Treasury’s Working System
- Credit Alert System or Credit Alert Interactive Voice Response System (CAIVRS), Restricted [SBA]
- Death Master File (DMF), Public [SSA]
- List of Excluded Individuals & Entities (LEIE), Public [HHS]
- System for Award Management (SAM) Exclusion Records (referred to in IPERIA as Excluded Party List System), Public & Restricted [GSA]
- Treasury Offset Program (TOP) Debt Check, Restricted [Treasury]
MOU Effective (awaiting data availability in portal)
- Credit Alert System or Credit Alert Interactive Voice Response System (CAIVRS), Restricted [VA]
- List of Excluded Individuals & Entities (LEIE), Restricted [HHS]
- CAIVRS, Restricted – Databases include: DOJ, Education, HUD & USDA
- Prisoner Update Processing System (PUPS), Restricted [SSA]
|Database||Function||Public Contents||Restricted Content*||Other Considerations & MOU status|
|Credit Alert System or Credit Alert Interactive Voice Response System (CAIVRS) System inputs from DOJ, Education, VA, SBA, HUD & USDA||Verify whether an individual is a delinquent Federal borrower.||None.||Borrower Taxpayer Identification Number (TIN) and information on which agency is owed.||It has high avoidance potential, with HUD reporting $26.3 billion in claims avoided and $9.5 billion in losses avoided for FY2010. [MOU effective for SBA and VA. MOUs pending with DOJ, Education, HUD and USDA.]|
|Dept. of Health and Human Services’ (HHS) List of Excluded Individuals & Entities (LEIE)||Verify whether payments are to entities excluded from participating in Federal health care programs.||Name, specialty, date of birth, address, and exclusion type.||TIN.||LEIE Public can only match on Name. Adding TIN to the matching algorithm would greatly cut down on false positives and effort adjudicating. [MOU effective.]|
|General Services Administration’s (GSA) System for Award Management (SAM) Exclusion Records||Verify whether payments are to debarred individuals.||Name, DUNS (a unique identification number, for each physical location of a business) and information about debarment.||TIN and full address.||SAM Exclusion Records Public can only match on Name, which leads to overwhelming false positives. In the month of June 2013, matching with EPLS Restricted in place of EPLS Public reduced the number of matches by 99.9% - from 360,841 matches to 356. [MOU effective.]|
|Social Security Administration’s (SSA) Death Master File (DMF)||Verify whether a payee is deceased.||SSN, Name, Date of Death, Date of Birth, verified or proof indicator.||Additional 10+ million records from States.||Currently, DNP does not have access to DMF Restricted (a.k.a., full DMF). DMF Public matches do not require a Computer Matching Agreement (CMA), because the deceased are not Privacy Act protected. [Subscription in place with DNP.]|
|SSA’s Prisoner Update Processing System (PUPS)||Verify whether an individual is incarcerated.||None.||SSN, Name, DOB, dates of confinement, and facility contact information.||PUPS covers 95% of all correctional facilities, including the Federal Bureau of Prisons, all State prison systems, and most county and local jails. [MOU pending.]|
|Treasury Offset Program (TOP) Debt Check||Verify whether payee owes delinquent non-tax debts to Federal Government (and participating States).||None.||Name, TIN, date of delinquency, debtor status.||Helps determine whether payments should be offset and if the Debt Collection Improvement Act applies, which bars delinquent debtors from federal loans or loan guaranty - with very specific exemptions. [MOU effective.]|
* A Computer Matching Agreement (CMA) must be in place to match against Restricted sources using DNP’s batch or continuous monitoring capabilities.
- Office of Foreign Assets Control (OFAC), Public [Treasury]
- SAM Entity Registry Records (formerly known as Central Contractor Registration/CCR), Restricted [GSA]
Treasury’s Working System vs. DNP Project
- Why is DNP differentiating between a system and a project? Isn’t it all just part of the DNP portal?
Yes, they are both part of the portal. Different requirements apply to each and the origin of the two terms is found in OMB M 03-22, which references information technology (IT) systems and projects that collect, maintain or disseminate personally identifiable information (PII).
- What must meet the requirements outlined in OMB M-13-20, which go above and beyond traditional privacy requirements? Is that the threshold for inclusion in Treasury’s Working System?
Yes, only those databases that comprise Treasury's Working System must meet the OMB M-13-20 requirements. They include the five databases listed in IPERIA (DMF, SAM Exclusion Records/EPLS, LEIE, TOP Debt Check and CAIVRS) and PUPS (via the Bipartisan Budget Act).
- Then what does the DNP Project include?
Any other DNP activities that align to non-IPERIA authorities fall into the DNP Project category and must meet traditional privacy requirements (Privacy Act, etc.). Examples include:
- agencies matching against OFAC and SAM Entity Registry Records. Since these data sets have not been designated by OMB, they are not part of Treasury's Working System. Non-IPERIA authorities must be cited to match against them.
- any other Legal approved activities that DNP may continue to provide in accordance with its pre-IPERIA role as a service provider (e.g., supporting non-Executive agencies)