payment files 

are matched against two databases—the Death Master File (DMF) 

and the System for Award Management (SAM) exclusion records—

and matching results are sent back to the agencies.11 When agencies 

receive matches through the payment integration functionality, they 

are required to adjudicate each match (i.e., verify the match to 

determine whether the corresponding payment is improper) and 

record the results in the DNP working system.

· The other three functionalities are online single search, batch 

matching, and continuous monitoring. Through online single search, 

an agency can match a single entity against the authorized and 

available databases for that agency in the DNP working system. 

Batch matching is a similar process in which an agency can match 

 

10Office of Management and Budget, Protecting Privacy while Reducing Improper 

Payments with the Do Not Pay Initiative, OMB Memorandum M-13-20 (Washington, D.C.: 

Aug. 16, 2013).

11As discussed in more detail later in this report, SSA shares two sets of death data. SSA 

shares its full death file with certain agencies that pay federally funded benefits. For other 

users of its death data, SSA shares DMF. DMF is a subset of the full death file, as it 

contains about 10 percent fewer death records than the full death file and does not include 

state-reported death data. DMF is distributed by the Department of Commerce’s National 

Technical Information Service.

The DNP Initiative and the 

DNP Working System
multiple entities against the authorized and available databases at 

one time. Online single search and batch matching can be conducted 

either before or after a payment is made, as decided by the agency. 

Continuous monitoring matches an agency’s file of entities against the 

authorized and available data sources on an ongoing basis whenever 

the data are updated. For these three functionalities, an agency 

receives matches through the DNP working system but does not 

record adjudication results for these matches in the system.

M-13-20 splits responsibilities related to the DNP Initiative—and the DNP 

working system—among four entities: (1) OMB, (2) Treasury, (3) originalsource agencies, and (4) payment-issuing agencies. These entities’

responsibilities include the following.

OMB is responsible for implementing the DNP Initiative—including 

establishing a working system for prepayment and preaward review—and 

providing guidance, oversight, and assistance to agencies. IPERIA 

requires OMB to submit annual reports to Congress regarding the 

operation of the DNP Initiative. These reports should include an 

evaluation of whether it has reduced improper payments or improper 

awards and provide the frequency of data corrections or identification of 

incorrect information.

OMB directed Treasury to host the DNP working system. In doing so, 

Treasury is responsible for developing memorandums of understanding 

(MOU) with original-source agencies and entering into computer matching 

agreements with payment-issuing agencies, as appropriate.

Page 7 GAO-17-15 Do Not Pay Working System

12 OMB 

guidance states that Treasury must also periodically reassess whether all 

of the data in the DNP working system are relevant and necessary and 

delete any data that are not. Additionally, Treasury is responsible for 

preparing and submitting to OMB a written assessment documenting the 

 

12If a computer matching program—defined as a computerized comparison of records for 

the purpose of establishing or verifying eligibility or recouping payments for a federal 

benefit program or relating to federal personnel management—is covered by the computer 

matching provisions of the Privacy Act (5 U.S.C. § 552a), the participating agencies must 

have a computer matching agreement. Among other things, a computer matching 

agreement includes the purpose and legal authority for conducting the matching program, 

a description of the records that will be matched, a justification for the program and the 

anticipated results, and procedures for verifying information produced in the matching 

program. 5 U.S.C. § 552(o).

Responsibilities Related to 

the DNP Initiative and 

Working System

OMB

Treasury
suitability of any commercial databases that could be designated for use 

in the DNP working system. Further, Treasury is responsible for taking 

steps to ensure that records in the DNP working system are sufficiently 

accurate, complete, and up-to-date; coordinating with original-source 

agencies to allow individuals to request data corrections; and submitting 

periodic reports to OMB.

Original-source agencies provide records (e.g., databases) to Treasury 

for the DNP working system. These agencies are responsible for entering 

into MOUs with Treasury that describe how Treasury may use the records 

and provide rules for protecting and correcting the information and for 

retaining and destroying the records. Additionally, original-source 

agencies are responsible for ensuring that they have sufficient legal 

authority and specific designation from OMB (except as provided by law) 

to share the records and that Treasury has the appropriate level of 

security controls before providing records to the DNP working system.

Payment-issuing agencies are responsible for making determinations 

about the disbursement of payments or awards, consistent with legal 

authority. In using the DNP working system, these agencies are 

responsible for ensuring that they only match against data sources that 

are relevant and necessary for the specific matching purpose. Paymentissuing agencies are responsible for ensuring that they have sufficient 

legal authority to engage in a matching program and, when appropriate, 

entering into computer matching agreements with Treasury. Treasury’s 

Do Not Pay User Guide states that each agency should verify match 

results received from the DNP working system against a secondary data 

source to ensure that match information received from the DNP working 

system is accurate. M-13-20 states that payment-issuing agencies should 

comply with all applicable requirements in the Privacy Act, which may 

include verifying match results and providing individuals an opportunity to 

contest match results prior to taking adverse action.

Page 8 GAO-17-15 Do Not Pay Working System

Original-Source Agencies

Payment-Issuing Agencies
Although OMB and Treasury have developed the DNP working system, 

the system does not offer full access to three of the six databases 

required by law. For example, the DNP working system offers access to 

the more limited DMF, but access to SSA’s full death file is not available. 

OMB has not formally evaluated user-agency suggestions for additional 

databases for the DNP working system, in part because it has not 

developed a formal process for obtaining the suggestions.

The DNP working system offers full access to three of the databases 

required by IPERIA: the System for Award Management exclusion 

records, the Debt Check database, and the List of Excluded Individuals 

and Entities (LEIE). However, it offers either partial or no access to the 

remaining three: the Credit Alert Interactive Voice Response System, 

SSA’s prisoner data, and SSA’s death records.

Page 9 GAO-17-15 Do Not Pay Working System

13 Availability of data 

through the DNP working system is shown in table 3.

Table 3: Availability of Required Databases through the Do Not Pay Working System

Database Source Available through the DNP working 

system

Yes No

System for Award Management exclusion 

records

General Services Administration Yes —

Debt Check Department of the Treasury Yes —

List of Excluded Individuals and Entities Department of Health and Human Services 

Office of Inspector General

Yes —

Credit Alert Interactive Voice Response 

System

Department of Agriculture — No

Department of Education — No

 

13IPERIA, as amended, requires the DNP working system to include the “death records 

maintained by the Commissioner of Social Security.” For purposes of this report, we refer 

to the “death records maintained by the Commissioner of Social Security” as SSA’s death 

records. As mentioned previously, SSA shares two sets of death data. SSA shares its full 

death file with certain agencies that pay federally funded benefits. For other users of its 

death data, SSA shares DMF. DMF is a subset of the full death file, as it contains about 

10 percent fewer death records than the full death file and does not include state-reported 

death data. DMF is distributed by the Department of Commerce’s National Technical 

Information Service.

OMB and Treasury 

Have Developed the 

DNP Working 

System, but Access 

to Certain Data Is 

Limited

The DNP Working System 

Offers Either Partial or No 

Access to Three of the Six 

Databases Required by 

Law
Page 10 GAO-17-15 Do Not Pay Working System

Database Source Available through the DNP working 

system

Yes No

Department of Housing and Urban 

Development

Yes —

Department of Justice Yes —

Department of Veterans Affairs Yes —

Small Business Administration Yes —

Social Security Administration’s (SSA) 

prisoner data

SSA — No

Database Dataset Not applicable Not applicable

SSA’s death records Full death file — No

Death Master FileaYes —

Source: GAO analysis of the Do Not Pay working system. | GAO-17-15

Note: The Do Not Pay working system also has access to unrequired databases, such as the System 

for Award Management entity registration records and Office of Foreign Assets Control data.

a

SSA’s Death Master File does not include state-reported death data.

According to Treasury officials, the process for obtaining access to 

databases for the DNP working system is extensive and requires 

coordination with original-source agencies to establish MOUs and to 

revise system of records notices (SORN) to include routine uses that 

allow disclosure of the data through the DNP working system.14 Treasury 

officials stated that Credit Alert Interactive Voice Response System 

(CAIVRS) data inputs from the Departments of Agriculture (USDA) and 

Education (Education) are not currently available through the DNP 

working system because of delays in negotiating MOUs with these 

agencies and revising SORNs. As efforts to finalize these documents 

continue, Treasury officials stated that they estimate that the DNP 

working system will offer access to CAIVRS data from USDA by the end 

of fiscal year 2016 and from Education in early fiscal year 2017.

