Strengthening Payment Integrity: Enhancing Do Not Pay with High-Quality Data

The U.S. Government has long wrestled with the challenge of improper payments – those that should not have been made, should have been made but were not, or were made in incorrect amounts. In its assessment of FY 2023, the Government Accountability Office (GAO) estimates the federal government made roughly $236 billion in improper payments– with Federal agencies reporting that 79 percent of FY 2023 improper payments were due to a failure to access the necessary data. The Department of the Treasury’s Do Not Pay (DNP) system has become a critical tool in enhancing payment integrity and ensuring accurate disbursements of federal funds, bringing together a variety of federal data sources to reduce improper payments. 

Over the past decade, significant strides have been made in bolstering DNP, both through legislation and enhanced capacity and capabilities. However, the system's efficacy hinges on the quality and timeliness of its data. Investing in the underlying data and infrastructure is the key to increased success and harnessing the full potential of DNP. 

Evolution of Do Not Pay

DNP’s primary goal is to ensure payment integrity by detecting and preventing improper payments. Since its inception in 2010, following Executive Order 13520, “Reducing Improper Payments,” DNP transformed significantly. What began as a list of databases grew into a comprehensive business center, offering data analytics capabilities and a web-based portal. The system allows federal benefit-paying agencies and state agencies administering federal programs to access data from a variety of sources in order to verify the eligibility of beneficiaries, grantees, vendors, or loan recipients to receive federal payments. 

The latest in a series of formalization efforts by Congress, the Payment Integrity Information Act of 2019 (PIIA) requires Executive Branch agencies to review outgoing payments and awards through the DNP system. DNP currently includes 14 databases, six of which are designated by statute, with plans to add additional data sources over time. Examples of available information include data on individuals previously convicted of fraud or otherwise barred from receiving federal payments and data on deceased individuals. 

Death data, in particular, plays an important role in preventing improper payments by helping agencies avoid disbursing funds to deceased recipients. DNP currently has access to five different data sources of death data. One of the most comprehensive sources of death data is SSA’s full Death Master File (DMF) which contains deaths reported to SSA directly as well as state death records. The Consolidated Appropriations Act, 2021 granted DNP temporary access to the SSA's full DMF starting in December 2023 through December 2026. 

A Path Forward for DNP

In several proposed bills designed to address improper payments, Congress demonstrates continued support for DNP, including by expanding access to available data sources. DNP addresses the need for a central access point to streamline eligibility verification and payment processes– and while expanding access to additional databases is an important step in strengthening the system, investing in the quality of the underlying data is equally crucial. Improving the quality of death data – and vital records data more broadly – presents an opportunity to address the underlying data issues seen in the DNP system today. 

The Importance of Data Quality 

Data quality directly impacts DNP’s effectiveness in identifying and reducing improper payments. Discrepancies among the various data sources can lead to conflicts, impacting the reliability of this information and its usefulness for decision-making regarding the disbursements of funds. An area where data quality is particularly crucial is in the management of vital records – birth, marriage, and death data. These records serve as official documentation of identity and relationships, and are essential for verification of benefits eligibility. However, issues with data quality and timeliness hinder the optimal use of these data assets. 

Data Quality and Integration Challenges

As outlined in a 2024 Data Foundation report “Reimagining Vital Records: A Digital, Interoperable & Timely Public Health Data Infrastructure,” the integration of death data from various state and federal sources presents substantial challenges. Variability in data standards across states can lead to inconsistencies, as different jurisdictions may have varying standards for recording and transmitting death data. These inconsistencies complicate data-sharing, integration, and automation processes. Additionally, there is often a significant lag in data reporting due to underinvestment in data infrastructure and limited capacity in state and local data providers, which can delay the availability of critical information needed to determine eligibility or stop payments. Further, inaccuracies in data entries, such as misspellings in names, incorrect Social Security numbers, or wrong dates, can complicate matching and verification processes and lead to errors in reporting.

Investing in Data Quality: The Key to Maximizing DNP’s Potential

Challenges related to the quality of death data can be addressed by streamlining how vital records data are recorded and shared across states and Federal agencies. Creating an ecosystem that supports real-time or near-real-time sharing of vital records data can minimize delays that currently hamper timely updates. This is why the Data Foundation recommends creating a national, secure, and interoperable vital records service.  

Improving data quality would not only significantly boost the effectiveness of DNP’s services, ensuring the most up-to-date information is available to make eligibility decisions, it would also unlock the potential for agencies to deploy modern-day technologies to streamline eligibility verification processes and further reduce improper payments. With a substantial amount of improper payments due to a failure to access necessary information, providing data in an accessible and user-friendly manner could significantly enhance payment integrity. By investing in data quality, agencies could automate processes and incorporate DNP functionalities directly into their internal systems, reducing manual entry and verification errors.

A robust data ecosystem is essential for enhancing DNP's accuracy and supporting payment integrity, and the Data Foundation supports DNP’s efforts to streamline access to vital data for program administration and decision-making regarding federal payments. As Congress continues their efforts to address improper payments, investing in high-quality, timely data should be a priority.