Analyses / Impact Analysis / 119 · S 1991 Impact Analysis

119-S-1991 Investigative Journalist Impact Analysis

119 · S 1991 Delivering On Government Efficiency in Spending Act

Bottom-line assessment
Bottom‑line judgment grounded in the evidence record.
FY2024 reported improper payments
162$B
Programs/agencies included in FY2024 estimate
68programs / 16 agencies
Share of FY2024 improper payments that were overpayments
84%
Payments issued by Treasury FDS in FY2024
1.27B payments
Published
12 Dec 2025
Updated
12 Dec 2025
Tags
Impact Analysis · S.1991 (119th) · Program Integrity
Unvetted
01 · Section

Summary

What the bill does, how it changes today’s controls, and where impacts will likely surface.

S.1991 (Delivering On Government Efficiency in Spending Act) would: (1) require agencies to transmit a brief purpose description, account symbol, and Business Event Type Code with each payment sent to Treasury’s disbursement systems; (2) mandate periodic accuracy attestations; (3) direct OMB/Treasury to publish those payment‑level fields to USAspending.gov within 30 days (with a sensitive‑operations carve‑out); and (4) broaden program‑integrity data access by granting Treasury access to the National Directory of New Hires (NDNH), select tax return items via a privacy‑preserving query, and certain consumer reports; it also instructs precertification bank‑account verification. [1]Congress.gov — S.1991 (119th): Delivering On Government Efficiency in Spending…

Context: Treasury’s Fiscal Service disburses the lion’s share of federal payments (about 1.27B payments totaling $5.45T in FY2024, ~97% electronic). While reported government‑wide improper payments fell to about $162B in FY2024 (from $236B in FY2023), GAO notes the estimate covers a subset of programs and likely understates total risk—making upstream verification attractive but highly sensitive to data quality and governance. [5]U.S. Department of the Treasury, Bureau of the Fiscal Service — Federal Disburs…[2]U.S. Government Accountability Office — Improper Payments: Information on Agenc…

FY2024 reported improper payments
162$B
Programs/agencies included in FY2024 estimate
68programs / 16 agencies
Share of FY2024 improper payments that were overpayments
84%
Payments issued by Treasury FDS in FY2024
1.27B payments
Share of Treasury‑issued payments that were electronic (FY2024)
96.9%
02 · Section

Economic Effects

Likely costs and savings for agencies, vendors, recipients, and markets.

  • Administrative burden and IT change costs: Agencies would need to capture and transmit payment‑purpose metadata consistently, implement annual verification workflows, and integrate bank‑account validation. Near‑term costs include system changes, staff training, and vendor interface updates. Treasury guidance and shared services (e.g., Account Verification Service) should reduce bespoke build costs. [1]Congress.gov — S.1991 (119th): Delivering On Government Efficiency in Spending…[6]U.S. Department of the Treasury, Bureau of the Fiscal Service — Payment Integri…[7]U.S. Department of the Treasury, Bureau of the Fiscal Service — Account Verific…
  • Potential reduction in misdirected or fraudulent payments: Treasury reports that enhanced fraud detection and analytics prevented/recovered more than $4B in FY2024; institutionalizing precertification bank‑account checks and broader eligibility data access could extend such savings, though actual yield depends on adoption and data accuracy. [8]U.S. Department of the Treasury — Treasury Announces Enhanced Fraud Detection P…
  • Cash‑flow effects on businesses and grantees: Added screening (NDNH, tax attributes, bank ownership) may introduce occasional delays or re‑verification cycles—especially when data mismatches occur—but should reduce downstream payment reversals and collections. Agencies can seek waivers when screening yields excessive false positives, indicating recognized trade‑offs. [9]U.S. Government Accountability Office — Improper Payments: Strategy and Additio…
  • Market transparency and oversight: Publishing payment‑level purpose/account/activity fields to USAspending could improve vendor due diligence and price discovery over time, but only if data quality improves; GAO has repeatedly found gaps and inconsistencies in USAspending data. [10]U.S. Government Accountability Office — Federal Spending Transparency: Opportun…
  • Scale/context: Centralized disbursement already covers roughly 90% of federal payments; standardizing payment metadata at that scale can sharpen spend analytics and contract oversight with relatively small marginal transaction cost. [11]U.S. Department of the Treasury — Treasury Letter to Congress Regarding Payment…
03 · Section

Social Effects

Consequences for communities, demographic groups, and vulnerable populations.