Additionally, the DNP working system does not offer access to SSA’s 

prisoner data. According to agency officials, Treasury and SSA have 

negotiated a permanent MOU to allow (1) the Internal Revenue Service 

(IRS) access to SSA’s prisoner data for tax administration through the 

 

14SORNs are required by the Privacy Act. 5 U.S.C. § 552a(e)(4). A SORN includes 

information on the records collected, routine uses of the data, and procedures that 

individuals can use to review and contest the information, among other things. 
DNP working system and (2) Treasury access to the data for planning 

and analysis purposes related to the DNP working system.

Page 11 GAO-17-15 Do Not Pay Working System

15 The MOU 

allows Treasury to evaluate the prisoner data and determine whether it 

will be useful in the DNP working system, although SSA officials noted 

that disclosure of the prisoner data to other agencies for matching 

purposes through the DNP working system will be limited until the 

relevant SORN is revised to include this matching as a routine use of the 

prisoner data.16 Although Treasury continues to work with relevant 

agencies, until access to all of the required databases is offered, 

agencies may face a higher risk of not preventing or identifying improper 

payments, particularly those to prisoners and individuals that are 

delinquent on federal nontax debt.

Further, Treasury has not obtained SSA’s more complete death records 

for the DNP working system. SSA shares two sets of death data: its full 

death file and DMF.17 DMF is a subset of the full death file, as it contains 

about 10 percent fewer death records than the full death file and does not 

include state-reported death data.18 Initially, IPERIA listed DMF as a 

required database for the DNP working system. FIPCA amended IPERIA 

by replacing the reference to DMF with “death records maintained by the 

Commissioner of Social Security.” SSA officials stated that the Social 

Security Act limits sharing of SSA’s full death file to federal benefit-paying 

agencies, which does not include the DNP working system. These 

officials stated that the Social Security Act would need to be amended to 

allow the agency to share its full death file with Treasury for the DNP 

working system. The President’s Budget for fiscal year 2017 included a 

 

15A temporary MOU between Treasury, SSA, and IRS was established to allow IRS to 

receive SSA’s prisoner data through the DNP working system to help determine Earned 

Income Tax Credit eligibility for the 2015 tax year. As of June 2016, IRS officials stated 

that IRS had not begun using SSA’s prisoner data through the DNP working system.

16The routine uses specified in the current SORN only allow SSA to share prisoner data 

with agencies for administration of income-maintenance or health-maintenance programs.

17Use of the term “full” is not meant to indicate that a file contains all deaths but rather that 

a file includes deaths reported by states. SSA does not have a death record for all 

deceased individuals (e.g., deaths not reported to SSA), and SSA does not guarantee the 

completeness or accuracy of its death data. 

18In our November 2013 report, SSA officials indicated that they expected the percentage 

of state-reported deaths as a proportion of all SSA death records to increase over time. 

GAO, Social Security Death Data: Additional Action Needed to Address Data Errors and 

Federal Agency Access, GAO-14-46 (Washington, D.C.: Nov. 27, 2013). 
proposal for such an amendment, but no amendment providing this 

authority has been enacted. Consequently, the DNP working system 

offers access to only DMF and not the full death file.

In November 2013, we reported that SSA’s processes for collecting and 

maintaining death reports could result in untimely or erroneous death 

information, such as including living individuals or not including deceased 

individuals.

Page 12 GAO-17-15 Do Not Pay Working System

19 For example, we identified about 500 instances in which 

death reports submitted to SSA in early 2013 listed dates of death in 2011 

or earlier. This is of concern because—if the dates of death are 

accurate—SSA and other agencies may have been at risk of paying 

benefits to these individuals for long periods after they died. We also 

reported that SSA’s Office of Inspector General found that data for about 

182,000 deceased Supplemental Security Income recipients and about 

1.2 million deceased Old Age and Survivors Insurance beneficiaries were 

not included in SSA’s death data. To help improve the accuracy of its 

death data, we recommended that SSA conduct a risk assessment and 

assess the feasibility and cost-effectiveness of addressing various types 

of errors given the risk they pose. We found that since fiscal year 2014, 

SSA has been taking steps to redesign how the agency processes death 

reports and compiles data for dissemination. As part of that redesign, 

SSA completed a risk assessment and a data quality assessment in June 

2014. SSA has completed the first two phases of its redesign project and 

developed a business process description for the third phase. According 

to SSA, the agency is taking care to ensure that improvements made to 

the death data processing system are cost-effective. Although we have 

not assessed the extent to which SSA’s efforts have improved the quality 

of its death data, we are encouraged that SSA plans to continue the 

redesign project in future years. SSA’s efforts will be critical to addressing 

the risk of errors in its death data. However, it is important to note that 

SSA does not guarantee the accuracy of the death information it provides 

to agencies. SSA reported that users of its death data must agree to 

independently verify the information before taking action based on an 

individual’s death report. Such verification—if completed—should help 

reduce the effect of erroneous death data.

 

19GAO-14-46. 
While there is a continued need for SSA to address the risk of errors in its 

death data, sharing the full death file through the DNP working system 

would provide agencies with additional information and enhance efforts to 

identify and prevent improper payments to deceased individuals. As we 

previously reported, because the deaths reported by states are generally 

more accurate, and these reports are included in the full death file, it is 

likely that agencies using SSA’s full death file would encounter fewer 

errors than agencies using the DMF.

Page 13 GAO-17-15 Do Not Pay Working System

20

IPERIA provides the Director of OMB, in consultation with agencies, the 

authority to designate additional databases that substantially assist in 

preventing improper payments. However, OMB has not formally 

evaluated user agencies’ suggestions for additional databases or 

designated any additional databases to be included in the DNP working 

system.21 OMB staff stated that they consulted with data analytic centers 

regarding potential databases and services, and the President’s Budget 

for fiscal year 2017 included proposals to obtain access to additional 

databases.22 Nevertheless, certain user agencies we reviewed identified 

additional databases that could be beneficial if included in the DNP 

working system.

OMB has not developed a formal process for user agencies to suggest 

additional databases to be included in the DNP working system. OMB 

staff stated that they expect user agencies to suggest additional 

databases to be included in the DNP working system through their AFRs. 

However, neither M-13-20 nor OMB Circular No. A-136 financial reporting 

 

20In November 2013, we reported that most states submit death reports through an 

Electronic Death Registration System. SSA considers these reports to be the most 

accurate because most states use the systems to verify the name and Social Security 

Number of each decedent with SSA databases before submitting a death report to SSA. 

GAO-14-46. 

21Per M-13-20, OMB will provide a 30-day public notice and an opportunity for comment 

prior to designating additional databases.

22OMB included a proposal in the fiscal year 2017 Budget of the U.S. Government for 

agency access to the National Directory of New Hires through the DNP working system. 

As previously mentioned, the fiscal year 2017 Budget of the U.S. Government also 

included a proposal to provide SSA authority to disclose its full death file for use in the 

DNP working system. These proposals have not been implemented.

OMB Has Not Designated 

Additional Databases for 

Inclusion in the DNP 

Working System
requirements communicate these expectations.

Page 14 GAO-17-15 Do Not Pay Working System

23 Further, OMB staff 

acknowledged that some user agencies made suggestions for additional 

databases through their AFRs but stated that the suggestions were not 

communicated through “formal requests.” OMB guidance does not clarify 

how agencies should formally suggest additional databases for inclusion 

in the DNP working system or how OMB should communicate its 

decisions to agencies. Because a formal process for obtaining 

suggestions for additional databases—whether from the AFRs or other 

means—has not been fully developed and communicated, OMB may not 

be identifying or considering additional relevant databases that could 

improve the effectiveness of the DNP working system.

