Audit Report

OIG-20-025

Fiscal Service

Performance Metric Policy Needed for the Fiscal Service Do Not 

Pay Business Center’s Data Analytics Services

January 28, 2020

Office of

Inspector General

Department of the Treasury
This Page Intentionally Left Blank 
Contents 

Performance Metric Policy Needed for the Fiscal Service Do Not Pay 

Business Center’s Data Analytics Services (OIG-20-025) Page i

Audit Report.................................................................................. 1

Results in Brief............................................................................................ 2

Background ................................................................................................ 5

Audit Results .............................................................................................. 9

Fiscal Service’s Performance Metrics for Measuring the Effectiveness of the 

Business Center DAS Need to Be Strengthened .......................................... 9

Recommendation .................................................................................... 17

Approvals of Project Deliverables Are Not Centrally Tracked and Improvements 

Are Needed in the Lessons-Learned Review Process.................................... 18

Appendices

Appendix 1: Objectives, Scope, and Methodology ...................................... 25

Appendix 2: Significant Events in the Development of the Do Not Pay

Business Center.....................................................................27

Appendix 3: Management Comments........................................................ 30

Appendix 4: Major Contributors to This Report........................................... 32

Appendix 5: Report Distribution................................................................ 33

Abbreviations

AIR Agency Insight Report

DAS data analytics services

DNP Do Not Pay

Fiscal Service Bureau of the Fiscal Service

FRB-Kansas City Federal Reserve Bank of Kansas City

FRB-STL Federal Reserve Bank of St. Louis

GAO Government Accountability Office

GPRA Government Performance and Results Act

IPERIA Improper Payments Elimination and Recovery Improvement Act 

of 2012
Contents

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Business Center’s Data Analytics Services (OIG-20-025) Page ii

JAMES Joint Audit Management Enterprise System

OIG Office of Inspector General

OMB Office of Management and Budget

SOP Standard Operating Procedure

SSA Social Security Administration

Treasury Department of the Treasury
OIG Audit 

Report

The Department of the Treasury

Office of Inspector General 

Performance Metric Policy Needed in the Fiscal Service Do Not Pay

Business Center’s Data Analytics Services (OIG-20-025) Page 1

January 28, 2020

Timothy E. Gribben 

Commissioner

Bureau of the Fiscal Service

This report presents the results of our audit of data analytics 

services (DAS) provided by the Department of the Treasury 

(Treasury) Bureau of the Fiscal Service’s (Fiscal Service), Do Not 

Pay (DNP) Business Center (hereinafter Business Center).

1

Fiscal 

Service established the Business Center in 2011 to support Federal 

agencies in their efforts to reduce the number of improper payments 

made through programs funded by the Federal Government.

2,3

Fiscal 

Service partnered with the Federal Reserve Bank of St. Louis (FRBSTL), through a fiscal agent agreement, to develop and provide the

Business Center DAS to agencies at no cost.4In addition, Fiscal 

Service partnered with the Federal Reserve Bank of Kansas City 

(FRB-Kansas City) to develop and operate the DNP portal for 

agencies to utilize DNP data. Through these DAS, the Business 

Center assists agencies by identifying trends and patterns through 

complex analyses of agency payments and other information that 

may be indicative of improper payments and provides this 

information to the agencies for further study. The Business Center 

reports to Fiscal Service senior management and to the Office of 

Management and Budget (OMB).

 

1 Effective October 2012, Treasury consolidated the Financial Management Service with the Bureau of 

the Public Debt to form Fiscal Service.

2 The Business Center was established by the Bureau of the Public Debt in response to the Presidential 

Memorandum dated June 18, 2010, Enhancing Payment Accuracy Through a “Do Not Pay List,”

Federal Register 75, No. 120, 35953. Through this memorandum, the President directed the 

establishment of a single point of entry through which agencies would access relevant data before 

determining eligibility for a benefit, grant, contract award, or other Federal funding.

3 An improper payment is 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. This includes any payment to an ineligible 

recipient, payment for an ineligible service, duplicate payment, and payment for services not received. 

4 A fiscal agent is an organization such as a bank or trust that acts on behalf of another party performing 

various financial duties.
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Business Center’s Data Analytics Services (OIG-20-025)

The objective of our audit was to assess how the Business Center 

DAS support the Federal Government’s efforts to identify and 

prevent improper payments. To accomplish this objective, we 

interviewed officials from the Business Center and FRB-STL

analytics division. We also interviewed officials from seven Federal 

agencies that participated in DAS projects, and reviewed 

documentation for DAS projects completed from the inception of 

the program through September 2016. We performed our fieldwork 

from March 2016 through November 2016, with additional followup through October 2019. Appendix 1 provides a more detailed 

description of our audit objective, scope, and methodology.

Results in Brief

Fiscal Service developed the Business Center to provide DAS to help

Federal agencies identify and prevent improper payments. We 

concluded that performance metrics developed by Fiscal Service to 

measure the effectiveness of the Business Center DAS need to be 

strengthened. Specifically, we noted that Fiscal Service developed 

performance metrics for measuring the effectiveness of completed 

DAS projects. For example, the metrics summarize the number and 

types of DAS projects initiated by the Business Center, business 

process mapping activities, and newly adopted DNP functionalities 

requested based on completed projects. However, the metrics did 

not include criteria such as specific dollar amounts of and 

percentage of improper payments identified or prevented as a result 

of completed DAS projects and agency follow-up. Without 

performance metrics that include the measurement of the actual 

impact of DAS projects on agencies’ efforts to prevent improper 

payments, Fiscal Service cannot fully measure if DAS are meeting 

the Business Center’s objectives. In addition, we found that Fiscal 

Service had not established a formal policy for the development,

implementation, and periodic review of performance metrics for 

DAS. 

We are recommending that the Commissioner of Fiscal Service 

establish a formal policy to develop, implement, and periodically 

review performance metrics to measure the impact of the Business 

Center DAS on agencies’ efforts to identify and prevent improper 

payments. This includes, but is not limited to, the development of 
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performance metrics based on the dollar value and percentage of 

customer agencies’ reduced improper payments as a result of 

completed DAS projects and agency follow-up.

In addition, during our fieldwork, we found that although Fiscal 

Service had a process in place for customer agencies to provide 

feedback regarding the improper payments identified, feedback was 

provided for less than 50 percent of the completed DAS projects.

Further, information about the participating agencies’ customary 

payments would also be useful for analyses of payment patterns 

that were acceptable and not representative of improper payments.

