About Do Not Pay
Our mission is to assist agencies to make informed decisions in the identification, mitigation, and elimination of improper payments.
Do Not Pay will provide innovative customer and data driven solutions that reduce the improper payment footprint across federally funded and state administered programs.
Individual privacy will be protected.
Data security will be incorporated into every aspect of our technology platform.
Minimal effort will be required by our customers to incorporate Do Not Pay into existing processes.
Relevant and useful data will be efficiently and effectively provided to our customers.
The History of Do Not Pay
Milestones in the Do Not Pay initiative span from 2022 to 2009
OMB Circular A-136
The Office of Management and Budget (OMB), with input from the financial management community, has updated OMB Circular A-136, Financial Reporting Requirements. This update clarifies and streamlines reporting requirements and reflects current federal generally accepted accounting principles. This revision of Circular A-136 is effective on issuance, unless otherwise specified in this Circular. Questions about this Circular A-136 should be directed to the Office of Federal Financial Management’s Financial Integrity and Risk Management Branch at (202) 395-3993.
OMB Memorandum M-21-19
Transmittal of Appendix C to OMB Circular A-123, Requirements for Payment Integrity Improvement. Appendix C to OMB Circular A-123 (which was last updated in June 2018 as OMB Memorandum M-18-20) is hereby modified. Unless otherwise noted in the guidance, the requirements found in Appendix C are effective starting in Fiscal Year 2021
Payment Integrity Information Act of 2019 (PIIA)
To improve efforts to identify and reduce Governmentwide improper payments, and for other purposes.
OMB Memorandum M-18-20: Appendix C to OMB Circular A-123, Requirements for Payment Integrity Improvement (Modified by M-21-19)
The requirements found in this guidance are effective for fiscal year (FY) 2018 and beyond. This guidance implements the requirements from the following laws:
- Improper Payments Information Act of 2002 (IPIA);
- Improper Payments Elimination and Recovery Act of 2010 (IPERA); and
- Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERIA)
Issuance of this guidance modifies Appendix C to OMB Circular A-123 (2014) and replaces OMB Memorandum M-12-11, Reducing Improper Payments through the "Do Not Pay List," OMB Memorandum M-13-20, Protecting Privacy while Reducing Improper Payments with the Do Not Pay Initiative, and OMB Memorandum M-15-02, Appendix C to Circular No. A-123, Requirements for Effective Estimation and Remediation of Improper Payments.M-18-20
Federal Improper Payments Coordination Act of 2015 (FIPCA)
This bill provides access to and use of information by Federal agencies in order to reduce improper payments, and for other purposes.Read the full text: FIPCA
OMB Memorandum M-15-02: Appendix C to Circular No. A-123, Requirements for Effective Estimation and Remediation of Improper Payments (Replaced by M-18-20)
The goal of this overhauled version of Appendix C to Circular No. A-123 is to transform the improper payment compliance framework to create a more unified, comprehensive, and less burdensome set of requirements.M-15-02
Memorandum for Heads of Executive Departments and Agencies: Protecting Privacy while Reducing Improper Payments with the "Do Not Pay Initiative" (M-13-20) (Replaced by M-18-20)
This memorandum sets forth implementation guidance for the DNP Initiative to help ensure that the Federal Government's efforts to reduce improper payments comply with privacy laws and policies. It builds on previous OMB guidance.
Although this memorandum creates new policy requirements, it does not extend the legal requirements of the Privacy Act to information or activities that would not otherwise be covered under the statute.
The DNP-specific standards and procedures do not apply to other efforts to combat improper payments or matching programs that are not part of the DNP Initiative.M-13-20
Database Integration Plan for the Do Not Pay Initiative
OMB pursued a phased approach in implementing the databases that agencies will use to check, as appropriate, all awards and payments.
The first phase focuses on two publicly available databases, Social Security Administration's Death Master File (DMF) and General Services Administration's (GSA) System for Award Management (SAM)/Excluded Parties List System (EPLS).
IPERIA allows the expansion of databases. The Fiscal Year 2014 President's Budget included key proposals to strengthen Do Not Pay by expanding access to multiple statutorily restricted databases.
Improper Payment Elimination and Recovery Improvement Act of 2012 (IPERIA), Public Law 112-248 (Repealed by Payment Integrity Act of 2019 (PIIA))
Reinforced the Administration’s ongoing efforts, IPERIA requires Federal executive agencies to review, as appropriate and before issuance, all payments and awards for all programs through a Do Not Pay Working System by June 1, 2013.
IPERIA requires the Office of Management and Budget (OMB) to develop a Database Integration Plan for the Do Not Pay Initiative focusing on the following elements:
- Providing agency access to the Do Not Pay Initiative
- Improving date use agreements to facilitate data access for the purposes of program integrity; and
- Including other databases in the Do Not Pay Initiative
Memorandum For Heads of Executive Departments and Agencies – Reducing Improper Payments Through the "Do Not Pay List" (M-12-11) (Replaced by M-18-20)
Directed Executive Agencies to take immediate steps to use the centralized solutions that are already in place for pre-payment eligibility review.
The memorandum requires the Chief Financial Officer of each agency (or the accountable official for improper payments and program integrity, under Executive Order 13520) to submit to OMB a plan for using centralized solutions.M-12-11
Development of the Do Not Pay Business Center
The Treasury’s Bureau of the Fiscal Service partnered with the Saint Louis and Kansas City Federal Reserve Banks as Treasury’s Fiscal Agent, to develop the Do Not Pay Business Center as part of the "Do Not Pay" solution. Do Not Pay became available in November 2011.
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 occurs before the release of any Federal funds, to the extent permitted by law.
At a minimum, agencies shall, before payment and award, check the following existing databases to verify eligibility:
- Credit Alert Verification Reporting System
- Death Master File
- Debt Check Database
- List of Excluded Individuals/Entities
- System for Award Management/ Excluded Parties List System
Executive Order - Reducing Improper Payments and Eliminating Waste in Federal Programs
The purpose of this order was to reduce improper payments by intensifying 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.Executive Order 13520