Nine of the 10 agencies we reviewed used the DNP working system’s 

payment integration functionality, despite limitations in its effectiveness 

and the lack of OMB and Treasury guidance for key aspects of the 

payment integration process. For example, this process matches against 

only two databases, and agencies generally receive results after 

payments are made. Further, certain agencies reported confusion 

regarding whether they were required to use the payment integration 

process, especially those agencies with other—and potentially 

duplicative—data matching processes. Aside from the payment 

integration process, 6 of the 10 agencies we reviewed used the DNP 

working system in limited ways, and 9 of the 10 agencies accessed the 

databases through means other than the DNP working system. OMB staff 

stated that they expect agencies to leverage the DNP working system to 

complement existing, non-DNP data matching processes, but OMB 

guidance does not reflect this approach, and OMB has not developed a 

strategy for how this should be carried out. The policies and procedures 

for using the DNP working system at the agencies that we reviewed 

generally lacked specific processes for (1) determining whether DNP 

matches were actually improper payments and (2) verifying matches 

 

23M-13-20 states that Treasury is responsible for preparing and submitting to OMB a 

written assessment to document the suitability of any commercial databases that could be 

designated for use in the DNP working system. The memorandum does not include any 

guidance on the responsibility of assessing or providing suggestions for noncommercial 

databases, but OMB staff stated that they expect Treasury to follow the same process 

outlined for commercial databases. In July 2016, OMB staff noted that they were in the 

process of evaluating a formal request from Treasury to designate additional databases 

for use in the DNP working system.

Selected Agencies 

Have Used the DNP 

Working System in 

Limited Ways in Part 

Because of a Lack of 

Clear Strategy and 

Guidance
against a secondary data source. These shortcomings were due in part to 

unclear and inconsistent guidance from OMB and Treasury.

Nine of the 10 agencies we reviewed used DNP’s payment integration 

functionality—despite limitations in its effectiveness—because it is built 

into Treasury’s payment process. In part because OMB and Treasury 

guidance does not address key aspects of the payment integration 

process, understanding of the process varied across selected agencies, 

and in some cases, the process was potentially duplicative of existing 

agency procedures.

DNP’s payment integration functionality is limited because of the timing of 

the matching performed and the scope of databases and payments 

reviewed. Moreover, certain limitations are not fully communicated 

through existing guidance.

· Timing of matching. The payment integration process is not 

consistent with the requirement in IPERIA to review databases prior to 

award or payment. While matching is conducted at the time of 

payment, agencies generally receive the results after payments have 

been made. As such, use of the payment integration process does not 

assist agencies in preventing improper payments before they occur.

Page 15 GAO-17-15 Do Not Pay Working System

24

While Treasury’s Do Not Pay Agency Implementation Guide states

that payment integration matching happens at the time of payment, 

the agencies we reviewed reported inconsistent interpretations of the 

timing of the process. Because the guide is not clear that the results 

are generally received after payments have been made, about half of 

the agencies we reviewed considered the payment integration 

process to be a prepayment function, whereas others considered it to 

be a postpayment activity. Further, OMB guidance does not 

specifically reference the payment integration functionality or its 

timing.

· Databases used in matching. The payment integration process 

matches against only two databases, DMF and SAM exclusion 

records. Any other database available through the DNP working 

 

24For recurring payments, use of the payment integration process may help agencies 

avoid future improper payments, although an initial payment may not be identified as 

improper until after it has been made.

OMB and Treasury 

Guidance Does Not 

Address Key Aspects of 

the Payment Integration 

Process

Guidance Does Not Fully 

Address Limitations of DNP’s 

Payment Integration Process
system must be accessed outside of the payment integration process. 

Some agencies we reviewed did not know which databases were 

included in the payment integration process, which may be a result of 

unclear guidance. While agency officials confirmed that it was their 

understanding that the objective of the process is to match against 

only DMF and SAM exclusion records, Treasury’s Do Not Pay Agency 

Implementation Guide states that the objective of the payment 

integration process is to match all payment files against the data 

sources identified in IPERIA. The guide does not acknowledge that 

the process matches payments against only two of the data sources 

identified in IPERIA, DMF and SAM exclusion records.

· Payments reviewed. Because the payment integration functionality is 

part of Treasury’s payment issuance process, payments that are 

made through other means—such as non-Treasury disbursing offices 

or contractors—are not automatically matched. Examples of these 

types of payments include Department of Defense payments 

disbursed through the Defense Finance and Accounting Service 

($477 billion in fiscal year 2015) and Medicare Fee-for-Service 

payments ($351 billion in calendar year 2014). Further, certain federal 

payments flow through various entities—such as state or local 

governments—before ultimately being spent for their intended 

purposes. For example, benefits for USDA’s Supplemental Nutrition 

Assistance Program are funded by the federal government, but states 

are responsible for determining individual and household eligibility for 

the program, calculating the amount of monthly benefits, and issuing 

benefits on an electric benefit transfer card. In these cases, only the 

payment from the federal agency to the first recipient is matched 

against DMF and SAM exclusion records, and subsequent 

payments—those to the ultimate recipients, for example—are not 

matched through DNP’s payment integration process, though they 

may go through other agency-specific reviews. Figure 1 illustrates the 

payments reviewed through the payment integration process.

Page 16 GAO-17-15 Do Not Pay Working System
Figure 1: Payments Reviewed through Do Not Pay’s Payment Integration Process

Page 17 GAO-17-15 Do Not Pay Working System

Note: Payments that are not reviewed through Do Not Pay’s payment integration process may 

undergo other agency-specific reviews prior to disbursement.

Standards for Internal Control in the Federal Government states that 

management should externally communicate the necessary quality 

information to achieve the entity’s objectives.25 Without clear guidance on 

the limitations of the payment integration functionality, there is an 

increased risk that agencies will not use the DNP working system 

effectively to reduce improper payments.

Eight of the 10 agencies we reviewed considered use of the payment 

integration functionality required because it is built into Treasury’s 

payment process, though neither OMB nor Treasury guidance sets out 

this requirement. OMB staff stated that they do not consider use of the 

process to be a requirement. However, OMB’s actions (as noted below) 

could give the opposite impression.

 

25GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).

Guidance Unclear as to 

Whether Use of the Payment 

Integration Process Is 

Required
· Two agencies we reviewed—SSA and IRS—requested and received 

permission exempting them from using the payment integration 

functionality for at least some of their payments. For example, OMB 

specifically determined that SSA is not required to use the payment 

integration functionality because it is the source agency for two 

relevant databases (death and prisoner data) and has access to SAM 

exclusion data and the Department of Health and Human Services’

Office of Inspector General’s LEIE outside of the DNP working 

system. Similarly, IRS officials stated that they worked with OMB to 

receive permission exempting IRS from using the payment integration 

process for its tax refunds given its existing data matching processes 

and confidentiality restrictions. Had the payment integration 

functionality been clearly optional, explicit OMB exemptions would not 

be necessary.

· Two other agencies we reviewed—the Railroad Retirement Board 

(RRB) and the Department of Veterans Affairs’ (VA) Veterans Benefits 

Administration (VBA)—had procedures to review SSA’s full death file 

for certain programs prior to implementation of the DNP working 

system. Officials at these agencies stated that they requested an 

exemption from OMB from the payment integration process—which 

they considered duplicative of their existing procedures—but were 

denied. OMB staff stated that they did not recall these agencies’

requests but that they would be willing to work with them to avoid 

duplication.

Standards for Internal Control in the Federal Government states that 

management should externally communicate the necessary quality 

information to achieve the entity’s objectives.

Page 18 GAO-17-15 Do Not Pay Working System

26 Given the limitations of the 

payment integration functionality, clear guidance is critical to help ensure 

that agencies fully understand the process and whether its use is 

required. Without clear guidance on whether the payment integration 

process is required, there is an increased risk that agencies may not 

effectively or efficiently use the DNP working system to reduce improper 

payments.

 

26GAO-14-704G.
Only 6 of the 10 agencies we reviewed used the DNP working system for 

purposes outside of payment integration, and their uses of the system 

were limited to certain programs or databases and often were not part of 

payment or award eligibility determinations.

Page 19 GAO-17-15 Do Not Pay Working System

27 Two of the agencies we 

reviewed—the National Science Foundation and USDA—used the DNP 

working system on a preaward or prepayment basis for certain types of 

payments.

· Officials at the National Science Foundation stated that the agency 

uses the DNP working system to review grant proposals against SAM 

(both exclusion records and entity registration records) and LEIE 

simultaneously, streamlining and automating a process that was 

previously performed manually for one application at a time.

· USDA officials stated that the Commodity Credit Corporation and Risk 

Management Agency use the DNP working system on a preaward or 

prepayment basis for certain payments. According to officials, the 

Commodity Credit Corporation uses the DNP working system to 

review secure payments against DMF and SAM exclusion records. 

