Summary

  • In a test using fiscal 2023 and 2024 data, GAO matched 2,074 awards involving 137 entities with active SAM Exclusion records at transaction time. The related obligations totaled $626.2 million as of February 2025. Awarding agencies must assess each case; the match alone settles no eligibility question.
  • Of 172,091 SAM Exclusion records in the test, 128,818 had no unique entity identifier. Many were records for which an identifier was not required, including individuals. GAO's exact-identifier join could not examine those records.
  • GAO found quality problems in all nine selected eligibility sources and no federal body empowered to enforce mandatory interoperability rules for recipient eligibility. It asked Congress to consider giving Treasury that lead role, working with the Chief Data Officer Council and consulting OMB.

A sharp match inside a blurry register

The GAO report begins with a routine public task: before awarding or paying federal money, an agency needs to know whether the recipient is eligible. It can consult more than 100 federal data sources. Twenty-eight were in Treasury's Do Not Pay working system, or designated for it, as of September 2025. That looks like a large safety net. Its knots do not have common dimensions.

GAO tested a narrow but consequential join. It compared fiscal 2023 and 2024 awards in USAspending.gov with SAM entity records and SAM Exclusions using the unique entity identifier, or UEI. The award side contained 20.3 million records: 12.8 million had a valid UEI that linked to SAM entity information, 7.4 million lacked one, and 2,969 carried an invalid one. Most awards without a UEI were aggregated financial-assistance records that did not require the identifier. The exclusion side held 172,091 records. Only 41,822 had a valid UEI; 128,818 had none and 1,451 had an invalid one.

Many missing identifiers on that side belonged to categories, such as individuals, for which a UEI was not required.

Within the part that could be joined, GAO found 2,074 awards involving 137 entities listed in SAM Exclusions at the time of the transaction. Obligations on those awards reached $626.2 million as of February 2025. Each match deserves a case review by the awarding agency. An active exclusion entry and an award transaction in the same join do not automatically establish an improper award. GAO's assignment was to see whether the files could be connected, not to adjudicate those 2,074 cases.

The more revealing count may be 128,818. Those exclusion records were outside this UEI-only test. Calling those exclusion records simply dirty data would be cheap and wrong: some lack a UEI because the rules never required one. On the award side, aggregated assistance may omit an identifier to protect personal information. The operating problem is to specify how a payment check handles lawful missingness. If the exact key is absent, which names, addresses, dates and exclusion details may be compared? Who validates the fields? Who records why a match was accepted, rejected or sent to a person?

A register full of records is only a safety net when the join rules can carry them.

Nine sources, no single rule writer

GAO selected nine eligibility sources for closer examination. All nine had quality issues, including missing, invalid or duplicate data. Seven showed inconsistencies across sources. Their dictionaries, validation rules and histories were uneven. These nine were a purposive sample, not a survey proving the condition of every federal file. They were enough to expose a familiar institutional bargain: each source was built for its owner's legal or program task, while another agency now wants to use it to decide eligibility.

For more than thirty years, federal law and guidance have praised standardization, sharing and reuse. The full report found no designated agency able to set and enforce mandatory government-wide interoperability requirements for recipient eligibility data. Councils and offices can advise, coordinate and publish good practice. Adoption across the people who own the records remains voluntary. A national payment check therefore depends on many local decisions about definitions and validation that no one can compel to align.

GAO asked Congress to consider assigning Treasury explicit lead authority to establish standards for definitions, dictionaries, validation rules and disclosures across the award life cycle, working with the Chief Data Officer Council and consulting OMB. Treasury's Bureau of the Fiscal Service agreed that clear authority would be necessary for government-wide standardization of eligibility data in Do Not Pay. OMB did not comment. As of July 2026, the matter for Congress was open. This is a proposed transfer of authority, not a power Treasury already holds.

The federal government can count the matches its existing keys produce. It has not settled who writes the rules for the records that do not fit the key. That is why the precise 2,074 and the unmatchable majority belong in the same story.

Sources