With that said, after the completion of our fieldwork and in 

response to our findings, Fiscal Service consulted with counsel and 

OMB to produce language for all DAS agency agreements to require 

customer agency feedback by a certain date and to quantify (a) the 

actual or projected number and dollar amount of improper payments 

identified and/or prevented; (b) costs avoided or projected to be 

avoided through process improvements or other results of the 

analytics project; and/or (c) other direct or indirect benefits flowing 

from the project. Based on our review of the language produced for 

the agency agreements, we are satisfied that Fiscal Service worked 

with OMB to improve the process to obtain feedback from customer 

agencies. Therefore, we are not making any related 

recommendations.

We also found, during our fieldwork, that FRB-STL was not centrally 

tracking approvals of project deliverables to ensure all required 

approvals were obtained prior to release of the end products to the 

customer agency. Rather, the FRB-STL analytics team recorded

approvals of DAS project deliverables through email messages 

stored in individual project folders. This approach was not 

consistent with the methodology used prior to the project initiation 

phase, in which FRB-STL tracked approvals and other items through 

its governance tracker. Similarly, FRB-STL was not centrally 

recording the results of lessons-learned reviews of completed

projects to facilitate sharing of the review results. The Business 

Center and FRB-STL could benefit from these records being centrally 

recorded and available to all project teams. These records could also

be used to improve future analytic projects and avoid problems 

encountered on completed projects. 
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After completion of our fieldwork and in response to our findings, 

Fiscal Service developed a project administrative closure form to

provide central tracking of approvals for DAS project deliverables 

and completion of lessons-learned reviews. We reviewed the

administrative closure form, which includes a checklist that tracks, 

among other things, the Fiscal Service approvals and the fulfillment 

of a lessons-learned review for each completed DAS project. In 

addition, FRB-STL’s Analytics Projects standard operating procedure 

(SOP) requires that the administrative closure form be completed 

and saved on the FRB-STL Analytics SharePoint Site. Furthermore, 

Fiscal Service responded that common issues from project level 

lessons-learned reviews are rolled up by category to the portfolio 

level and discussed by Fiscal Service leadership and analytics staff 

during a quarterly vision meeting. The portfolio level lessons-learned 

are also centrally stored and tracked on the FRB-STL Analytics 

SharePoint Site. Based on our review of the Analytics Projects SOP 

and the new processes put in place, we are satisfied that Fiscal 

Service has completed actions to centrally track approvals of project 

deliverables and lessons-learned reviews, as well as to ensure that 

the results of all lessons-learned reviews are considered by analytics 

teams in conducting future projects. Therefore, we are not making 

any related recommendations. 

In a written response, which is included in its entirety as appendix 

3, Fiscal Service management concurred with our recommendation. 

Fiscal Service management stated that Fiscal Service and the 

Business Center DAS have established an internal working group to 

evaluate current metrics and recommend new metrics that will 

measure the effect of DAS on both the number and dollar amount 

of improper payments. These metrics will also seek to measure the 

percentage of reduced improper payments as communicated by 

customer agencies. At the exit conference discussing our audit 

results, the current Executive Director of the Business Center stated 

that Fiscal Service will establish a formal policy that documents the 

process on how the bureau measures the impact of DAS towards 

customer agencies’ efforts in identifying and preventing improper 

payments.

Management’s response and its corrective actions, taken and 

planned, meet the intent of our recommendation. Management will 
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need to record the estimated date for completing its planned 

corrective actions as well as the actual date of completed corrective 

actions in the Joint Audit Management Enterprise System (JAMES), 

Treasury’s audit recommendation tracking system.

Background

In response to the Administration’s efforts to combat improper 

payments and in accordance with the June 2010 Presidential 

Memorandum discussed above, OMB directed Treasury to establish 

the Business Center as part of the overall government-wide DNP 

Initiative to identify and prevent improper payments. During April 

2012, OMB directed agencies to develop plans for pre-payment 

eligibility reviews and how to identify improper payments.5 

The Improper Payments Elimination and Recovery Improvement Act 

of 2012 (IPERIA) codified the Administration’s efforts regarding 

improper payments by requiring Federal executive agencies, no later 

than June 1, 2013, to review, as appropriate, all payments and 

awards. OMB was designated to establish a DNP working system 

for agencies to perform prepayment eligibility reviews using 

specified databases.6 OMB’s August 2013 memorandum provides 

the roles and responsibilities for OMB, Treasury, payment issuing 

agencies such as Fiscal Service, and Federal agencies that have the 

data that is used by a payment-issuing agency to perform eligibility 

reviews.7

 OMB designated Treasury to host the DNP working 

system. The DNP working system includes the system of records 

 

5

 The centralized DNP solution referenced by OMB Memorandum M-12-11, Reducing Improper Payments 

through the “Do Not Pay List” (April 12, 2012), refers to the Fiscal Service Business Center. 

6

 P.L. 112-248 (January 10, 2013) requires agencies to review five databases, at a minimum, including 

(1) the Social Security Administration’s (SSA) Death Master File; (2) the General Services 

Administration’s Excluded Parties List System; (3) Treasury’s Debt Check Database; (4) the 

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

Response System; and (5) the Department of Health and Human Services Office of Inspector General’s

(OIG) List of Excluded Individuals/Entities. Information regarding incarcerated individuals maintained by 

the Commissioner of Social Security under sections 202(x) and 1611(e) of the Social Security Act was 

added to IPERIA as a sixth required database by the enactment of P.L. 113-67, Bipartisan Budget Act 

of 2013, on December 26, 2013. The Prisoner Update Processing System maintains this information. 

7

 OMB Memorandum M-13-20, Protecting Privacy while Reducing Improper Payments with the Do Not 

Pay Initiative (August 16, 2013)
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for DNP used for the detection of improper payments through 

analytic technology techniques. 

Business Center 

The Business Center, established within Fiscal Service’s Debt 

Management Services division, is responsible for administering the 

Fiscal Service programs and services relating to the identification 

and prevention of improper payments. The Business Center’s 

management team reports to Fiscal Service senior management and 

OMB. 

Fiscal Service partnered with FRB-Kansas City and FRB-STL to 

develop and operate the Business Center’s DNP portal, and DAS 

components.8 Officials from the Business Center’s outreach teams 

work with Federal agencies to educate them on the suite of no cost 

services available through the Business Center, the value of these 

services, and the process of on-boarding agencies to participate in 

the DNP program.9 Appendix 2 presents a timeline of significant 

events relating to the development of the Business Center as the 

host of the working system established by OMB to meet the 

requirements of IPERIA.

DNP Portal 

The DNP portal provides participating Federal agencies with an 

online, single point of entry to the Business Center’s DNP data

sources.10 Through the portal, agencies can assess recipient 

eligibility to receive federal payments or engage in federal contracts 

or grants. Agencies can perform individual online searches across 

the DNP data sources, or utilize the portal’s batch processing 

capabilities to have recipient records included in agency submitted 

files evaluated against DNP data sources. 

