Can’t Someone Get Some Privacy Around Here?

August 19, 2013 | By Jerry Ashworth | Post a Comment

key-lock-4-147894-mWith all the hoo-hah over Edward Snowden and the National Security Administration, concerns about privacy are moving up on people’s priority lists. Not that this is directly related, but the Office of Management and Budget last week issued a memorandum to federal agencies on protecting privacy while federal agencies reduce improper payments through the Do Not Pay Initiative.

Here’s some background on the Do Not Pay Initiative if you haven’t followed it. The White House in January signed the Improper Payments Elimination and Recovery Improvement Act of 2012 (H.R. 4053), which requires the Office of Management and Budget to:

  • identify, annually, a list of high-priority federal programs for greater levels of oversight and review in which the highest dollar value or highest rate of improper payments occur or for which there is a higher risk of improper payments;
  • coordinate with agencies responsible for administering high-priority programs to establish annual targets and semi-annual or quarterly actions for reducing improper payments; and
  • provide guidance to agencies for improving estimates of improper payments.

The law also requires federal agencies to report annually to their Inspectors General on any high-dollar improper payments identified and requires OMB to make such reports available to the public on a central website.

The law requires federal agencies to review prepayment and preaward procedures and available databases to determine program or award eligibility and prevent improper payments before releasing any federal funds. The law also established the Do Not Pay Initiative, which allows agencies to use these databases to prevent improper payments. OMB is directed to report annually on the progress of the initiative in reducing improper payments or awards, as well as address the identification of incorrect database information.

Under the Do Not Pay Initiative, OMB was required to establish a system for prepayment and preaward review. By June 1, each federal agency was required to review all of its payments and program awards using the system.

OMB’s Mike Wetklow told attendees at last week’s National Governmental Accounting and Auditing Update Conference in Washington, D.C., that the law “forced us to take a controlled approach” with the Department of the Treasury, adding that Treasury is processing all federal payments centrally through Do Not Pay databases. It has already processed 89 million payments, or $150 billion, through Do Not Pay databases. “Treasury is continuing to work on system enhancements to stop a payment before it’s made,” he added.

However, OMB stressed in the memorandum it issued last week that “as the federal government takes these important steps to prevent waste, fraud and abuse in federal spending, it is vital for agencies to ensure that individual privacy is fully protected.” Therefore, the memorandum sets forth implementation guidance concerning privacy related to the Do Not Pay Initiative. The guidance defines roles and responsibilities, and addresses applicable databases, record use and retention, correction of data, procedural safeguards, review by data integrity boards and public availability of computer matching agreements.

Frankly, I found the document to be chock-full with technical speak and bureaucratic language. Therefore, it’s not one of the most thrilling pieces of memorandum coming out of OMB. However, it is important that agency officials follow this guidance to protect individual privacy, which we can’t seem to get enough of these days.

What do you think of this memorandum? Let us know.

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