Congress should consider assigning a single federal agency authority to establish and implement governmentwide data standards and interoperability requirements for data used to determine recipient eligibility for federal programs, according to a new report from the Government Accountability Office (GAO).
The report found that no designated data governance agency currently has authority to establish and enforce governmentwide interoperability requirements for recipient eligibility data, leaving efforts to improve interoperability fragmented across federal agencies.
GAO said the Treasury Department could be well positioned to serve as a lead agency because of its roles in preventing and detecting improper payments and operating systems that collect, validate, and use financial, award, spending, and payment data.
Federal agencies use more than 100 data sources to verify recipient eligibility throughout the award life cycle, including pre-award screening, post-award monitoring, and payment validation. As of September 2025, 28 of those sources were included in or designated for inclusion in the federal Do Not Pay working system, GAO noted.
The agency reviewed nine selected data sources and found data quality issues in all of them, including missing, invalid, and duplicate records. Seven sources also contained inconsistencies, such as overlapping information in categories intended to be mutually exclusive. According to the report, insufficient or poorly documented validation rules contributed to many of those issues, reducing data reliability and making eligibility determinations more difficult.
The report said improved interoperability could support efforts to prevent improper payments and enhance the government’s ability to leverage artificial intelligence (AI) and advanced analytics.
While federal laws and guidance address data interoperability, GAO found they do not establish governmentwide requirements for recipient eligibility data sources. Many of the databases that GAO reviewed were created to meet legal requirements or support individual programs rather than governmentwide eligibility determinations.
GAO also examined how eligibility data could be linked with award data.
The agency matched System for Award Management (SAM) and SAM Exclusion records with USAspending.gov award data using unique entity identifiers (UEIs). While most USAspending.gov recipient UEIs could be linked to SAM entity records, most SAM Exclusion records lacked a UEI because the identifier is not always required.
Among exclusion records that included a UEI, GAO identified 2,074 awards made to recipients listed in the exclusion data source at the time of the transaction. However, the report stressed that those matches alone do not indicate fraud, waste, abuse, or improper awards and would require case-by-case review.
GAO said the limitations of its analysis illustrate broader challenges agencies face when matching data across systems.
The report noted that standardized data elements and greater consistency in information such as names and addresses could improve matching efforts and help agencies identify potentially ineligible recipients.
Under GAO’s proposal, Treasury would coordinate with the Chief Data Officer Council and consult with the Office of Management and Budget (OMB) as needed. The report warned that without a designated data governance agency, federal agencies will continue to face reporting challenges and inefficiencies in determining recipient eligibility, limiting their ability to leverage AI and advanced analytics in eligibility determinations.
In comments included in the report, the Bureau of the Fiscal Service agreed with GAO’s findings and said Treasury would need clear authority to lead governmentwide standardization efforts for eligibility data used in the Do Not Pay system. OMB did not comment.