The Business Center also offers a continuous monitoring service to 

agencies. With this service, files of agency provided recipient 

 

8 The FRB-STL and FRB-Kansas City provide services to the Business Center under a fiscal agent 

agreement with Fiscal Service.

9 Outreach teams are comprised of officials from FRB-STL and the Business Center.

10 The DNP portal is operated by the FRB-Kansas City on behalf of Fiscal Service. 
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information are retained by the Business Center and continuously 

evaluated against DNP data sources. Agencies are notified by email 

of potential recipient eligibility changes and can view the details of 

the changes through the portal. Agencies also use the portal to 

retrieve information on agency payment records that matched 

information from either of two DNP data sources that are queried by 

Fiscal Service through its payment integration process.11 

DAS 

Beginning operation in 2014, DAS were the last major DNP function 

implemented by the Business Center. DAS are provided by FRB-STL 

through a fiscal agent agreement with Fiscal Service to assist 

agencies by identifying trends and patterns in agency payment data, 

and risks associated with fraud or systemic sources of improper 

payments. DAS have also been used on projects to assess the 

quality of data in the DNP data sources and to create new business 

processing rules for agencies interested in refining the criteria used 

in portal matching to reduce false positives. 

Federal agencies can request DAS support on projects that meet the 

agencies’ business needs. The FRB-STL analytics team can also 

initiate projects that focus on agencies that might benefit from 

DAS. DAS projects include customized analyses of agencies’ 

payment information for irregularities and patterns indicative of 

improper payments. DAS projects also include the matching of 

agency payment or other information to DNP data sources and the 

matching of payment information from multiple Federal agencies to 

identify common recipients that may be indicative of improper 

payments. The Business Center outreach teams promote DAS 

services and facilitate communication with agencies to determine 

the types and depth of custom analyses to be conducted. 

In developing the initial set of analytics projects with Federal 

agencies, the Business Center’s Outreach and Business Processes 

division, as instructed by OMB, focused its research on Federal 

 

11 Through payment integration, many agency payments processed by Fiscal Service are matched to

records included in SSA’s Death Master File and the General Services Administration’s System for 

Award Management Exclusion Records. The results of these matches are made available to the 

agency through the DNP portal for adjudication. 
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agencies that had high rates of improper payments rooted in 

eligibility verification errors and did not receive funding to develop 

internal payment integrity programs.12 The Business Center 

continued this approach during our audit, along with vetting any 

other agency requests for DAS support.

The Business Center staff, which includes personnel from Fiscal 

Service, worked with FRB-STL analytics management to establish a 

governance process. This process was designed to ensure that 

proposed analytics projects involving data matching or relying on 

information included in restricted DNP data sources are reviewed 

and approved by Business Center management, and that all legal 

and privacy issues are resolved.13 The Business Center management 

team developed a governance tracking application to monitor the 

status of proposed analytics projects, document governance 

decisions, and ensure that required approvals are obtained prior to 

the initiation of the planning phase for each project.

At the conclusion of the project, deliverables for the customers are

approved by Fiscal Service and FRB-STL prior to release. These

deliverables may include reports that provide specific information 

about payments such as dates, amounts, payee names, and the 

sources of data related to payments identified as potentially 

improper. FRB-STL is responsible for maintaining the official record 

of documentation for the deliverables. Fiscal Service relies on FRBSTL for the official records for DAS projects.

Similarly, FRB-STL is responsible for maintaining the official records 

of the lessons-learned reviews, which serve as a source of 

information for Fiscal Service. FRB-STL implemented a lessonslearned review process as part of its operating procedures for 

completed analytics projects. The lessons-learned reviews are 

intended to identify areas that went well during the execution of 

each project, process improvements that can be made, and pitfalls 

to be avoided in future projects.

 

12

 The Department of Health and Human Services, Internal Revenue Service, SSA, and the Department 

of Labor have received funding from Congress to develop analytical capabilities to identify and prevent 

improper payments through payment integrity programs.

13 The Business Center management is responsible for determining the analytics projects that require 

data governance approval. 
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In 2015, the Business Center introduced Agency Insight Reports 

(AIR) to Federal agencies. AIRs are high-level summary reports that 

Fiscal Service began providing to selected Federal agencies.14 AIRs 

show patterns and anomalies in agency payment data that may 

warrant further in-depth study. The Business Center’s outreach 

teams present AIRs to agencies to help them understand the 

information provided and the value of DAS, as well as to facilitate 

communication between agency and DAS representatives in 

developing in-depth analytical projects based on AIRs. 

As of March 16, 2018, there were 37 DAS analytics projects 

completed for 13 Federal agencies and 46 internal analytics 

analyses of the usefulness of payment data sources for the Business 

Center’s informational purposes. These internal analyses may 

include a background of the data that was analyzed, information 

about the scope of the analysis including the data elements 

analyzed, data trends from payment information analyzed, and 

commentary on the agency’s payment data quality based on the 

analysis. 

Audit Results

Finding 1 Fiscal Service’s Performance Metrics for Measuring the 

Effectiveness of the Business Center DAS Need to Be 

Strengthened

We concluded that performance metrics developed by Fiscal Service 

to measure the effectiveness of the Business Center DAS need to 

be strengthened. We noted the performance metrics summarized 

the number and types of in-depth analytics projects, business 

process mapping activities, and newly adopted DNP functionalities 

requested based on completed projects. However, performance 

metrics did not include criteria to measure the actual amount of

improper payments identified or prevented. As a result, the impact 

 

14 The Business Center selected the following agencies that were considered to have the highest rate of 

improper payments and did not receive substantial program integrity funding: the Department of 

Agriculture, the Department of Education, the Department of Housing and Urban Development, the 

Department of Veterans Affairs, the Small Business Administration, and the Department of Defense. 
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of the Business Center DAS on agencies’ efforts to prevent 

improper payments could not be determined. In addition, Fiscal 

Service had not established a formal policy for the development, 

implementation, and periodic review of performance metrics for 

DAS. We also found that customer agency feedback was provided 

for less than 50 percent of the completed DAS projects. Further, it 

would be useful for agencies to also provide feedback on payments 

unique to their operations that may appear as improper but are valid 

payments.