Similarly, the Risk Management Agency uses the DNP working 

system to review payments for reinsurance funds to entities other than 

approved insurance providers against DMF.

The other four agencies use the DNP working system to periodically 

review certain of their databases, though the reviews are not necessarily 

tied to a payment or award. For example:

· CMS officials reported using the working system to review provider 

enrollment information from its Provider Enrollment, Chain and 

Ownership System against SAM exclusion records on a monthly 

basis.28

 

27The DNP working system is currently available to federal executive branch agencies. In 

December 2015, FIPCA expanded access to federal judicial and legislative branch 

agencies; states; and contractors, subcontractors and agents of a state. OMB is currently 

developing guidance for implementing the expanded access. 

28The Provider Enrollment, Chain and Ownership System is a centralized database 

designed to contain medical providers’ and suppliers’ enrollment information. CMS 

requires prospective medical providers and suppliers to use the system, and enrollment 

allows them to bill for services provided to Medicare beneficiaries. 

Aside from Payment 

Integration, Use of the 

DNP Working System at 

Selected Agencies Is 

Limited
· Officials at the General Services Administration reported using the 

DNP working system to review its vendor database against SAM 

exclusion records on a monthly basis.

While some of the agencies we reviewed used the DNP working system 

for purposes beyond payment integration, 9 of the 10 agencies we 

reviewed accessed certain IPERIA-specified databases outside of the 

DNP working system. For example:

· Most agencies reported that they use SAM exclusion records when 

awarding contracts, as required by the Federal Acquisition Regulation. 

These agencies generally accessed SAM exclusion records through 

SAM.gov or by using systems integrated with SAM data.

· As previously noted, RRB and VBA reported that they use SSA’s full 

death file outside of the DNP working system. For example, VBA 

reported matching its Compensation and Pension programs’ master 

records against SSA’s full death file on a weekly basis, while RRB 

reported matching its master benefit payment file against SSA’s full 

death file on a monthly basis.

· Officials at the Veterans Health Administration reported that it reviews 

LEIE outside of the DNP working system when adding non-VA 

medical providers to its vendor database.

Agencies are using the DNP working system in limited ways in part 

because of a lack of OMB strategy and guidance. OMB has not 

developed or documented a strategy for how it expects agencies to use 

the DNP working system. Instead, OMB staff informed us that OMB 

expects agencies to determine how best to use the DNP working system 

to complement existing data matching processes. According to M-13-20, 

OMB is responsible for providing agencies guidance on the DNP 

Initiative, but key aspects of OMB’s stated approach are not addressed by 

its existing guidance.

Page 20 GAO-17-15 Do Not Pay Working System

29 Specifically, the memorandum does not indicate 

that agencies should determine how to use the DNP working system or 

whether agencies should consider using the system to streamline existing 

data matching processes. Because the DNP working system offers a 

single point of access to multiple databases, agencies may be able to 

 

29As discussed earlier, the DNP Initiative includes the DNP working system and other 

agency-specific efforts to prevent improper payments.
streamline existing processes by using the DNP working system rather 

than accessing these databases separately.

While it required agencies to develop plans for using the DNP working 

system through M-12-11 in 2012, OMB has not followed up with agencies 

to determine whether the plans were implemented or updated as the 

capabilities of the DNP working system evolved. Further, OMB guidance 

does not address other key aspects of the program, including how 

agencies should demonstrate that their data matching processes meet 

the requirements of IPERIA, whether agencies can decide on their own 

which specific databases to use, or how agencies should use the specific 

data matching functionalities offered through the DNP working system. 

Standards for Internal Control in the Federal Government states that 

management should externally communicate the necessary quality 

information to achieve the entity’s objectives.

Page 21 GAO-17-15 Do Not Pay Working System

30 Without a strategy 

communicated through guidance, agencies may not effectively use the 

DNP working system to help prevent improper payments and, when 

possible, streamline data matching processes.

Most of the agencies we reviewed did not have documented policies and 

procedures for determining whether a DNP match represented an 

improper payment (i.e., the adjudication process), including verifying a 

DNP match against a secondary data source and providing individuals an 

opportunity to contest the matching results prior to taking adverse action. 

OMB and Treasury guidance is inconsistent and unclear regarding 

agencies’ responsibilities for verifying DNP matches. M-13-20 provides 

requirements for agencies conducting matching programs under the 

Privacy Act, which include verifying matches and providing individuals an 

opportunity to contest. However, agencies we reviewed did not consider 

the majority of their matching through the DNP working system to meet 

the definition of a matching program per the Privacy Act, and M-13-20 

does not state what is required if an agency concludes that its use of the 

DNP working system does not constitute a matching program.

In contrast to OMB guidance, Treasury’s Do Not Pay User Guide states 

that agencies should verify all DNP matches against a secondary source. 

 

30GAO-14-704G.

Selected Agencies Had 

Limited Policies and 

Procedures for Using the 

DNP Working System
However, aside from Treasury’s Quick Reference Card for SAM, neither 

OMB nor Treasury guidance explains how an agency should verify a DNP 

match, including the use of a secondary source. Standards for Internal 

Control in the Federal Government states that management should 

externally communicate the necessary quality information to achieve the 

entity’s objectives.

Page 22 GAO-17-15 Do Not Pay Working System

31 Without clear and consistent guidance, agencies may 

not effectively develop and document processes to help ensure that DNP 

matches are accurate and that, when appropriate, individuals are given 

an opportunity to contest adverse actions. Further, if agencies do not 

verify DNP matches, they face an increased risk that they may not 

effectively use the DNP working system to reduce improper payments.

Although OMB collects relevant information, it has not evaluated agency 

use of the DNP working system. OMB has not established specific goals 

or performance measures by which to evaluate agency use of the DNP 

working system, in part because it has not developed a strategy for how 

agencies should use the system. In its first annual report to Congress on 

the overall DNP Initiative, OMB reported that the DNP Initiative prevented 

$2 billion in improper payments in fiscal year 2014.32 While the report 

highlighted the DNP working system and four other agency-specific 

efforts, all of the reported $2 billion in prevented improper payments 

 

31GAO-14-704G.

32IPERIA requires OMB to annually report to Congress on the DNP Initiative, including an 

evaluation of whether the DNP Initiative has reduced improper payments. As previously 

noted, the DNP Initiative includes the DNP working system and other agency-specific 

efforts to prevent improper payments. OMB has not yet issued its report for fiscal year 

2015.

OMB Does Not 

Sufficiently Monitor 

Agency Use of the 

DNP Working System

OMB Has Not Evaluated 

Agency Use of the DNP 

Working System
resulted from use of the agency-specific efforts, not the DNP working 

system.

Page 23 GAO-17-15 Do Not Pay Working System

33

Further, several agencies we reviewed reported little benefit from their 

use of the DNP working system. The 10 agencies under our review 

reported in their AFRs a total of only $725 in improper payments that 

were prevented through use of the DNP working system during fiscal year 

2015, although concerns regarding the reliability of these data are 

discussed later in this report. The 24 Chief Financial Officers Act 

agencies collectively reported in their AFRs about $680,000 in improper 

payments prevented through use of the DNP working system in fiscal 

year 2015.34 Although OMB considers it to be one part of the overall DNP 

Initiative, it is important for OMB to specifically monitor agency use of the 

DNP working system—as part of its responsibility to oversee the DNP 

Initiative—to determine whether its use is effective. Standards for Internal 

Control in the Federal Government states that management should 

establish and operate monitoring activities, evaluate the results, and 

remediate identified deficiencies on a timely basis.35 To do so, 

management can establish baselines or benchmarks against which to 

measure program performance. Without monitoring mechanisms, OMB 

may not effectively evaluate the DNP working system or identify 

performance issues. Further, OMB may be unable to provide complete 

information on the DNP working system to Congress as part of its annual 

report on the overall DNP Initiative.

 

33The four agency-specific efforts cited were CMS’s Fraud Prevention System, the 

Department of Labor’s Unemployment Insurance Integrity Center of Excellence, the 

Department of Defense’s Business Activity Monitoring tool, and SSA’s use of death and 

prisoner data. 