  • Program integrity vs. access: Expanded data matching (NDNH, tax data, consumer reports) could better flag ineligible or deceased payees, protecting program resources; however, data errors and stale records risk interrupting payments to eligible beneficiaries, especially in state‑administered programs serving low‑income households. Strong adjudication processes are essential. [4]Legal Information Institute (Cornell Law School) — 31 U.S.C. § 3354 — Do Not Pa…[12]Congressional Research Service — CRS In Focus: The National Directory of New Hi…
  • Notice and remedy: The bill’s FCRA tweak would exclude certain pre‑certification terminations from “adverse action,” which may reduce consumers’ notice rights when a credit‑report‑based screen stops a payment before issuance—raising due‑process concerns if agencies don’t provide equivalent notice/appeal paths. This is an inference from the intersection of the bill’s language and existing FCRA notice requirements. [1]Congress.gov — S.1991 (119th): Delivering On Government Efficiency in Spending…[13]Legal Information Institute (Cornell Law School) — 15 U.S.C. § 1681a — Fair Cre…[14]Legal Information Institute (Cornell Law School) — 15 U.S.C. § 1681b — FCRA Per…
  • Equity and error propagation: GAO has warned that anti‑fraud tools, including AI, depend on clean, representative data and a skilled workforce; poor data quality can misclassify legitimate recipients. Agencies will need to monitor false‑match rates and impacts on protected classes. [15]Web search · turn 3 #3
04 · Section

Environmental Effects

Direct environmental effects are limited; indirect effects relate to federal IT footprint and data‑center energy use.

Requiring additional payment‑metadata capture and verification modestly increases data processing/storage but rides on existing Treasury and agency systems. Federal data‑center policy has emphasized consolidation and energy efficiency, with billions in reported savings since 2012—suggesting the incremental load from this bill is likely negligible if agencies continue optimizing and using cloud/shared services. [16]U.S. Government Accountability Office — Data Center Optimization: Agencies Cont…[17]Web search · turn 8 #2

05 · Section

Temporal Analysis

Near‑term vs. long‑term effects and dependencies.

  1. 0–18 months (implementation): Rulemaking/guidance from Treasury and OMB; agency system changes to tag payments; onboarding to Account Verification Service; establishing annual attestation workflows. Expect transitional friction (match‑rate tuning, help‑desk load) and some payment holds due to mismatches. [1]Congress.gov — S.1991 (119th): Delivering On Government Efficiency in Spending…[7]U.S. Department of the Treasury, Bureau of the Fiscal Service — Account Verific…
  2. 1–3 years (stabilization): If data quality and procedures improve, agencies should see fewer misdirected payments and better visibility into spend patterns; public reporting may aid oversight and procurement market analysis if USAspending data quality improves. [8]U.S. Department of the Treasury — Treasury Announces Enhanced Fraud Detection P…[10]U.S. Government Accountability Office — Federal Spending Transparency: Opportun…
  3. 3+ years (steady state): The net effect on improper payments should be positive but bounded by data coverage limits GAO highlights (many susceptible programs still lack estimates). Realized savings hinge on sustained governance, data‑sharing agreements, and workforce capacity. [2]U.S. Government Accountability Office — Improper Payments: Information on Agenc…
06 · Section

Unintended Consequences

Credible risks and secondary effects documented in oversight literature or implied by statutory interactions.

  • Privacy and data‑sharing creep: 31 U.S.C. §3354 allows OMB to waive certain Privacy Act matching requirements for DNP activities. S.1991 further expands Treasury’s access (NDNH, tax elements) and redisclosure authorities. Without tight minimization, audit trails, and breach response, risk of over‑collection or secondary use rises. [4]Legal Information Institute (Cornell Law School) — 31 U.S.C. § 3354 — Do Not Pa…[1]Congress.gov — S.1991 (119th): Delivering On Government Efficiency in Spending…
  • False positives and payment disruption: GAO documented concerns that DNP payment‑integration can produce burdensome false matches, to the point OMB created a waiver process. Scaling checks to every payment could amplify this if tuning and adjudication lag. [9]U.S. Government Accountability Office — Improper Payments: Strategy and Additio…
  • Transparency without quality: Mandating rapid public posting of payment fields won’t deliver accountability if data are inconsistent or incomplete—an ongoing USAspending critique—potentially eroding trust or misdirecting watchdog effort. [10]U.S. Government Accountability Office — Federal Spending Transparency: Opportun…
  • Contractor/credit‑bureau reliance: Expanded use of consumer reports and bank‑account validation can centralize gatekeeping in private vendors; outages, bias, or inaccuracies could block legitimate payments at scale unless agencies maintain fallback procedures and robust dispute mechanisms. This risk follows from FCRA/AVS operational dependencies noted in official materials. [14]Legal Information Institute (Cornell Law School) — 15 U.S.C. § 1681b — FCRA Per…[7]U.S. Department of the Treasury, Bureau of the Fiscal Service — Account Verific…
  • Sensitive‑operation exemptions: The bill’s public‑reporting exemptions for law‑enforcement and national‑security payments are prudent, but if over‑used they could create opaque spend categories hard for Congress and the public to scrutinize. Agencies must justify exemptions in annexes as required. [1]Congress.gov — S.1991 (119th): Delivering On Government Efficiency in Spending…
07 · Section

Assessment

Bottom‑line judgment grounded in the evidence record.