Performance Metrics Did Not Include Criteria to Measure the 

Effectiveness of the Business Center DAS on Agencies’ DNP Efforts 

The Business Center DAS performance metrics were adopted by 

Fiscal Service following a fiscal year 2016 presentation to OMB. As 

OMB’s designated agency for administration of the DNP initiative, 

Treasury in conjunction with Fiscal Service, creates and develops 

performance metrics that are reported to OMB. The former 

Executive Director of the Business Center stated that the 

performance metrics in use resulted from a verbal agreement 

between Fiscal Service and OMB. The metrics for quarterly 

reporting were developed to assess how well the Business Center 

was meeting its goals to provide: 

 timely, accurate, and actionable information to assist 

agencies with eligibility verification in order to reduce 

improper payments; 

 clear and understandable information using data analytics 

regarding the nature, causes, and magnitude of improper 

payments; and 

 timely, accurate, and actionable information about improper 

payments. 

To assess the impact DAS have in assisting agencies in their 

improper payments efforts for reporting to OMB, Fiscal Service 

measures the items listed below. 
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 AIR Outcomes 

o The number and type of newly adopted DNP 

functionalities resulting from AIRs, 

o the number and type of business process mapping 

activities resulting from AIRs, and 

o the number and type of in-depth analytics projects 

resulting from AIRs. 

 Business Process Mapping Outcomes 

o The number and type of newly adopted DNP 

functionalities resulting from business process mapping 

activities. 

 Multi-Agency/Government-Wide Projects Initiated 

o The number of cross-agency/government-wide highlevel research reviews, and 

o the number of cross-agency/government-wide in-depth 

analytics projects. 

These performance metrics allowed Fiscal Service to summarize the 

number and types of DAS projects undertaken or new business 

processes developed through the DAS program. Statistical data 

derived from these metrics demonstrated that the Business Center 

was reaching out to Federal agencies regarding data analytics 

through AIRs and other products, and developing in-depth analytical 

projects with the agencies. In fiscal year 2017, Business Center 

management updated the presentation of these performance metrics 

to provide OMB and Fiscal Service management with visual 

summaries of the results of DNP efforts, and to display trend 

information. 

The Business Center DAS performance metrics, however, did not 

include criteria for Fiscal Service to determine the impact of its 

efforts. For example, specific dollar amounts of improper payments 

that were actually identified or prevented as a result of the 

completed in-depth DAS projects and agency follow-up on the 

results were not included. DAS projects identified areas of concern 
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for agencies, and in some cases, potential payments that may have 

been improper. The determination of which would only be known 

after agencies completed follow-up reviews on deliverables provided 

by the Business Center. 

The Government Performance and Results Act (GPRA) 

Modernization Act of 2010 requires Federal agencies to annually 

submit performance plans covering each program activity set forth 

in the agency’s budget.15 The performance plans should establish 

performance goals to be achieved, which should be expressed in 

objective, quantifiable, and measurable form unless an alternative 

form has been authorized by OMB. While the Business Center DAS 

performance metrics are measurable, they do not provide for a 

measurement of the true impact of DAS on agencies’ efforts to 

identify and prevent improper payments. 

The Government Accountability Office’s (GAO) Standards for 

Internal Control in the Federal Government state, 

Management establishes processes to evaluate performance 

against the entity’s expected standards of conduct and 

address any deviations in a timely manner. Management 

determines whether performance measures for the defined 

objectives are appropriate for evaluating the entity’s 

performance in achieving those objectives. For quantitative 

objectives, performance measures may be a targeted 

percentage or numerical value. For qualitative objectives, 

management may need to design performance measures that 

indicate a level or degree of performance, such as 

milestones.

16

 

While the DNP program currently has performance metrics, we 

believe they can be enhanced. Without performance metrics that 

include the measurement of the actual impact of in-depth DAS 

projects on agencies’ efforts to prevent improper payments, Fiscal 

Service cannot fully measure if DAS are meeting the Business 

Center’s objectives. The Business Center reported that metrics were 

 

15

 P.L. 111-352, GPRA Modernization Act of 2010 (January 4, 2011), Section 3, 1115, Federal 

Government and agency performance plans 

16

 GAO, Standards for Internal Control in the Federal Government (Sept. 2014). 
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added for internal purposes in fiscal year 2017 to aid Fiscal Service 

management in assessing the Business Center DAS. However, we 

found no evidence that the metrics were sufficient to assess the 

effectiveness of DAS based on the dollar value and percentage of 

customer agencies’ reduced improper payments. As an additional 

follow-up, in March 2018, we asked Fiscal Service if its 

performance metrics have changed since May 2017 and Fiscal 

Service replied that OMB has not asked DNP for new metrics. 

Fiscal Service Did Not Have a Formal Policy for DAS Performance 

Metrics 

We noted Fiscal Service did not have a formal policy for DAS 

performance metrics. That said, the Business Center is in a unique 

position regarding performance metrics. Treasury, through Fiscal 

Service, operates the program for OMB. As a result, Fiscal Service 

is responsible for reporting to OMB regarding the results of the DNP

initiative. The Business Center’s former Executive Director stated 

that Fiscal Service has been reporting to OMB on performance 

metrics quarterly since fiscal year 2016. However, to ensure that 

Fiscal Service maintains consistent reporting on the DNP initiative, 

we believe it should establish a formal policy. This policy should 

provide for the development, implementation, and periodic review of 

performance metrics measuring the impact of the Business Center 

DAS on agencies’ efforts to identify and prevent improper 

payments. 

According to Fiscal Service, decisions about Business Center DAS 

performance metrics and related processes are developed 

considering input from OMB. While Fiscal Service does not have a 

formal policy regarding development of Business Center DAS 

performance metrics, the bureau has a process in place using an adhoc cross-functional team of DAS representatives to periodically 

refresh metrics to meet OMB expectations. 

The Business Center’s former Executive Director recognized the 

importance of a formalized policy for performance metrics, but 

stated that because the Business Center DAS were relatively new, 

Fiscal Service had not had the time to develop a formal policy. The 

former Executive Director believed that Fiscal Service was fully 
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aware of the effectiveness of DAS efforts through continued dialog 

with officials at the agencies served and with the analytics team at 

FRB-STL, along with the increased number of analytics projects 

completed, underway, or planned. When asked, Fiscal Service 

stated a formalized policy for performance metrics had not been 

implemented because it had a verbal agreement with OMB regarding

quarterly reporting of AIR outcomes, business process mapping 

outcomes, and multi-agency/government-wide projects initiated. 

GAO’s Standards for Internal Control in the Federal Government

state, “Management designs control activities in response to the 

entity’s objectives and risks to achieve an effective internal control 

system” and that “management should implement control activities 

through policies.”17 

We believe that Fiscal Service needs to formalize its practices 

regarding the development, implementation, and periodic review of 

performance metrics into a written policy. The policy should ensure 

that periodic reviews of the performance metrics in use are 

completed to determine if the metrics remain appropriate for 

assessing the performance of Business Center DAS and meet the 

needs of OMB and Fiscal Service management. These performance 

metrics should be written so that the Business Center consistently 

collects the data necessary to report the impact of its efforts to 

identify and prevent improper payments. 