34The Chief Financial Officers Act, Pub. L. No. 101-576 (Nov. 15, 1990), established chief 

financial officers to oversee financial management activities at 23 major executive 

departments and agencies. The list now includes 24 entities, which are often referred to 

collectively as Chief Financial Officers Act agencies, and is codified, as amended, in 31 

U.S.C. § 901. 

35GAO-14-704G.
While OMB staff stated that they collect and review agency-reported data 

on use of the DNP working system, the information may be limited and 

unreliable. Specifically, OMB staff stated that they use information in 

agencies’ AFRs to monitor the DNP Initiative, which includes agencies’

use of the DNP working system.

Page 24 GAO-17-15 Do Not Pay Working System

36 OMB staff stated that they reviewed 

draft AFRs for fiscal year 2015 against OMB guidance in OMB Circular 

No. A-136 and found no issues with the information. However, among the 

10 agencies we reviewed, we identified instances in which certain 

reporting in the fiscal year 2015 AFRs was inconsistent with OMB 

guidance or monthly adjudication reports generated by the DNP working 

system, calling into question the reliability of the information.37

Certain agencies we reviewed did not include all required elements in the 

AFR narrative or complete the results summary table in accordance with 

OMB guidance, resulting in potentially inaccurate data. For example:

· One agency overstated its false positives in its results table by 

reporting the payments reviewed that did not receive matches, instead 

of payments with matches that were reviewed and the payment 

determined to be proper (i.e., false positives).

· One agency did not use the most up-to-date template for its results 

table, leading it to report results of its matching inconsistent with the 

reporting of other agencies. Specifically, the agency reported on 

matches identified as improper payments instead of false positives.

· One agency reported on its use of the DNP working system for fiscal 

year 2014 instead of fiscal year 2015 in its fiscal year 2015 AFR.

In addition, certain agencies we reviewed included information in the AFR 

results summary table that conflicted with reports generated by the DNP 

working system. For example:

 

36OMB Circular No. A-136 lays out AFR requirements, which for the DNP Initiative include 

a narrative about the agency’s use of the DNP working system and a table summarizing 

payments reviewed and improper payments stopped, among other things.

37A monthly adjudication report summarizes the agency’s adjudication (i.e., the 

determination of whether payments are proper or improper) of matches for a specific 

month. Among other things, the report includes the number and dollar value of matches 

identified, payments stopped, payments deemed proper (i.e., false positives), payments 

deemed improper, and payments not yet adjudicated.

OMB Did Not Identify 

Inconsistencies in AgencyReported Data

Inconsistency with OMB 

Guidance

Inconsistency with DNP 

Working System Reports
· One agency reported no false positives in its summary table, but its 

DNP working system adjudication reports indicated over 60 false 

positives for fiscal year 2015.

· One agency reported identical information as both payments stopped 

and false positives in its summary table, calling into question the 

accuracy of these data. Further, these results did not agree with the 

agency’s DNP working system adjudication reports and were 

inconsistent with the agency’s AFR narrative, which stated that 

reviews were conducted after payments had been made. Because 

reviews were performed on a postpayment basis, the payments could 

not have been stopped.

Given the issues we identified, OMB’s process for reviewing information 

on agency use of the DNP working system reported in AFRs may not be 

effective. Further, OMB Circular No. A-136 notes that Treasury will 

provide OMB summary information on use of the DNP working system on 

behalf of user agencies. However, this information is limited to results of 

the payment integration functionality. Although the DNP working system 

offers agencies four different methods for conducting data matching, the 

system only tracks results for the payment integration process. Treasury 

officials stated that the decision to track only payment integration results 

was made for ease of use by agencies. Agencies using the other three 

functionalities—online single search, batch matching, and continuous 

monitoring that can be used for prepayment reviews, such as eligibility 

determinations—must track their results manually, which may be more 

inefficient and susceptible to human error. Additionally, OMB guidance 

does not indicate whether agencies should report on all uses of the DNP 

working system, including those outside payment integration that the DNP 

working system does not track. Standards for Internal Control in the 

Federal Government states that management should use quality 

information to achieve the entity’s objectives.

Page 25 GAO-17-15 Do Not Pay Working System

38 Without complete and 

reliable data and clear guidance on what information agencies should 

report, OMB cannot effectively monitor and evaluate the use of the DNP 

working system.

Improper payments are a significant problem in the federal government, 

and the DNP working system is one tool that agencies can use to help 

 

38GAO-14-704G.

Conclusions
reduce them. However, the lack of certain data limits the effectiveness of 

the DNP working system. For example, SSA’s more complete set of 

death data is not offered through the DNP working system, and OMB has 

not developed a formal process to obtain suggestions of additional 

databases from user agencies for data matching.

While the most common use of the DNP working system is its payment 

integration process, OMB guidance is unclear as to whether use of the 

process is required, and Treasury’s Do Not Pay Agency Implementation 

Guide does not clearly describe the limitations of the process, including 

the data sources used and the timing of matching. Further, the agencies 

we reviewed used the DNP working system in limited ways in part 

because OMB has not developed a strategy for how agencies should use 

it. Without a strategy that is communicated through guidance, agencies 

may not use the DNP working system to effectively and efficiently reduce 

improper payments.

Finally, OMB does not sufficiently monitor use of the DNP working 

system. OMB has not developed performance measures or other 

monitoring mechanisms, in part because it lacks a strategy for use of the 

system, and the information OMB collects on agencies’ use of the DNP 

working system may be unreliable. Because the DNP working system 

does not track matches obtained through all of the available 

functionalities, the information OMB collects may also be incomplete. 

Without monitoring mechanisms and reliable and complete data, OMB will 

not be able to effectively evaluate agencies’ use of the DNP working 

system or remediate any issues identified.

To provide agencies access to SSA’s more complete set of death data, 

Congress should consider amending the Social Security Act to explicitly 

allow SSA to share its full death file with Treasury for use through the 

DNP working system.

We recommend that the Director of OMB take the following seven 

actions.

· To reasonably assure that additional relevant databases are identified 

and evaluated for inclusion in the DNP working system, the Director of 

OMB should develop, document, and communicate a formal process 

that user agencies can use to identify, suggest, and receive feedback 

Page 26 GAO-17-15 Do Not Pay Working System

Matter for 

Congressional 

Consideration

Recommendations for 

Executive Action
on additional databases to be evaluated for inclusion in the DNP 

working system.

· To reasonably assure that the DNP working system is used effectively 

and consistently, the Director of OMB should develop guidance that 

clarifies whether the use of DNP’s payment integration functionality is 

required and—if required—the circumstances and process in which 

agencies may obtain an exemption from this requirement.

· To reasonably assure that agencies use the DNP working system 

effectively, the Director of OMB should develop a strategy—and 

communicate its strategy through guidance—for how agencies should 

use the DNP working system to complement existing data matching 

processes and whether and how agencies should consider using the 

DNP working system to streamline existing data matching. Such 

guidance may cover how agencies should demonstrate that their data 

matching processes meet the requirements in IPERIA, whether 

agencies can decide on their own which specific databases to use, 

and how agencies should use the functionalities available through the 

DNP working system.

· To reasonably assure that agencies develop consistent policies and 

procedures to verify DNP matches, the Director of OMB should 

provide additional guidance that outlines when and how agencies 

should verify DNP matches against a secondary source and provide 

individuals an opportunity to contest before taking adverse actions as 

a result of DNP matches.

· To better monitor agency use of the DNP working system once a 

strategy has been developed, the Director of OMB should develop 

and implement monitoring mechanisms—such as goals, benchmarks, 

and performance measures—to evaluate agency use of the DNP 

working system.

· To reasonably assure that agency-reported information on use of the 

DNP working system is reliable, the Director of OMB should develop a 

process for comparing agency reporting on the use of the DNP 

working system to available sources, such as OMB guidance and 

DNP working system adjudication reports.

· To reasonably assure that agency-reported information on use of the 

DNP working system is complete, the Director of OMB should revise 

its guidance to clarify whether agencies should report on their uses of 

all of the functionalities of the DNP working system in their AFRs.

In addition, we recommend that the Secretary of the Treasury take the 

following two actions:

Page 27 GAO-17-15 Do Not Pay Working System
· revise Treasury’s Do Not Pay Agency Implementation Guide to clearly 

describe the limitations of the payment integration process, including 

the data sources used and the timing of matching, and

· modify the DNP working system to track adjudication of matches 

obtained through all functionalities.

