Do Not Pay Business Center

Jenny RoneDirector, Outreach & Business Processes

January 2015

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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

A New Day for Do Not Pay

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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

Brookings Institute

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A multi-functional analytics tool

and one-stop data shop

built to help federal agencies

detect and prevent improper payments

Do Not Pay (DNP) is…

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• Help prevent, reduce, and stop improper payments while protecting citizens’ privacy

DNP’s Mission is to…

• 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

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

Why? –• Documentation and Administrative Errors• Authentication and Medical Necessity Errors• Verification Errors

What? –Payments made to the wrong entity, in the wrong amount, or for the wrong reason

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Improper Payments Legislation & DNP

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The Problem (part of) The Solution

DNP – A Tool in an Agency’s Toolbox

$106 billion in improper

payments issued in FY 2013

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DNP Built on a Strong Foundation

People Governance

Technology Data

DNP Program

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It’s a Partnership - DNP

• 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

Role and Responsibility

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It’s a Partnership – Federal Agency

• 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.

Federal Agency

Role and Responsibility

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Breaking it Down -

One-stop Data Shop

One Source – Many DatasetsMany Sources - Many Datasets

VS.

Death – SSAExcluded Parties – GSA, HHSCredit – SBA, VA, DOJ, HUD, USDA, EdDebt – TreasuryForeign Asset Control - TreasuryIncarceration – SSA

Do Not Pay Verification Records System of Records Notice – 01/14

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Batch Matching

Single On Line Search

Breaking it DownMulti-functional Analytics Tool

Continuous Monitoring

Advanced Analytics

One tool supporting an agency’s business processes and financial management controls

Payment Integration

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DNP throughout the Payment Lifecycle

Pre-award• Verify

award eligibility

Pre-payment• 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

On-line single searchBatch MatchingContinuous Monitoring

Advanced Analytics Payment IntegrationAgency Adjudication

On-line single searchBatch MatchingContinuous Monitoring

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At Time of Payment

4. Payment Integration 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 Records-Restricted includes exact name, DUNS, TIN, full address and information about debarment

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Agency Adjudication Process

DNP identifies conclusive,

probable and possible matches

Agency notified of matches

and logs onto portal

Prioritize critical matches

Research internal business rules

that apply to matches

Investigate further,

confirm matches &

document decision

Determine and identify

“proper” or “improper”

1

2

3

45

DNP suggests the following steps to successful adjudication

Apply applicable rules

6

7

8Ensure alignment with

existing process and

mission

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OMB Circular No. A-136

X. Agency reduction of improper payments with the Do Not Pay Initiative.

Financial Reporting Requirements

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Pre-Award / Pre-Payment

4. Payment Integration Helping agencies verify eligibility through the DNP Portal

Continuous Monitoring

Batch Matching

Single On Line Search

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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• 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]

Currently Available through the Portal

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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 non-Federal 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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• 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)

CMAs are NOT Required for…

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• 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

CMA Triggers

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DNP and CMAs

Office of Management and BudgetOMB M-13-20, Protecting Privacy while Reducing Improper Payments with the Do Not Pay Initiative

Two Important Documents

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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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 Analysis

Agencies' cost-benefit analyses for a DNP matching program need not contain a specific estimate of any savings.

CMA Process – OMB M-13-20

• Highlights of OMB M-13-20, Protecting Privacy while Reducing Improper Payments with the Do Not Pay Initiative:

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Typical CMA Process without DNP SORN

GSA

CMA

HHS

CMA

Treas

CMA

LEIE

SAM

TOP

Federal Agency

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CMA Process with DNP SORN

LEIE

SAM

TOPDNP –

Treasury’s

Working

System

(SORN #.023)

Federal Agency

DNP

CMA MOU

MOU

MOU

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“…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…”

M-13-20 & Data Analytics

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Moving on – Advanced Analytics

Creating and executing predictive models

Identifying specific and generalized scenarios

Analyzing matching trends within and across agencies

Matching agency payment data against data sources using program-specific business rules

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Payment Data(validated; disbursed;

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Adjudication Advanced Analytics

Risk Analysis

Identify

Assess

Treat

Mo

nit

or

Assembling Data into Information and

Information into Insight

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Helping to strengthen Government-wide Financial Management Controls on Payments

Business Process Mapping

• 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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GREAT!!!!

With DNP you have….

But I Have a Pre-award/Payment Process

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Identifying payments to be stopped or recovered

Preventing future improper payments

Agencies Are Having Success

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Contact Information

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

visit us at: www.donotpay.treas.gov

1-855-837-4391

donotpay@stls.frb.org

DNP Executive Director: Kevin.Jones@fiscal.treasury.gov 202-504-3516DNP Director of Outreach & Bus. Processes: Virginia.Rone@fiscal.treasury.gov 202-874-6185