The Process to Obtain Customer Agency Feedback on the 

Completed DAS Projects Needs Improvement 

At the conclusion of DAS projects, the Business Center held project 

closeout meetings with agency officials and FRB-STL analytics 

teams to discuss the deliverables, obtain agency feedback on the 

DAS process, and identify improvements for future analytics 

projects. It should be noted that the effectiveness of the DAS 

projects was not available at the time of these meetings because 

agencies needed to complete their research to determine if the 

payments were improper. Following these meetings, Fiscal Service 

had a process in place for agencies to provide the results of their 

research and conclusions once complete; however, feedback was 

 

17 GAO, Standards for Internal Control in the Federal Government (Sept. 2014).
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provided in less than 50 percent of the DAS projects completed. 

The purpose of the DNP program is to help in the government-wide 

effort to reduce improper payments by assisting agencies in their 

efforts to prevent improper payments.18 In order for Fiscal Service 

to fully determine if the Business Center DAS are meeting this 

objective, Business Center management needs to seek feedback 

from its customer agencies regarding DAS projects. In addition, to 

make DAS projects more effective, it would be beneficial to know 

the types of payments made by the agencies, which should include 

unique patterns to be considered when the Business Center is 

performing DAS. 

Treasury’s fiscal year 2015 Citizens’ Report stated that Treasury 

had improved its analytics capabilities and developed agencyspecific reports that provide a particular agency (or program within 

an agency), a high-level summary of statistical observations that 

may contribute to improper payments.19 The Citizens’ Report noted 

that these observations may call for more in-depth analytical 

projects to assess the potential improper payments, determine the 

root cause, and develop internal control methodologies to eliminate 

the improper payments. 

Subsequently, in its September 2016 Improper Payments Data 

Analysis Report to Congress required by the Federal Improper 

Payments Coordination Act of 2015,20 Treasury cited numerous 

success stories regarding the services provided to agencies by the 

Business Center through the portal and payment integration. 

Regarding DAS, Treasury noted several projects that had identified 

potential duplicate payments and that the customer agencies were 

conducting research to determine if the payments were duplicate 

payments. We believe the Business Center needs to obtain agency 

information in order to determine the effectiveness of its DAS 

 

18 Objective 3.2 of the Treasury Fiscal Year 2014-2017 Strategic Plan calls for Treasury to reduce 

improper payments made by the U.S. Government. Treasury’s improper payment efforts are led by the 

functions implemented by the DNP Business Center. However, Treasury’s Strategic Plan 2018 -2022 

did not have any objectives related to improper payments. 

19

 The Treasury Citizens’ Report, Summary of Performance and Financial Information, Fiscal Year 2015

(February 16, 2016) 

20 P.L. 114-109, (December 18, 2015), Section 4, Data Analytics 
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Business Center’s Data Analytics Services (OIG-20-025)

program. For example, agencies should provide data on the 

confirmed number or dollar value of identified improper payments. 

When reaching out to customer agencies during our fieldwork, 

officials stated that they planned to provide feedback to the 

Business Center at some point. Further, officials at four agencies 

told us that while the DAS project results were helpful, further 

research by the agencies was needed to determine if the payments

were, in fact, improper. In some cases, agency officials believed 

that based on their knowledge of the payment types or other 

factors that the Business Center was not aware of, the payments 

identified by DAS were not improper. That said, obtaining this

feedback will help the Business Center streamline future analysis

which, in turn, will help agencies prevent improper payments. 

For example, one project where the Business Center, using an 

agency provided file, identified beneficiaries that were included on 

SSA’s Death Master File, the agency deactivated the recipient 

records in its internal system. While the results of this project may 

have prevented improper payments, without further agency 

feedback, the Business Center could not determine the actual 

impact of the project on the agency’s improper payment efforts. We 

believe it would benefit future DAS projects if agencies provided the 

Business Center the types and patterns of their payments. In 

addition, this information could help the Business Center identify 

those payments that are improper.

Based on our review of the SOPs provided to us in April 2018, we 

found that Fiscal Service had not implemented any new policies and 

procedures for obtaining feedback for the Business Center.

Recognizing that Fiscal Service does not have the authority to 

compel agencies to provide feedback, we believe the critical nature 

of this information in assessing the impact of DAS projects on 

agency improper payments, as well as more focused planning for 

future projects, warrants heightened Fiscal Service effort in this 

area. The lack of customer agencies’ interest to provide feedback 

inhibits the Business Center’s ability to obtain information about the 

impact of these projects to reduce improper payments.
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Business Center’s Data Analytics Services (OIG-20-025)

After the completion of fieldwork and in response to our findings, 

Fiscal Service consulted with counsel and OMB to produce language 

for all DAS agency agreements that were not yet signed as of 

October 1, 2019. The language requires customer agency feedback 

by a certain date, which will be determined at the time of the 

engagement, taking into account the scope and complexity of the 

engagement. It also requires the customer agency to quantify

(a) the actual or projected number and dollar amount of improper 

payments identified and/or prevented; (b) costs avoided or projected 

to be avoided through process improvements or other results of the 

analytics project; and/or (c) other direct or indirect benefits flowing 

from the project. With the language produced for the agency 

agreements, we are satisfied that Fiscal Service worked with OMB 

to improve the process to obtain feedback from customer agencies. 

Therefore, we are not making related recommendations to this 

finding.

Recommendation 

We recommend the Commissioner of Fiscal Service: 

1. Establish a formal policy to develop, implement, and periodically 

review performance metrics to measure the impact of the 

Business Center DAS on agencies’ efforts to identify and prevent 

improper payments. This includes, but is not limited to, the 

development of performance metrics based on the dollar value 

and percentage of customer agencies’ reduced improper 

payments as a result of the completed DAS project and agency 

follow-up. 

Management Comments 

Fiscal Service management concurred with the recommendation. 

According to its response, Fiscal Service and the Business 

Center DAS have established an internal working group to 

evaluate current metrics and recommend new metrics that will 

measure the effect of DAS on both the number and dollar 

amount of improper payments. These metrics will also seek to 

measure the percentage of reduced improper payments as 

communicated by customer agencies. At an exit conference 
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Business Center’s Data Analytics Services (OIG-20-025)

discussing our audit results, the current Executive Director of the 

Business Center stated that Fiscal Service will establish a formal 

policy that documents the process on how the bureau measures 

the impact of DAS towards customer agencies’ efforts in 

identifying and preventing improper payments. 