We provided a draft of this report to each of the agencies we reviewed for

comment. OMB, Treasury, and SSA provided written comments, which 

are reprinted in appendixes II through IV, respectively. USDA, HHS, 

Department of the Interior, Department of Labor, VA, GSA, National 

Science Foundation, and RRB had no formal comments on the draft 

report. In addition, Treasury, HHS, Department of Labor, SSA, and 

National Science Foundation provided technical comments, which we 

have incorporated as appropriate. 

In its written comments, OMB stated that it agreed with our first two 

recommendations and cited plans to consider or implement them. OMB 

stated that it agreed or generally agreed with the concepts behind the 

remaining five recommendations, as discussed below, but did not state 

whether it agreed with the recommendations themselves or planned to 

implement them. 

· In response to our third recommendation, OMB stated that it generally 

agreed with the concept of developing a strategy for how agencies 

should use the DNP working system to complement existing data 

matching processes and will explore the concept further. 

· In response to our fourth recommendation, OMB stated that it agreed 

with the concept of consistent policies and procedures and will work 

with agencies so that their policies and procedures for verifying DNP 

matches are developed consistently. 

· In response to our fifth recommendation, OMB stated that it agreed 

with the concept of monitoring mechanisms and will continue to work 

with agencies to reduce improper payments and encourage agencies 

to establish goals to improve payment accuracy that will be monitored 

and evaluated by OMB. 

· In response to our sixth recommendation, OMB stated that it agreed

with the concept of ensuring that data are reliable and will consider 

Page 28 GAO-17-15 Do Not Pay Working System

Agency Comments

and Our Evaluation
the feasibility of a process to compare agency submissions to 

available sources to reasonably assure that agency-reported 

information on use of the DNP working system is reliable. 

· In response to our seventh recommendation, OMB stated that it 

agreed with ensuring the completeness of data and will continue to 

work with agencies and the Chief Financial Officer community to 

ensure that agency-reported information on use of the DNP working 

system is complete. 

While OMB stated that it agreed or generally agreed with the concepts 

behind the recommendations and in some cases identified steps it would 

take in response, it is too soon to determine whether OMB’s approach will 

fully address these recommendations. We continue to believe that 

implementing the recommendations would help ensure that agencies use 

the DNP working system as intended.

In its written comments, Treasury agreed with our two recommendations

to it and stated that it plans to take action to implement them.

Although there were no recommendations made to SSA, the agency 

noted in its written comments that it appreciates the matter for 

congressional consideration regarding amending the Social Security Act 

to explicitly allow the sharing of SSA’s full death file through the DNP 

working system, stating that it aligns with a similar proposal in the 

President’s Budget for fiscal year 2017. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to relevant 

congressional committees; the Director of the Office of Management and 

Budget; the Secretaries of Agriculture, Health and Human Services; the 

Interior; Labor, the Treasury; and Veterans Affairs; the Administrator of 

the General Services Administration; the Director of the National Science 

Foundation; the Railroad Retirement Board; the Commissioner of the 

Social Security Administration; and other interested parties. In addition, 

this report will be available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions on matters discussed in this report, 

please contact me at (202) 512-2623 or davisbh@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

Page 29 GAO-17-15 Do Not Pay Working System
be found on the last page of this report. GAO staff who made major 

contributions to this report are listed in appendix V.

Sincerely yours,

Beryl H. Davis

Director

Financial Management and Assurance 

Page 30 GAO-17-15 Do Not Pay Working System
Appendix I: Objectives, Scope, and 

Methodology

This review examines the extent to which (1) the Office of Management 

and Budget (OMB) and the Department of the Treasury (Treasury) 

developed the Do Not Pay (DNP) working system and obtained access to 

relevant databases, (2) selected agencies used the DNP working system 

to help review eligibility, and (3) OMB monitored the use of the DNP 

working system.

In addition to OMB and Treasury’s DNP Business Center, we selected 10 

agencies and relevant components for review. To do so, we reviewed 

budgetary outlays, net cost information, and improper payment estimates 

from fiscal year 2014 (the most recent information available at the time of 

the review), as well as information about agencies’ use of the DNP 

working system obtained from the DNP Business Center. We determined 

that these data were sufficiently reliable for the purposes of selecting 

agencies and components for review. The agencies and relevant 

components selected for review are included in table 4.

Table 4: List of 10 Agencies and Relevant Components Selected for Review

Page 31 GAO-17-15 Do Not Pay Working System

Agency Component

Department of Agriculture Commodity Credit Corporation

Food and Nutrition Service

Risk Management Agency

Rural Development

Department of Health and Human 

Services

Administration for Children and Families

Centers for Medicare & Medicaid Services

Department of the Interior N/Aa

Department of Labor Employment and Training Administration

Office of Workers’ Compensation Programs

Department of the Treasury Internal Revenue Service

Bureau of Engraving and Printing

Department of Veterans Affairs Veterans Benefits Administration

Veterans Health Administration

General Services Administration N/Aa

National Science Foundation N/Aa

Railroad Retirement Board N/Aa

Social Security Administration N/Ab

Legend: N/A = not applicable.

Appendix I: Objectives, Scope, and 

Methodology

Agencies Selected for 

Review
Appendix I: Objectives, Scope, and 

Methodology

Source: GAO analysis of fiscal year 2014 budgetary outlays, net cost information, and improper payment estimates and information on 

agencies’ use of the Do Not Pay working system. | GAO-17-15

a

This agency uses the Do Not Pay working system centrally.

b

This agency does not use the Do Not Pay working system.

To select the 10 agencies for review, we first split agencies into two 

groups (large and small agencies) based on fiscal year 2014 budgetary 

outlays. Within these groups, we analyzed fiscal year 2014 improper 

payment estimates to select agencies with high improper payment 

estimates and information on agencies’ use of the DNP Business Center 

to select agencies capable of using the different functionalities offered by 

the DNP working system. We also selected the Social Security 

Administration because, while it is the source of certain data in the DNP 

working system, the agency does not use the system.

Five of the selected agencies delegated use of the DNP working system 

to agency components. For 4 of these agencies, we selected relevant 

components for review based on analysis of information on net costs by 

components in agencies’ fiscal year 2014 agency financial reports and 

fiscal year 2014 improper payment estimates. We used this information to 

identify large components and those with high reported improper payment 

estimates. Because net cost information does not capture Treasury’s 

custodial activities relating to tax administration (i.e., tax collections and 

refunds/tax credits), we used improper payment estimates and interviews 

with agency officials to select relevant Treasury components for review.

To address our first objective, we obtained documentation from OMB and 

Treasury regarding the availability of required databases and other 

relevant databases through the DNP working system. We compared this 

documentation to relevant laws and guidance. We also interviewed 

officials at Treasury’s DNP Business Center, OMB, and the 10 user 

agencies selected for review regarding database availability and 

suggestions for additional databases for inclusion in the DNP working 

system.

To address our second objective, we interviewed officials at the selected 

agencies regarding their use of the DNP working system. Additionally, we 

met with officials at shared service providers used by certain of our 

selected agencies and components as these shared service providers 

may use the DNP working system on behalf of the selected agencies. We 

analyzed OMB and Treasury guidance on the DNP working system. We 

also reviewed the 10 selected agencies’ policies and procedures for using 

the DNP working system to determine if they were effectively designed to 

Page 32 GAO-17-15 Do Not Pay Working System

Methodology
Appendix I: Objectives, Scope, and 

Methodology

meet requirements in relevant laws, guidance, and federal internal control 

standards. Our review focused on the design of internal controls, and as 

such, we did not test the implementation of the agencies’ policies and 

procedures.

To address our third objective, we analyzed agency reporting on the use 

of the DNP working system in the 10 selected agencies’ fiscal year 2015 

agency financial reports and OMB’s first annual report on the DNP 

Initiative; obtained relevant documentation regarding OMB’s monitoring of 

the DNP working system; and compared this information to relevant laws, 

guidance, and federal internal control standards. We also interviewed 

officials at Treasury’s DNP Business Center and OMB.

