Notice 2026-17369

Checking retirement eligibility against a Treasury database — the safeguards when agencies match records about people

Office of Personnel Management Published Aug 26, 2026 91 FR 55128

The Office of Personnel Management gave notice of a program matching its records against the Treasury Do Not Pay system to verify eligibility for federal retirement benefits. A match alone cannot stop a payment: independent verification and a right to contest are guaranteed.

Document overview (primary data)

  • Document typeNotice
  • AgencyOffice of Personnel Management
  • Citation91 FR 55128

Key points

  • OPM gave notice of a new program matching its records against the Treasury Do Not Pay system to verify retirement benefit eligibility.
  • It covers former federal employees, annuitants, survivors and beneficiaries with records tied to federal retirement systems.
  • Match results will not be used as the sole basis for suspending, terminating, denying or recouping benefits.
  • OPM will independently verify potential matches and provide notice, an opportunity to contest and appeal rights before adverse action.
  • The program takes effect 30 days after publication and runs through September 10, 2029 under safeguards set by the 1988 Act.

1When agencies compare records

Comparing individual records held by one government agency against records held by another, by machine, is called computer matching. It is done to find improper or fraudulent payments, but the records belong to real people. The Computer Matching and Privacy Protection Act of 1988 therefore amended the Privacy Act of 1974 to establish procedural safeguards, and this notice follows that procedure.

2What is matched against what

  1. 1The matching sideRecords systems held by OPM Retirement Services
  2. 2The matched sideThe Do Not Pay Working System, run by the Treasury Bureau of the Fiscal Service
  3. 3PurposeIdentifying and preventing improper payments and verifying pre-payment eligibility
  4. 4Individuals coveredFormer federal employees, annuitants, survivors, beneficiaries and others with records tied to retirement benefits

What is verified is continued eligibility for retirement benefits under the Civil Service Retirement System and the Federal Employees Retirement System. Checking whether payments continue to someone who has died is a typical use.

3A match alone cannot stop a payment

The most important line here is that Do Not Pay match results will not be used as the sole basis for suspending, terminating, denying or recouping benefits. Machine comparison contains error — identical names, keying mistakes, records not yet updated. So OPM will independently verify any potential match and, before taking adverse action, provide notice, an opportunity to contest and appeal rights.

4Term and procedure

Effective30 days after publicationComments go through the federal rulemaking portal
ExpirySeptember 10, 2029Unless terminated earlier or superseded
AuthorityPayment Integrity Information Act of 2019, among othersCarried out under safeguards set by the 1988 Act

A matching program carries a term rather than running indefinitely. The notice also states that comments are made publicly viewable without change, including any personal identifiers submitted with them. A regime handling individual records is itself governed through an open procedure.

Why it matters

That machine comparison contains error is built into the design of the regime itself. Treating a match as evidence rather than as a decision, with human verification and a right to contest, is a useful model for any administrative use of matched data.

FAQ

What is computer matching?
Comparing individual records held by one government agency against records held by another, by machine, to find improper or fraudulent payments.
Does a match stop benefits immediately?
No. A match cannot be the sole basis for stopping benefits; it must be independently verified, with notice, an opportunity to contest and appeal rights.

Sources (primary)

Source: Federal Register (federal documents, public domain). Links go to the official site.

#OPM#Privacy Act#Data matching#Retirement benefits#Personal data
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