Office of Inspector General (OIG) Comment 

Management’s response and planned and taken corrective 

actions meet the intent of our recommendation. 

Finding 2 Approvals of Project Deliverables Are Not Centrally 

Tracked and Improvements Are Needed in the LessonsLearned Review Process 

FRB-STL, as the fiscal agent, did not centrally track project 

deliverable approvals to ensure all required approvals were obtained 

prior to release of deliverables to customer agencies. In addition, 

FRB-STL’s controls did not ensure that the results of its lessonslearned reviews performed on completed projects were centrally 

summarized to make useful information readily available for future 

projects. Fiscal Service should ensure that the fiscal agent 

agreement with FRB-STL provides for improved tracking of 

approvals for DAS project deliverables and requires controls to 

ensure lessons-learned reviews are performed for all projects, and 

the results of these reviews are centrally summarized. 

FRB-STL Did Not Centrally Track Approvals for DAS Project 

Deliverables 

DAS projects authorized by the Business Center’s Executive 

Director are performed by FRB-STL analysts under the supervision 

of FRB-STL analytics management.21 The analytics teams work with 

outreach staff to obtain clarification from customer agency officials 

and modify project requirements, as needed. FRB-STL’s Analytics 

Projects SOP provides levels of review of project deliverables by the 

 

21 Each DAS project goes through five phases in its lifecycle including project initiation, project planning, 

project execution, project delivery, and project closure.
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project team and FRB-STL analytics management to ensure the 

deliverables are accurate and meet customer needs. The SOP also 

provides for review by Fiscal Service regarding privacy and legal 

matters to ensure deliverables are appropriate for release to the 

customer agency, and do not violate privacy restrictions. The 

Business Center’s Executive Director authorizes the release of 

project deliverables to customer agencies.

FRB-STL and Fiscal Service, however, did not have a methodology 

for centrally tracking approvals of project deliverables through the 

later stages of each project’s lifecycle. This was in contrast to the 

governance process used to track proposed analytics projects and 

document approvals from Fiscal Service and FRB-STL analytics 

officials through the start of the project planning phase. FRB-STL’s 

Analytics Projects SOP requires that an independent review of each 

project deliverable be performed by a project team member to verify 

the general soundness of the deliverable.22 This review is recorded 

in the FRB-STL verification tracker application. However, FRB-STL 

does not centrally track the approvals of project deliverables by 

FRB-STL analytics management and Fiscal Service officials.

FRB-STL’s Director of Analytics told us that approvals for project 

deliverables at both the FRB-STL and Fiscal Service levels are 

documented in e-mail messages stored in electronic project folders

maintained by FRB-STL. In addition, operational procedures provide 

for self-audits on completed analytics projects by the FRB-STL risk 

management analyst. Self-audits, performed at a minimum of once 

per quarter, include all analytics projects completed since the prior 

self-audit. As part of the self-audits, the risk management analyst 

evaluates project compliance with all approvals outlined in FRB-STL 

SOP, and ensures that emails approving project deliverables, a 

lessons-learned document, and a copy of all project deliverables 

were documented in the project folders.

We believe both Fiscal Service and FRB-STL management would 

benefit from a centralized methodology for tracking required 

approvals of project deliverables similar to the governance tracker

 

22

 In April 2017, FRB-STL consolidated operational procedure documents for analytics requests, 

governance determination, and the analytics project lifecycle into an SOP document for analytics 

projects.
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used to track approvals prior to the initiation of DAS projects. The 

governance tracker allows Fiscal Service and FRB-STL analytics 

management to determine the status of proposed analytics projects

and identify approvals needed and obtained prior to the initiation of 

the planning phase for authorized projects. Centralized tracking of 

deliverable approvals would similarly help ensure all appropriate 

approvals at both FRB-STL and Fiscal Service levels are obtained 

prior to the release of any deliverables to customer agencies. 

GAO’s Standards for Internal Control in the Federal Government

state, “Management documents internal control to meet operational 

needs. Documentation of controls, including changes to controls, is 

evidence that controls are identified, capable of being 

communicated to those responsible for their performance, and 

capable of being monitored and evaluated by the entity.” The 

standards also state, “Documentation also provides a means to 

retain organizational knowledge and mitigate the risk of having that 

knowledge limited to a few personnel, as well as a means to 

communicate that knowledge as needed to external parties, such as 

external auditors.” FRB-STL’s Director of Analytics agreed that a 

centralized tracking methodology for deliverable approvals could 

help Fiscal Service and FRB-STL management ensure all required 

approvals are obtained. The director added that FRB-STL continues 

to work on improving the analytics project management processes

and that a centralized tracker for approvals of project deliverables 

would be considered.

After the completion of fieldwork and in response to our findings, 

FRB-STL developed a project administrative closure form to provide 

central tracking of approvals for DAS project deliverables. This form 

includes a checklist that tracks Fiscal Service approvals before the 

release of deliverables to customer agencies. In addition, FRB-STL’s 

Analytics Projects SOP requires that the administrative closure form 

be completed and saved on the FRB-STL Analytics SharePoint Site

as part of project closure. We are satisfied that Fiscal Service has 

completed actions to centrally track approvals of project 

deliverables; and therefore, we are not making any related 

recommendations.
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Improved Controls Over Lessons-Learned Reviews Are Needed 

FRB-STL implemented a lessons-learned review process for 

completed analytics projects during September 2015. The lessonslearned reviews are intended to identify areas that went well during 

the execution of each project, process improvements that can be 

made, and pitfalls to be avoided in future projects. The Director of 

Analytics stated that lessons-learned reviews, conducted by both 

FRB-STL analytics management and the project team, are to be 

performed during project closeout. FRB-STL’s SOP for self-audits on 

completed projects requires the FRB-STL risk management analyst 

to verify that a lessons-learned document (template) was included in 

each project folder, but do not call for any type of review to ensure 

the lessons-learned review was adequately completed and 

documented in the template. 

FRB-STL’s revised Analytics Projects SOP implemented in April 

2017, only states that lesson-learned reviews are completed by 

requiring that project staff ensure a lessons-learned document 

(template) is populated and saved in the administrative project 

folder. However, the revised SOP does not state what information 

should be captured in the lessons-learned template. Although the 

SOP does not outline how lessons-learned reviews are to be 

performed, the lessons-learned template includes a description of 

what information should be captured during the review. 