We conducted this performance audit from April 2015 to October 2016 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Page 33 GAO-17-15 Do Not Pay Working System
Appendix II: Comments from the Office of 

Management and Budget

Page 34 GAO-17-15 Do Not Pay Working System

Appendix II: Comments from the Office of 

Management and Budget
Appendix II: Comments from the Office of 

Management and Budget

Page 35 GAO-17-15 Do Not Pay Working System
Appendix II: Comments from the Office of 

Management and Budget

Page 36 GAO-17-15 Do Not Pay Working System
Appendix III: Comments from the Department 

of the Treasury

Page 37 GAO-17-15 Do Not Pay Working System

Appendix III: Comments from the 

Department of the Treasury
Appendix III: Comments from the Department 

of the Treasury

Page 38 GAO-17-15 Do Not Pay Working System
Appendix IV: Comments from the Social 

Security Administration

Page 39 GAO-17-15 Do Not Pay Working System

Appendix IV: Comments from the Social 

Security Administration
Appendix IV: Comments from the Social 

Security Administration

Page 40 GAO-17-15 Do Not Pay Working System
Appendix V: GAO Contact and Staff 

Acknowledgments

Beryl H. Davis, (202) 512-2623 or davisbh@gao.gov

In addition to the contact named above, Phillip McIntyre (Assistant 

Director), James M. Healy (Auditor in Charge), Stephanie Adams, Daniel 

Flavin, Maxine Hattery, Christopher R. Klemmer, Diana Lee, Kevin 

McAloon, David Plocher, and Coleman Williams made key contributions 

to this report.

Page 41 GAO-17-15 Do Not Pay Working System

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(197248)
Appendix VI: Accessible Data

Page 42 GAO-17-15 Do Not Pay Working System

EXECUTIVE OFFICE OF THE PRESIDENT

OFFICE OF MANAGEMENT AND BUDGET

WASHINGTON, D. C. 20503

THE CONTROLLER

September 23, 2016

Ms. Beryl H. Davis

Director, Financial Management Assurance

U.S. Government Accountability Office

441 G Street NW

Washington, DC 20548

Dear Ms. Davis:

I appreciate the opportunity to provide comments on behalf of the Office 

of Management and Budget (OMB) in response to the Governmental 

Accountability Office's (GAO) draft report entitled "Improper Payments: 

Strategy and Additional Actions Needed to Help Ensure Agencies Use the 

Do Not Pay Working System as Intended" (GA0-17-15). Our partnership 

with Congress and consultation with GAO over the years has been critical 

in identifying and improving the tools and resources available for 

executive agencies to reduce and prevent improper payments. Improving 

Appendix VI: Accessible Data

Agency Comment 

Letter

Text of Appendix II: 

Comments from the Office 

of Management and 

Budget

Page 1
Appendix VI: Accessible Data

payment integrity is a fundamental component of the Administration's 

efforts to eliminate waste, fraud, and abuse in Federal programs.

On November 20, 2009, the President signed Executive Order 13520, 

Reducing Improper Payments and Eliminating Waste in Federal 

Programs, which directed the development of recommendations on "ways 

in which information sharing may improve eligibility verification and prepayment scrutiny." Following the issuance of this Executive Order, OMB 

launched the Do Not Pay (DNP) Initiative in phases to help programs 

ensure taxpayer dollars reach the intended recipients in the correct 

amounts and reduce the administrative burden on agencies of having to 

check disparate sources of information. As provided in the President's 

Budgets, OMB continues to seek partnership with Congress to further 

improve payment accuracy and remove restrictions on data sharing while 

maintaining individual privacy. The seven recommendations you suggest 

in the report correspond with actions OMB has undertaken to improve 

payment accuracy, as outlined below.

1. OMB agrees with your recommendation that a formal process for 

agencies to identify, suggest, and receive feedback on additional 

databases for inclusion in the DNP working system will assure 

additional relevant databases are identified and evaluated and OMB 

will develop, document, and communicate this process to user 

agencies. As authorized by Section 5(b)(l)(B) of the Improper 

Payments Elimination and Recovery Improvement Act of 2012, Pub. 

L. No. 112-248, (IPERIA), Section 5(b) of OMB Memorandum M- 13-

20, Protecting Privacy while Reducing Improper Payments with the Do 

Not Pay Initiative, detailed a formal process for designating additional 

databases to include OMB publishing a 30-day notice of the 

designation proposal in the Federal Register asking for public 

comment, and OMB publishing a notice in the Federal Register to 

officially designate the database for inclusion in the DNP Initiative. 

Additionally, OMB Circular

A-136, Financial Reporting Requirements, requests a narrative that 

identifies how an agency has incorporated databases not listed in 

!PERIA into existing business processes and programs to prevent 

improper payments. In addition, agencies are required to footnote 

those databases not listed in IPERIA so that OMB can identify 

additional databases for inclusion in the DNP working system.

2. OMB agrees with your recommendation and is considering revisions 

to its guidance to clarify whether the use of DNP's payment 

Page 43 GAO-17-15 Do Not Pay Working System

Page 2
Appendix VI: Accessible Data

integration functionality is required and-if required-the circumstances 

and process for obtaining an exemption. The Department of the 

Treasury's (Treasury) operation and hosting of the DNP working 

system has improved over time as Treasury has enhanced its data 

analytics capabilities. The payment integration features offered by 

Treasury provide agencies a cost-effective manner to screen 

payments against timely, accurate, and actionable information, about 

payees and payments, to assist Federal agencies with eligibility 

verification in order to reduce improper payments. Ultimately, each 

agency retains the authority to stop a payment. OMB and Treasury 

have worked with agencies to develop pilots, platforms, and portals 

for agencies to improve their payment accuracy through the 

centralized system. Section 5(a)(l) of IPERIA specifies that "[e]ach 

agency shall review prepayment and preaward procedures and 

ensure that a thorough review of available databases with relevant 

information on eligibility occurs to determine program or award 

eligibility and prevent improper payments before the release of any 

Federal funds." Agencies have begun this screening of their payments 

on different timelines because of the complexities of the authorities for 

payments and the continued important responsibility of each Federal 

program to maintain individual privacy of personally identifiable 

information. OMB does not currently provide exemptions to the 

screening requirements of IPERIA.

3. OMB Memorandum M-12-11, Reducing Improper Payments through 

the "Do Not Pay List," directed agencies to develop plans for the use 

of the DNP working system in order to comply with the President's 

2010 Memorandum on Finding and Recapturing Improper Payments, 

provide OMB visibility on implementation, and reach agreement with 

Treasury on use of the DNP system. Each agency subsequently 

provided an implementation plan and developed user agreements 

with Treasury to align with their plan. As Treasury has continued to 

improve the service offerings of the DNP system, Treasury has 

worked with agencies to improve the user interface experience, 

streamline payment reviews, and provide additional data analytics 

capabilities to help inform agencies on ways to identify, reduce, and 

stop improper payments. OMB generally agrees with the concept of 

developing a strategy for how agencies should use the DNP working 

system to complement existing data matching processes and will 

explore the concept further.

4. Subsection (p) of the Privacy Act of 1974, 5 U.S.C. § 552a, provides 

requirements for verification of matches and opportunity to contest 

findings in order to protect any individual whose records are used in a 

matching program. Payments may not be suspended, terminated, 

Page 44 GAO-17-15 Do Not Pay Working System
Appendix VI: Accessible Data

reduced, or denied under a Federal benefit program until an individual 

is notified, provided the opportunity to contest, and independent 

verification is made or an agency data integrity board reviews the 

information. Agencies retain the

authority and responsibility to confirm, notify, and resolve payment 

disputes with individuals or entities. OMB agrees with the concept of 

consistent policies and procedures and will work with agencies so that 

their policies and procedures to verify DNP matches are developed 

consistently.

5. Reducing improper payments through the DNP Initiative and the 

Treasury DNP working system are notable efforts that have 

successfully stopped over five billion dollars of improper payments 

since passage of IPERIA, and continue to improve the efficacy of 

Federal programs. During the development and implementation of the 

DNP working system, OMB recognized the program complexities as 

well as the policy and statutory specific analyses required to 

determine whether a particular payment is proper. Goals, 

benchmarks, and performance measures need to be set in a manner 

that accounts for the scale and scope of different programs. As 

described above, OMB Memorandum M-12-11 required agencies to 

develop and submit implementation plans that would tailor their 

interactions with the DNP working system to their specific program 

needs. OMB agrees with the concept of monitoring mechanisms and 

will continue to work with agencies to reduce improper payments and 

encourage agencies to establish goals to improve payment accuracy 

that will be monitored and evaluated by OMB.

