Do Not Pay Business Center
Jenny Rone
Director, Outreach & Business Processes
January 2015
A New Day for Do Not Pay
2014 Transformation
• Two major releases within the last few months
• A new architecture provides:
 An improved user interface
 Increased efficiency
• More substantive data sets continue to be
incorporated - significantly increasing the ability to
identify potential improper payments
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Brookings Institute
Top 10 Tech Innovations
That Will Transform Society and Governance
“New technologies can have revolutionary impacts with
widespread and unexpected benefits. Technology can also
serve as a tool to enable governments to better
serve their citizens.”
#8 – Do Not Pay Portal
12/22/14
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Do Not Pay (DNP) is…
A multi-functional analytics tool
and one-stop data shop
built to help federal agencies
detect and prevent improper
payments
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DNP’s Mission is to…
• Help prevent, reduce, and stop improper payments
while protecting citizens’ privacy
• Partner with agencies to identify potential
fraud, waste, and abuse in federally
funded programs while protecting citizens’
privacy
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Improper Payments – the basics
$106 billion in
improper
payments issued
in FY 2013
The Problem
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All improper payments degrade
the integrity of government
programs
Reducing improper payments is
a top priority
Not all improper payments
represent a loss to the
government and not all
improper payments are
fraudulent
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Improper Payments – what, how, and why
What? –
Payments made to the wrong entity, in the wrong
amount, or for the wrong reason
Why? –
• Documentation and Administrative Errors
• Authentication and Medical Necessity Errors
• Verification Errors
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Improper Payments Legislation & DNP
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DNP – A Tool in an Agency’s Toolbox
$106 billion in
improper
payments issued
in FY 2013
The Problem
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(part of) The
Solution
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DNP Built on a Strong Foundation
People
Governance
DNP
Program
Technology
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Data
It’s a Partnership - DNP
Role and Responsibility
• Provide a centralized system that agencies can use to
determine whether a payment is proper or improper – one
which is committed to providing:
• more and better quality data
• continuous system development
• service enhancements
• DNP does not:
• inform an agency whether a payment is proper or improper
• stop payments UNLESS they are approved/established in
conjunction with agency
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It’s a Partnership – Federal Agency
Federal
Agency
Role and Responsibility
• Adjudication - the process by which agencies review the
results of matches received from DNP and determine
whether a payment is proper or improper.
• Determination of “proper vs. improper” are made consistent
with existing laws, regulations, and guidance related to
those particular payments.
• Agencies can work with DNP to establish business and
stop payment rules.
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Breaking it Down One-stop Data Shop
VS.
Many Sources - Many Datasets
One Source – Many Datasets
Death – SSA
Excluded Parties – GSA, HHS
Credit – SBA, VA, DOJ, HUD, USDA, Ed
Debt – Treasury
Foreign Asset Control - Treasury
Incarceration – SSA
Do Not Pay Verification Records
System of Records Notice – 01/14
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Breaking it Down
Multi-functional Analytics Tool
One tool supporting an agency’s business processes and
financial management controls
Payment Integration
Continuous
Monitoring
Batch Matching
Single On Line
Search
Advanced Analytics
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DNP throughout the Payment Lifecycle
On-line single search
Batch Matching
Continuous Monitoring
Pre-award
Pre-payment
• Verify
award
eligibility
• Re-verify or
monitor eligibility
for payments
• Research matches
Post-payment
• Analyze data and
trends
• Conduct
reporting
• Implement
corrective action
At Time of
Payment
• Review matches
from payment
integration
Payment Integration
Agency Adjudication
Advanced Analytics
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On-line single search
Batch Matching
Continuous Monitoring
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At Time of Payment
Payment
Integration
4. Payment
Integration
Helping agencies seamlessly comply with IPERIA
DNP, at time of payment, performs matches against the:
Death Master File (DMF)-Public
includes Social Security Number, Name, Date of Death, Date
of Birth, Verified or Proof Indicator
System for Award Management (SAM)-Exclusion RecordsRestricted
includes exact name, DUNS, TIN, full address and
information about debarment
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Agency Adjudication Process
Determine and identify
“proper” or “improper”
Ensure alignment with
existing process and
mission
DNP identifies conclusive,
probable and possible matches
8
2
7
Investigate further,
confirm matches &
document decision
DNP suggests the
following steps to
successful adjudication
3
6
Prioritize critical matches
5
Apply applicable rules
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Agency notified of matches
and logs onto portal
1
4
Research internal business rules
that apply to matches
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OMB Circular No. A-136
Financial Reporting Requirements
X. Agency reduction of improper payments with the Do Not Pay Initiative.
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Pre-Award / Pre-Payment
Helping agencies verify eligibility through the DNP Portal
4. Payment Integration
Single On Line
Search
Batch Matching
Continuous
Monitoring
One-off search to verify eligibility up front
or further research a match identified
during payment integration
Verify eligibility up front for a group
(e.g., potential grant recipients)
Monitor eligibility for a group that receives
recurring payments
(e.g., approved vendor list)
Agencies Adjudicate Matches from these activities too…..