In February 2017, the Business Center and FRB-STL analytics team 

adopted what they refer to as an “agile” framework for analytics 

project management. The strategy document developed by the 

Business Center for this framework provides for bi-weekly 

retrospective meetings for on-going projects, along with an overall 

project retrospective meeting conducted at the conclusion of each 

project. The project retrospective findings are to be documented in 

project folders. The combined retrospective meetings reportedly 

comprise a lessons-learned process used for each project. However, 

our review determined that none of the language regarding 

retrospective meetings as part of a lessons-learned process were 

incorporated into FRB-STL’s revised SOP. 
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In our review of lessons-learned documents provided by FRB-STL for

16 completed DAS projects, we found spreadsheets summarizing 

the project objectives, the project team, and the lessons learned 

from the project. Each of these lessons-learned spreadsheets were 

stored in respective project folders on the FRB-STL Analytics 

SharePoint Site. Therefore, to identify lessons learned on completed 

projects that may have recurring issues, staff had to review 

documentation in all project folders for completed DAS projects. 

FRB-STL’s analytics management did not utilize a centralized 

summary of lessons-learned by issues categorized in DAS projects 

so that similar or recurring issues encountered under these projects 

could be easily identified by analytics staff.23 The lack of a 

centralized summary makes it increasingly more difficult for FRBSTL and Business Center management to identify similar or 

recurring issues encountered under projects, as well as the 

approaches taken to resolve the issues as more projects are 

completed by DAS. As part of the February 2017 agile project 

management framework adopted by the Business Center and FRBSTL, high-level lessons-learned identified in project retrospective 

meetings are also captured on project administrative closure forms. 

A GAO study on lessons-learned practices among several Federal 

agencies identified an eight step process that can be used to 

identify and apply lessons learned.24 The eight steps are identified in 

Figure 1. 

 

23 Issues are categorized in each lessons-learned spreadsheet regarding what could be improved for 

future projects. These include the need to: (1) establish agency contacts for additional data sources 

necessary to complete future projects; (2) further educate the outreach team, consisting of FRB-STL 

and the Business Center personnel, on the details of the project so they may better inform customer 

agencies when they provide them with the project results; and (3) ensure project results are 

consistently documented. 

24 GAO, Federal Real Property Security: Interagency Security Committee Should Implement a LessonsLearned Process (GAO-12-901; issued September 10, 2012) 
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Figure 1: GAO’s 8-Step Lessons-learned Process

Source: GAO

Steps 4 and 5 of GAO’s lessons-learned process address the 

storage and dissemination of the results of lessons-learned reviews.

In the study, GAO stated, “The storage of lessons usually involves 

entering lessons into an electronic database to disseminate and 

share information.” Additionally, GAO stated, “A critical step in any 

lessons-learned process is the sharing and disseminating of the 

knowledge gained. Agencies can disseminate lessons through many 

venues, such as briefings, bulletins, reports, emails, websites, 

database entries, the revision of work processes or procedures, and 

training.” 

Subsequently, in March 2018, we inquired whether Fiscal Service 

personnel had any new or updated SOPs for documenting a 

centralized summarization for lessons-learned reviews and there 

were none. We believe SOPs should be updated to require the 

results of the lessons-learned to be centrally summarized. Centrally 

summarizing the results of the lessons-learned would ensure that all 

lessons-learned are considered by analytics teams in conducting

future projects, and in turn, would enhance the effectiveness of the 

DAS provided to agencies. It should be noted that the FRB-STL 

Director of Analytics agreed that a centralized summarization 

document for lessons-learned reviews could be beneficial and would 

be considered.

As discussed above, after the completion of our fieldwork and in 

response to our findings, FRB-STL developed a project 

administrative closure form to provide central tracking of approvals 

for DAS project deliverables. The form was also developed to verify 

that lessons-learned reviews were performed. This form includes a 
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Business Center’s Data Analytics Services (OIG-20-025)

checklist that tracks the lessons-learned review for every completed 

DAS project. In addition, FRB-STL’s Analytics Projects SOP requires 

that the administrative closure form be completed and saved on the 

FRB-STL Analytics SharePoint Site as part of project closure. 

Furthermore, Fiscal Service responded that common issues from 

project level lessons-learned reviews are rolled up by category to 

the portfolio level and discussed by Fiscal Service leadership and 

analytics staff during a quarterly vision meeting. The portfolio level 

lessons-learned are centrally stored and tracked on the FRB-STL 

Analytics SharePoint Site. We are satisfied that Fiscal Service has 

completed actions to centrally track lessons-learned reviews, as well 

as to ensure that the results of all lessons-learned reviews are 

considered by analytics teams in conducting future projects. 

Therefore, we are not making any related recommendations. 

* * * * * *

We appreciate the cooperation and courtesies extended to our staff 

during the audit. If you wish to discuss the report, you may contact 

me at (617) 223-8638. Major contributors to this report are listed in 

appendix 4. A distribution list for this report is provided as appendix 

5.

/s/

Sharon Torosian

Director, Manufacturing and Revenue
Appendix 1 

Objectives, Scope, and Methodology 

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Business Center’s Data Analytics Services (OIG-20-025)

The objective of our audit was to assess how the Bureau of the 

Fiscal Service’s (Fiscal Service) Do Not Pay (DNP) Business 

Center’s data analytics services (DAS) support the Federal 

Government’s efforts to identify and prevent improper payments. 

We performed our fieldwork from March 2016 through November 

2016, with additional follow-up through October 2019.

To accomplish this objective, we interviewed individuals from 

Fiscal Service and the Federal Reserve Bank of St. Louis (FRB-STL)

to gain an understanding of the operation of the DNP Business 

Center and DAS. We also interviewed representatives from the 

following Federal agencies to obtain their views on DAS projects 

completed for their agencies:

 Department of the Treasury’s (Treasury) Administrative 

Resource Center;

 The Department of Veterans Affairs;

 The Department of Defense, Defense Finance and 

Accounting Service;

 The Department of Transportation;

 The Small Business Administration;

 The Department of Health and Human Services; and 

 The Department of Agriculture.

To assess the processes used to initiate, execute, and finalize DAS 

projects, we reviewed policies and procedures relating to the 

Business Center and FRB-STL operations. In addition, we reviewed 

documentation and materials related to Business Center outreach

services used to promote DAS, as well as metrics used to assess 

DAS performance. We also compared DAS performance metrics 

against the DNP program goals, Treasury’s strategic plan, and 

relevant laws applicable to improper payments. 

We obtained a list of DAS projects planned, in progress, 

completed, and terminated for the period April 2011 through March 

2016. We reviewed information for 18 DAS projects listed as 

completed by Fiscal Service as of March 21, 2016. To determine 

whether the projects were executed in accordance with Business 

Center and FRB-STL procedures, we reviewed documentation 

contained in project folders maintained by FRB-STL, as well as 
Appendix 1 

Objectives, Scope, and Methodology 

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information in the governance and project trackers. We reviewed

documentation of all 16 lessons-learned reviews performed on 

completed projects by FRB-STL since inception of this process in 

September 2015.25 We also reviewed spreadsheets for all 19 selfaudits performed on completed DAS projects through 

September 29, 2016.