6. OMB Circular A-136 includes requirements for reasonable assurance 

from agencies as each prepares and submits its Agency Financial 

Report to OMB. Treasury provides the adjudication reports to the 

agency to inform agency management of the use of the DNP system, 

and offers additional data analytics capabilities for Federal programs. 

OMB agrees with the concept of ensuring data is reliable and will 

continue to work with agencies to improve this existing reporting 

structure and will consider the feasibility of a process to compare 

agency submissions to available sources to reasonably assure that 

agency-reported information on use of the DNP working system 

remains reliable.

7. The right balance between robust reporting and costly oversight must 

be achieved on a program by program basis in order to ensure the 

optimal use of Federal funds. Treasury continues to develop tools that 

use available data to inform agencies on opportunities for improved 

Page 45 GAO-17-15 Do Not Pay Working System

Page 3
Appendix VI: Accessible Data

payment accuracy. Additionally, as OMB agrees with ensuring 

completeness of data, it will continue to work with agencies and the 

Chief Financial Officer community to ensure agency-reported 

information on use of the DNP working system is complete, and will 

consider the benefits of additional requirements beyond the statutory 

requirements.

I appreciate the attention that GAO dedicates to reviewing improper 

payments. The Administration remains committed to achieving our mutual 

objective of achieving payment integrity throughout Federal programs.

Sincerely,

David Mader

Controller

Page 46 GAO-17-15 Do Not Pay Working System

DEPARTMENT OF THE TREASURY

BUREAU OF THE FISCAL SERVICE

WASHINGTON, DC 20227

COMMISSIONER

September 23, 2016

Ms. Beryl Davis

Director, Financial Management and Assurance

U.S. Government Accountability Office

441 G Street NW

Text of Appendix III: 

Comments from the 

Department of the 

Treasury

Page 1
Appendix VI: Accessible Data

Washington, DC 20548

Dear Ms. Davis:

Thank you for the opportunity to respond to the Government 

Accountability Office's (GAO) formal draft report Improper Payments: 

Strategy and Additional Actions Needed to Help Ensure Agencies Use the 

Do Not Pay Working System as Intended, dated October 2016. The 

Department of Treasury's Bureau of the Fiscal Service (Fiscal Service) 

remains committed to continuous improvement of the Do Not Pay 

Business Center and appreciates your recommendations to further our 

efforts.

As discussed below. the Fiscal Service agrees with GAO's 

recommendations. The Do Not Pay Business Center is a data shop 

committed to providing top-notch analytics to agencies and analyzing 

data to systematically drive improvements in our products. Capitalizing on 

opportunities to more effectively assist agencies in identifying improper 

payments before those payments are disbursed is consistent with our 

objective to evolve the Do Not Pay Business Center. This is critical to 

fulfilling Do Not Pay's mission of supporting agency efforts to prevent 

government-wide improper payments.

In December 201 l, the Do Not Pay Business Center launched its online 

portal that automatically matches payee data to sources that can indicate 

a payment may be improper. We have been rapidly evolving and 

improving this tool. For example, since 2011, we have implemented 15 

new system upgrades to improve user experience and expand 

functionality. In addition, by analyzing agency usage of the portal and 

collecting agency feedback, we have dramatically reduced false positives. 

In October 2014, we debuted a tool in the portal that allows agencies to 

record the outcomes of adjudication decisions made for payment 

integration, a functionality that matches payments against data sources at 

the time of disbursement. The adjudication tool significantly increased 

agency reporting of identified improper payments. Specifically, in the first 

three quarters of fiscal year (FY) 2016, agencies reported identifying 

nearly $18.4 million of improper payments using the adjudication tool. 

This is more than double the amount reported during all of FY 2015.

Do Not Pay's online portal offers several tools that allow agencies to 

detect improper payments early enough in the payment life cycle to 

prevent the payments from being made. Because agencies have different 

business processes for pre-award and prepayment eligibility screening,

Page 47 GAO-17-15 Do Not Pay Working System
Appendix VI: Accessible Data

agencies may need solutions specifically designed to fit these processes. 

Fiscal Service is committed to driving innovation in the Do Not Pay 

Business Center to develop such solutions, but this will take systematic 

research and creativity. We have accomplished this for one agency, and 

we plan to do more. Specifically, Do Not Pay developed a customized 

function for one agency that, during the first three quarters of FY 2016, 

stopped nearly $34 million of improper payments before the payments 

were disbursed.

Finally, Do Not Pay's payment integration tool will always have an 

important role in addressing improper payments even as Do Not Pay 

enhances tools to screen payments before they are disbursed. Payment 

integration is a final defense against improper payments, and it has been 

critical in identifying payments that would be recurring such as a monthly 

benefit. Of the nearly $18.4 million in improper payments identified 

through payment integration in the first three quarters of FY 2016, about 

$17.4 million were flagged as monthly benefits. Absent payment 

integration, these payments may not have been stopped in future months.

Our responses to the two recommendations are as follows:

1. Revise Treasury's Do Not Pay Agency Implementation Guide to 

clearly describe the payment integration process, including the data 

sources used and timing of the matching. Fiscal Service concurs with 

GAO's recommendation. We appreciate GAO identifying agencies' 

need for additional information and will make the recommended 

updates.

2. Modify the working system to track adjudication of matches obtained 

through all functionalities.

Fiscal Service concurs with GAO's recommendation, and we plan to 

develop a tailored solution to ensure we are building to user needs.

If you have any questions or wish to discuss these comments in more 

detail, please contact me on (202) 874-7000.

Sincerely,

Sheryl R. Morrow

Commissioner

Page 48 GAO-17-15 Do Not Pay Working System

Page 2
Appendix VI: Accessible Data

Page 49 GAO-17-15 Do Not Pay Working System

SOCIAL SECURITY

Office of the Commissioner

September 19, 2016

Mrs. Barbara D. Bovbjerg

Managing Director, Education, Workforce, and Income Security Issues

United States Government Accountability Office

441 G Street, NW

Washington, DC 20548

Dear Mrs. Bovbjerg:

Thank you for the opportunity to review the draft report, "Improper 

Payments: Strategy and Additional Actions Needed to Help Ensure 

Agencies Use the Do Not Pay Working System as Intended" (GA0-17-

15). We agree that the Do Not Pay (DNP) portal is an important part of 

the Administration's efforts to prevent, reduce, and stop improper 

payments while protecting citizens' privacy.

Under current law, we are not authorized to share state death information 

with the DNP portal. Section 205(r) of the Social Security Act (Act) limits 

the purposes for which we may disclose state death information. While 

the Federal Improper Payments Coordination Act of 2015 (P.L. 114-109) 

requires us to share our death information with DNP, it did not amend 

section 205(r) of the Act to include authority for us to provide DNP State 

death information. Thus, we appreciate GAO's recommendation that 

"Congress should consider amending the Act to explicitly allow SSA to 

share its full death file with Treasury for use through the DNP working 

system." This recommendation also aligns with a proposal in the 

President's fiscal year (FY) 2017 Budget that would grant us the legal 

Text of Appendix IV: 

Comments from the Social 

Security Administration

Page 1
Appendix VI: Accessible Data

authority to share all our death information, including data from the states, 

with DNP.

Our death records are important to our program integrity efforts and help 

us ensure accurate payment of Social Security benefits. They are also a 

useful tool for other Federal agencies that issue Federal payments. 

Nevertheless, we are not the national repository of death information, and 

as GAO acknowledges in this report, the death data we collect is not a 

comprehensive accounting of every death in the U.S. We are, however, 

committed in continuing to share death information with our Federal 

partners, as required by law, and to improving the accuracy of the data 

we collect. Accordingly, as recognized in the President's FY 2017 Budget, 

we believe the best possible way to improve the quality of the death 

information we collect and share is for Congress to fund the continued 

expansion by the states of Electronic Death Registration.

SOCIAL SECURITY ADMINISTRATION

BALTIMORE, MD 21235-0001

If you have any questions, please contact me at (410) 965-4991. Your 

staff may contact Gary S. Hatcher, Senior Advisor for the Audit Liaison 

Staff, at (410) 965-0680.

Sincerely

Frank Cristaudo

Executive Counselor to the Commissioner

Enclosure

Page 50 GAO-17-15 Do Not Pay Working System

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