The United States Department of Agriculture (USDA) recently announced a new, consolidated department-wide matching program, a significant step in the federal government's ongoing effort to curb improper payments. Published in the Federal Register on September 3, 2026, this notice details a collaborative effort between the USDA and the Department of the Treasury's Do Not Pay (DNP) Working System, designed to prevent, detect, and recoup erroneous financial disbursements across a wide array of federal programs. The public has a 30-day window to submit comments, with the deadline set for October 5, 2026. This program is slated to remain in effect through September 10, 2029.
Foundations in Federal Law and Policy
The matching program operates under a robust legal and policy framework. It builds upon the Computer Matching and Privacy Protection Act of 1988, which amended the Privacy Act of 1974 to establish procedural safeguards for computerized matching activities. Further refinements were introduced by the Omnibus Budget Reconciliation Act of 1990. A pivotal authority for this initiative is the Payment Integrity Information Act of 2019 (PIIA), specifically 31 U.S.C. 3351 et seq., which empowers the agency operating the DNP Working System to waive certain matching agreement requirements.
Consistent with this authority, the Secretary of the Treasury, following consultation with the Director of the Office of Management and Budget (OMB), has issued a four-year waiver for the requirement of a matching agreement under 5 U.S.C. 552a(o). This waiver, effective from September 10, 2025, through September 10, 2029, applies to matching activities that meet the criteria outlined in OMB Memorandum M-25-32, "Preventing Improper Payments and Protecting Privacy Through Do Not Pay." Executive Order 14249, "Protecting America's Bank Account Against Fraud, Waste, and Abuse," issued by President Trump, also underpins the authority for conducting such matching programs, emphasizing the federal government's commitment to financial integrity.
Operational Mechanics of the Program
The core purpose of this matching program is straightforward: to identify and prevent improper payments and to facilitate related recoupment activities. This is achieved through pre-payment and pre-award eligibility verification. The USDA will submit minimal necessary data elements to the DNP Working System. These elements may include an individual's name, Social Security number, Federal or State Taxpayer Identification Number, Unique Entity Identifier, date of birth, various addresses, business identifiers, and payment or award identifiers.
Upon receiving USDA data, the DNP Working System will conduct comparisons with its extensive databases. If a potentially matching record is identified, the DNP system will notify the USDA and specify the source database of the potential match. It is crucial to note that a potential match from the DNP system is not, by itself, a determination of ineligibility or a basis for adverse action. Instead, it serves as an indicator requiring independent verification by the USDA. Following this verification, the USDA will determine appropriate follow-up actions in accordance with applicable law and program procedures.
Scope and Affected Entities
The program's reach extends to a broad spectrum of individuals involved with USDA-administered federal funds. This includes applicants for or recipients of these funds, such as sole proprietors, beneficiaries, borrowers, grantees, vendors, contractors, producers, landowners, and individuals doing business with the Food and Nutrition Service. While the primary focus is on individuals, records concerning organizations or other non-individual entities are included to the extent they identify or pertain to an individual.
Five distinct USDA systems of records are involved in this matching program. These systems support a wide array of USDA programs and activities. For instance, the USDA/RD-1 system covers various Rural Development programs, including technical assistance, grant programs, and housing loans. The USDA/FNS-10 system encompasses Food and Nutrition Service programs, such as the Child and Adult Care Food Program, Supplemental Nutrition Assistance Program (SNAP), and National School Lunch Program. The USDA/FSA-14 and USDA/FSA-2 systems are associated with Farm Service Agency programs, including different types of loans, commodity programs, and disaster assistance programs.
Data Elements and Privacy Safeguards
Records involved in the computerized comparison include both identifying and payment- or award-related data submitted by USDA, as well as information maintained in the DNP Working System. The DNP source records are specifically housed in Treasury/Fiscal Service .017 Do Not Pay Payment Verification Records. USDA's follow-up records may include identity-verification results, supporting documentation, correspondence, and notices related to eligibility determinations or subsequent actions.
While the program leverages a waiver for the matching agreement requirement, it is still subject to the broader Privacy Act of 1974 and the safeguards it establishes. The intent is to balance the need for robust payment integrity with the protection of individual privacy. The independent verification step by USDA after a potential DNP match is a critical safeguard, ensuring that no adverse action is taken solely based on automated comparison results.
Implications and Outlook
This consolidated matching program underscores the federal government's commitment to safeguarding taxpayer dollars and enhancing the integrity of federal programs. By integrating its payment verification processes with the Treasury's DNP system, the USDA aims to reduce financial waste and improve accountability across its diverse operations. The program's pre-payment and pre-award verification mechanism represents a proactive approach to preventing improper payments before they occur, rather than solely focusing on recovery after the fact.
The public comment period offers an important opportunity for stakeholders to provide input on this significant federal initiative. The success of such a program hinges not only on its technical implementation but also on continuous oversight, adherence to privacy principles, and transparent communication. As the program progresses, careful attention will be needed to ensure its effectiveness in combating improper payments while upholding the rights and protections afforded to individuals under the Privacy Act.