26

We conducted this performance audit 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.

 

25 Projects completed prior to September 2015 were not subject to lessons-learned reviews.

26 The self-audit process was implemented by FRB-STL in November 2015. 
Appendix 2 

Significant Events In the Development of the Do Not Pay Business Center 

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Business Center’s Data Analytics Services (OIG-20-025)

November 2009: Executive Order 13520, Reducing Improper 

Payments and Eliminating Waste in Federal Programs: Focused on 

reducing improper payments by intensifying agencies’ efforts to 

eliminate payment error, waste, fraud, and abuse in the major 

programs administered by the Federal Government, while 

continuing to ensure that federal programs serve and provide 

access to their intended beneficiaries.

March 2010: Presidential Memorandum, Finding and Recapturing 

Improper Payments: Directed executive departments and agencies 

of the Federal Government to expand the use of payment recapture 

audits for detecting and recapturing payment errors. 

June 2010: Presidential Memorandum, Enhancing Payment 

Accuracy Through a ’Do Not Pay List’: Directed agencies to review 

current pre-payment and pre-award procedures and ensure that a 

thorough review of available databases with relevant information 

on eligibility occurred before the release of any federal funds, to 

the extent permitted by law.

July 2010: P.L. 111-204, Improper Payments Elimination and 

Recovery Act of 2010 (July 22, 2010): Expanded improper 

payment elimination and recovery efforts by performing and 

reporting on improper payment reviews and risk assessments.

April 2011: The Bureau of the Fiscal Service (Fiscal Service)

partnered with the St. Louis and Kansas City Federal Reserve 

Banks as Department of the Treasury’s (Treasury) Fiscal Agent, to 

develop the Do Not Pay (DNP) Business Center as part of the 

government-wide "Do Not Pay" Initiative. 

November 2011: The Business Center became operational and 

available to agencies to use for performing prepayment eligibility 

reviews against available DNP data sources.

April 2012: Office of Management and Budget (OMB) 

Memorandum M-12-11, Reducing Improper Payments through the 

‘Do Not Pay List’ (April 12, 2012): Directed executive agencies to 

take immediate steps to use the centralized solutions already in 

place for pre-payment eligibility reviews and for the Chief Financial 
Appendix 2

Significant Events In the Development of the Do Not Pay Business Center

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Business Center’s Data Analytics Services (OIG-20-025)

Officer of each agency to submit to OMB a plan for using 

centralized solutions.

January 2013: P.L. 112-248, Improper Payments Elimination and 

Recovery Improvement Act of 2012 (IPERIA) (January 10, 2013):

Reinforced the Administration’s ongoing efforts by requiring

executive agencies to perform prepayment eligibility reviews on all 

payments and awards through a DNP working system by June 1, 

2013. IPERIA also designated OMB to establish a DNP working 

system for agencies to perform prepayment eligibility reviews. 

August 2013: OMB Memorandum M-13-20, Protecting Privacy 

while Reducing Improper Payments with the Do Not Pay Initiative

(August 16, 2013): Set forth implementation guidelines for the 

DNP Initiative to help ensure that the Federal government’s efforts 

to reduce improper payments complied with privacy laws and 

policies and designated Treasury to host the DNP working system 

for agencies to perform prepayment eligibility reviews required by 

IPERIA. 

As Treasury’s payment-issuing agency, Fiscal Service was to 

ensure it had the legal authority to engage in a matching program 

for purposes of the DNP initiative, and for ensuring that matches 

were made against relevant and necessary data sources for the 

specific matching purpose to perform prepayment eligibility reviews 

as required by IPERIA.

May 2014: The Business Center initiated its first data analytics 

services project with a Federal agency. The project was designed 

to help officials at Treasury’s Administrative Resource Center 

determine if it was beneficial to match the resource center’s payee 

file against the private version of the General Services 

Administration’s System for Award Management Exclusion 

Records.

June 2015: The Business Center began dissemination of Agency 

Insight Reports to selected external agencies providing high level 

overviews of patterns and anomalies in agency payments.
Appendix 2

Significant Events In the Development of the Do Not Pay Business Center

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Business Center’s Data Analytics Services (OIG-20-025)

December 2015: P.L.114-109, The Federal Improper Payments 

Coordination Act of 2015 (December 18, 2015): Extended access 

to the DNP program to the legislative and judicial branches of the 

government as well as state governments, contractors, and agents 

for purposes of verifying payment or award eligibility. The 

legislation also required Treasury to submit a report to Congress on 

improper payments that included a description of the data analytics 

performed by the Business Center, the metrics used in determining 

whether the analytic and investigatory efforts have reduced, or 

contributed to the reduction of, improper payments or improper 

awards, and the target dates for implementing the data analytics 

operations.

June 2016: P.L. 114-186, Fraud Reduction and Data Analytics Act 

of 2015 (June 30, 2016): The purpose of the act is to improve 

Federal agency financial and administrative controls and procedures 

to assess and mitigate fraud risks, and to improve Federal 

agencies’ development and use of data analytics for the purpose of 

identifying, preventing, and responding to fraud, including improper 

payments.
Appendix 3 

Management Comments 

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Appendix 3

Management Comments

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Business Center’s Data Analytics Services (OIG-20-025)
Appendix 4 

Major Contributors to This Report 

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Business Center’s Data Analytics Services (OIG-20-025)

Kenneth Dion, Audit Manager

Kar Lee, Auditor-in-Charge

James Shepard, Auditor

Virginia Shirley, Referencer
Appendix 5 

Report Distribution 

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Business Center’s Data Analytics Services (OIG-20-025)

The Department of the Treasury

Secretary

Deputy Secretary

Fiscal Assistant Secretary

Deputy Assistant Secretary for Fiscal Operations and Policy

Office of Strategic Planning and Performance Improvement

Office of the Deputy Chief Financial Officer, Risk and Control 

Group

Bureau of the Fiscal Service

Commissioner

Office of Management and Budget

Office of Inspector General Budget Examiner

U.S. Senate

Chairman and Ranking Member

Committee on Homeland Security and Governmental Affairs

U.S. House of Representatives

Chairman and Ranking Member

Committee on Oversight and Reform
Treasury OIG Website

Access Treasury OIG reports and other information online: 

http://www.treasury.gov/about/organizational-structure/ig/Pages/default.aspx

Report Waste, Fraud, and Abuse

OIG Hotline for Treasury Programs and Operations – Call toll free: 1-800-359-3898

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Email: Hotline@oig.treas.gov

Submit a complaint using our online form: 

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