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                                                                                                   March  10, 2025

Using Data to Reduce Improper Payments: An Overview of the

Do Not Pay Initiative


Payment  integrity-ensuring that payments issued by
federal agencies are accurate and proper-is a central
concern in the stewardship of taxpayers' dollars. The Office
of Management  and Budget (OMB)  identifies data and
information access issues as being among the root causes of
improper payments. Improper payments are those that
should not have been made or were made in incorrect
amounts, including overpayments and underpayments,
under a statutory, contractual, administrative, or other
legally applicable requirement (31 U.S.C. §3351(4)). OMB
characterizes a root cause as something that would directly
lead to an improper payment, and if corrected, would
prevent the improper payment.

According to data available on paymentaccuracy.gov,
between FY2021  and FY2024,  agencies estimated that a
total of $765.8 billion in overpayments was caused by data
or information access issues (see Figure 1). OMB describes
three ways this might occur: (1) an agency fails to access
available data; (2) an agency is unable to access available
data (e.g., because statute restricts access in some way); or
(3) the needed data do not exist (e.g., there is no known
data source).

Figure  I. Overpayments  Due  to Data Access  Issues
Total for FY2021 -FY2024 Is $765.8 Billion
  FYTotal in Millions
                                           MFailue to ?acess
 $300,000                                   ava oab e data
 $250,000                                   Inability to access
                                            available data
 $260,000                                  * Needed data does not
                                            exist
 $150,00
 $160,000
 $50,000

          FY2021    FY2022   FY2023    FY2024
Source: CRS analysis of the 2024 improper payments ciataset on
paymentaccuracy.gov.
The Payment  Integrity Information Act of 2019 (PIJA, P.L.
116-117) establishes government-wide requirements that
are intended to reduce improper payments. Among its
provisions, PIJA codifies the Do Not Pay (DNP) Initiative
(31 U.S.C. §3354). Under this initiative, agencies have
access to certain databases, enabling them to verify whether
recipients are eligible to receive payments and prevent
improper payments in cases of ineligibility.

Type of Dat Needed
As part of their annual reporting for paymentaccuracy.gov,
agencies identify the types of data needed to determine


whether a payment would be proper. OMB's  guidance lists
several different types of data, such as data related to
address or location (e.g., place of residency or of a
property); the status of a contractor or provider (e.g.,
contractor standing and suspension determinations);
financial status (e.g., value of assets, credit history, tax
exemption status); or identity-proving (e.g., verifying that
people are whom they say they are). The data on
paymentaccuracy.gov  suggests contractor or provider
status-related data caused the largest share of overpayments
related to data access issues for FY2021-FY2024 ($232.1
billion).

The   Do   Not   Pay   Intative
In general, PIIA requires agencies to ensure that their
preaward and prepayment procedures provide for a
thorough review of available databases with relevant
information on eligibility prior to the release of any funds
(31 U.S.C. §3354(a)). Preaward and prepayment
procedures-which   may also be referred to as internal
controls within an agency-are generally considered
essential for avoiding the more reactive pay and chase
approach, where improper payments are disbursed and then
agencies attempt to recover or recoup those funds.

Using  Databases
The DNP  Initiative involves using databases to verify the
eligibility of a recipient to receive a payment. This includes
(1) certain databases enumerated specifically in statute, as
discussed below, and (2) other databases designated by the
OMB   director that substantially assist in preventing
improper payments (31 U.S.C. §3354(b)(1)). The OMB
director's designations are subject to a public notice and
comment  period (31 U.S.C. §3354(b)(2)(B)). OMB has
exercised its authority to expand the databases available to
agencies through the DNP Initiative, including access to
some databases maintained by federal agencies and to some
nonfederal databases as well.

The use of databases enables data matching, where data
concerning a potential payment recipient can be matched
and compared  with data from different data systems. Prior
to issuing any award or payment, each executive agency is
instructed to at a minimum review (1) the incarceration
records maintained under 42 U.S.C. §402(x)(3) and
§1382(e)(1)(I) and the death records maintained by the
Commissioner  of Social Security; (2) the General Services
Administration's System for Award Management  exclusion
records; (3) the Department of the Treasury's Debt Check
Database (associated with the Treasury Offset Program);
(4) the Department of Housing and Urban Development's
Credit Alert System (also referred to as the Credit Alert

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