Overall stance: neutral. Evidence suggests the package can strengthen pre‑payment controls (notably via bank‑account verification and expanded eligibility data) and improve spend traceability, potentially trimming a slice of the ~$162B in FY2024 reported improper payments. But material benefits depend on execution—data quality, appeal/notice processes when screens trip, and genuine improvements to USAspending data. Privacy and due‑process risks are non‑trivial given expanded access/redisclosure and the FCRA carve‑out for pre‑certification terminations. Oversight, metrics, and safeguards will determine whether promised savings outweigh administrative costs and social risks. [2]U.S. Government Accountability Office — Improper Payments: Information on Agenc…[7]U.S. Department of the Treasury, Bureau of the Fiscal Service — Account Verific…[10]U.S. Government Accountability Office — Federal Spending Transparency: Opportun…[13]Legal Information Institute (Cornell Law School) — 15 U.S.C. § 1681a — Fair Cre…

08 · Section

Sourcing and Provenance

Primary sources used for statutory text, program baselines, and risk evidence.

  • Bill text and structure: Congress.gov official text for S.1991. [1]Congress.gov — S.1991 (119th): Delivering On Government Efficiency in Spending…
  • Improper‑payment baselines and program‑integrity context: GAO FY2024 report and related materials. [2]U.S. Government Accountability Office — Improper Payments: Information on Agenc…
  • Treasury operations and services: Fiscal Service stats; Do Not Pay and Payment Integrity/AVS documentation; Treasury press materials. [5]U.S. Department of the Treasury, Bureau of the Fiscal Service — Federal Disburs…[3]U.S. Department of the Treasury, Bureau of the Fiscal Service — Do Not Pay — Pr…[6]U.S. Department of the Treasury, Bureau of the Fiscal Service — Payment Integri…[7]U.S. Department of the Treasury, Bureau of the Fiscal Service — Account Verific…[8]U.S. Department of the Treasury — Treasury Announces Enhanced Fraud Detection P…
  • Legal authorities: 31 U.S.C. §3354 (Do Not Pay); FCRA adverse‑action and permissible‑purpose provisions; NDNH scope via CRS and Federal Register notices. [4]Legal Information Institute (Cornell Law School) — 31 U.S.C. § 3354 — Do Not Pa…[13]Legal Information Institute (Cornell Law School) — 15 U.S.C. § 1681a — Fair Cre…[14]Legal Information Institute (Cornell Law School) — 15 U.S.C. § 1681b — FCRA Per…[12]Congressional Research Service — CRS In Focus: The National Directory of New Hi…[19]Federal Register / govinfo.gov — Federal Register Notice: SSA–OCSS Matching Pro…
  • Data transparency issues: GAO on USAspending data quality. [10]U.S. Government Accountability Office — Federal Spending Transparency: Opportun…
  • Environmental/IT footprint: GAO on federal data‑center optimization; broader demand trend context. [16]U.S. Government Accountability Office — Data Center Optimization: Agencies Cont…[18]Reuters — U.S. data‑center power use could nearly triple by 2028, DOE‑backed re…
Sources cited
  1. [1] S.1991 (119th): Delivering On Government Efficiency in Spending Act — Bill Text Congress.gov
  2. [2] Improper Payments: Information on Agencies’ Fiscal Year 2024 Estimates (GAO-25-107753) U.S. Government Accountability Office
  3. [3] Do Not Pay — Program Overview U.S. Department of the Treasury, Bureau of the Fiscal Service
  4. [4] 31 U.S.C. § 3354 — Do Not Pay Initiative Legal Information Institute (Cornell Law School)
  5. [5] Federal Disbursement Services — FY2024 Payments Summary U.S. Department of the Treasury, Bureau of the Fiscal Service
  6. [6] Payment Integrity — Office of Payment Integrity (OPI) U.S. Department of the Treasury, Bureau of the Fiscal Service
  7. [7] Account Verification Service (AVS) — Payment Integrity U.S. Department of the Treasury, Bureau of the Fiscal Service
  8. [8] Treasury Announces Enhanced Fraud Detection Prevented/Recovered Over $4B in FY2024 U.S. Department of the Treasury
  9. [9] Improper Payments: Strategy and Additional Actions Needed to Help Ensure Agencies Use the Do Not Pay Working System as Intended (GAO-17-15) U.S. Government Accountability Office
  10. [10] Federal Spending Transparency: Opportunities to Improve the Information Available on USAspending.gov (GAO-22-104702) U.S. Government Accountability Office
  11. [11] Treasury Letter to Congress Regarding Payment Systems (Feb. 4, 2025) U.S. Department of the Treasury
  12. [12] CRS In Focus: The National Directory of New Hires — An Overview Congressional Research Service
  13. [13] 15 U.S.C. § 1681a — Fair Credit Reporting Act Definitions (incl. Adverse Action) Legal Information Institute (Cornell Law School)
  14. [14] 15 U.S.C. § 1681b — FCRA Permissible Purposes of Consumer Reports Legal Information Institute (Cornell Law School)
  15. [15] Web search · turn 3 #3
  16. [16] Data Center Optimization: Agencies Continue to Report Progress (GAO-23-105946) U.S. Government Accountability Office
  17. [17] Web search · turn 8 #2
  18. [18] U.S. data‑center power use could nearly triple by 2028, DOE‑backed report says Reuters
  19. [19] Federal Register Notice: SSA–OCSS Matching Program Using NDNH Data (Nov. 21, 2025) Federal Register / govinfo.gov

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