Enhancing Payment Accuracy Through a "Do Not Pay List"

This memorandum directs federal agencies to check existing eligibility databases before making payments or awards to prevent improper payments to ineligible recipients. It establishes a 'Do Not Pay List' combining multiple databases and sets deadlines for OMB to develop integration plans and guidance.

Federal Register Open PDF 75 FR 35953

Impact dates

Dec 15, 2010
OMB Director issues guidance on actions agencies must take
Oct 16, 2010
OMB Director provides President plan for completing database integration
Sep 16, 2010
Agencies submit plans on current pre-payment/pre-award procedures to OMB

Key directives

Agencies must review pre-payment and pre-award procedures
Agencies must check specified databases before payment/award
OMB Director must provide integration plan within 120 days
Agencies must submit plans to OMB within 90 days
OMB Director must issue guidance within 180 days

Who is ordered

Timeline

Immediate

Agencies must begin reviewing pre-payment and pre-award procedures
Agencies must check specified databases before releasing funds

Near term (90d)

OMB Director must submit integration plan to President by October 16, 2010
Agencies must submit pre-payment procedure plans to OMB by September 16, 2010

Long term

OMB must issue guidance on agency actions within 180 days
Potential single entry point for all databases after integration

Risks & tensions

Database integration complexity may delay single entry point
Legal exceptions may limit effectiveness of payment stops
Agency compliance burden for new verification requirements
Privacy concerns with centralized eligibility data