What Treasury Sends Back When It Finds Your TIN

CMS filed two pages in the Federal Register on Friday morning that contain no codes, no rates, and no comment-and-response table, and they will do more to your accounts receivable next year than most of what published this month.

The document is a Privacy Act notice re-establishing the computer match between the Provider Enrollment, Chain, and Ownership System and Treasury's Do Not Pay Working System. Initial term of 36 months, running approximately October 19, 2026 to October 18, 2029.

We gave it five sentences on yesterday's radar. It earns more than that, and the trade press has not touched it at all.

So here is the whole machine, and the part of it that reaches backward into claims you have already been paid for.

Why This Needed a New Notice

The 2020 notice is still on file at 85 FR 58062, which makes this one of the rare cases where the diff is available to anyone who wants it.

We ran it. The purpose clause is word for word the same, including the sentence that matters most: the match exists "to promptly suspend or revoke the Medicare billing privileges of the identified disqualified providers and suppliers" and "to enable recoupment of past payments made to those providers and suppliers."

The twelve fields CMS hands Treasury are identical, in the same order. The list coming back shrank by exactly one entry, from 50 fields to 49, and the entry that went missing is the catch-all one called Other Agency Data.

Which raises the obvious question, because the notice itself says a matching agreement can be renewed without any of this if the parties "make no change to the matching program."

"If nothing in the program changed, why file a new notice at all?"

The answer is in the authority list, which is the one section that was rewritten.

Gone: the 2010 Presidential Memorandum on a "Do Not Pay List" and OMB Memorandum M-18-20. Added: the Payment Integrity Information Act framing, OMB Memorandum M-25-32, and Executive Order 14249, signed March 2025.

Section 4(b)(v) of that order directs Treasury to consider enforcing a pre-certification criterion on federal disbursement vouchers, stated in six words: "Payees are not deceased individuals." Section 3(d) gave agencies 90 days to add a routine use to their systems of records permitting disclosure to Treasury for "identifying, preventing, or recouping" improper payments.

And the arithmetic on the old agreement lands in the same week. A 36-month term from October 13, 2020 ran to October 12, 2023, and the single renewal the notice allowed would carry it to October 12, 2026.

The new term starts seven days after that.