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Currently Available through the Portal
• Death Master File (DMF) Public [SSA]
• List of Excluded Individuals & Entities (LEIE) Public
[HHS]
• Office of Foreign Assets Control (OFAC) Public [Treasury]
• System for Award Management (SAM) Exclusion Records
Public & Restricted [GSA]
• SAM Entity Registration Records Restricted [GSA]
• Treasury’s Offset Program (TOP) Debt Check Restricted
[Treasury]
• Credit Alert System or Credit Alert Interactive Voice
Response System (CAIVRS) Restricted [SBA]
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Availability Pending through the Portal
• CAIVRS Restricted [VA, DOJ, Education, HUD, USDA]
• List of Excluded Individuals & Entities (LEIE) Restricted
[HHS]
• Prisoner Update Processing System (PUPS) Restricted
[SSA]
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Public vs. Restricted – Let’s Talk CMA
Computer Matching Agreements must be
established for….
any computerized comparison of two or more automated
systems of records or a system of records with nonFederal records for the purpose of establishing or
verifying the eligibility of, or continuing compliance with,
statutory and regulatory requirements by, applicants for,
recipients or beneficiaries of, participants in, or providers
of services with respect to cash or in-kind assistance or
payments under federal benefit programs
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CMAs are NOT Required for…
• Single On Line searches
• Statistical matches
• Matching program between public data sources or
those not aligned to a system of records
• Matching programs that do not involve verifying
eligibility in a Federal benefit program
– Example: When the purpose of the match is to make
procurement decisions
• Payment Integration (Treasury handles this for you in the
payment stream)
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CMA Triggers
• Matching against data sources with personally
identifiable information (PII) on U.S. citizens;
deceased are not covered by Privacy Act
• Typically, only Federal benefit programs providing
cash or in-kind assistance to individuals are covered
• Presently, only batch and continuous monitoring
users will need CMAs to match against restricted
sources within Treasury’s Working System
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DNP and CMAs
Two Important Documents
Office of Management and Budget
OMB M-13-20, Protecting Privacy while Reducing
Improper Payments with the Do Not Pay Initiative
Do Not Pay Verification Records System of Records
Notice (SORN #.023) JAN 2014
Enables DNP to derive data and retain records,
and enter into CMAs
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CMA Process – OMB M-13-20
• Highlights of OMB M-13-20, Protecting Privacy
while Reducing Improper Payments with the Do Not
Pay Initiative:
Topic
Excerpt
CMA
Lifespan
Matching programs have a termination date of less than three years.
Agencies may renew these CMAs for a maximum of three years.
Review
Period
Data Integrity Boards (DIBs) have a 60-day deadline for review of a
CMA. If circumstances do not permit the DIB to approve or
disapprove the DNP matching program within 60 days, the DIB shall
provide a brief memorandum to the head of the agency (or to the
Inspector General in cases where the Inspector General proposed
the matching program) describing the necessity for the delay.
Cost Benefit Agencies' cost-benefit analyses for a DNP matching program need
Analysis
not contain a specific estimate of any savings.
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Typical CMA Process without DNP SORN
CMA
GSA
CMA
Treas
Federal
Agency
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CMA
HHS
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CMA Process with DNP SORN
CMA
DNP
Federal
Agency
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M-13-20 & Data Analytics
“…Treasury's Working System includes Treasury's system of
records for Do Not Pay, as well as other activities such as
investigation activities for fraud and systemic improper
payments detection through analytic technologies and other
techniques…”
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3
2
1
4
Level
Level
Payment Data
(validated; disbursed;
post-payment)
Data source shared with
Payment Management
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Data
Sources
Demographic
Data
Financial
Data
Matching agency payment data against data sources
using program-specific business rules
Agency
Data
Analyzing matching trends within and across
agencies
Eligibility
Data
Identifying specific and generalized scenarios
Level
Creating and executing predictive models
Level
Moving on – Advanced Analytics
Adjudication
Advanced Analytics
Assembling Data into
Information and
Information into Insight
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Risk
Analysis
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Business Process Mapping
Helping to strengthen Government-wide Financial
Management Controls on Payments
• In-depth examination of the entire payment
disbursement system
• Components examined include program’s
objectives, target beneficiaries, eligibility
requirements, awarding criteria, and
verification processes
• Resulting in development of:
• improved improper payment detection methods
• business rules and/or stop payment rules
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But I Have a Pre-award/Payment Process
GREAT!!!!
With DNP you have….
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Agencies Are Having Success
Identifying payments to be stopped or recovered
Preventing future improper payments
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Contact Information
visit us at: www.donotpay.treas.gov
Want to Learn More?
Sign up for our mailing list to receive updates on
new functionality and data sources or to
schedule a demo.
http://www.donotpay.treas.gov/MailingList.htm
1-855-837-4391
donotpay@stls.frb.org
DNP Executive Director:
Kevin.Jones@fiscal.treasury.gov
DNP Director of Outreach & Bus. Processes: Virginia.Rone@fiscal.treasury.gov
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202-504-3516
202-874-6185