Accounts payable — payment release procedure (internal control text)

Payment-time read. Before release of funds to any payee, the payment system shall obtain a dated read of the SAM.gov Exclusions public extract, the HHS-OIG exclusion list and the OFAC SDN list for the payee's exact legal name and key, compared line by line with the previous read of the same payee. The record shall state, for each source: the source's own file date or the read time, the official key (UEI, NPI, EIN, CIK or CCN) or the exact printed name used, the rows returned verbatim, and any source that was not read or did not answer. The record shall carry a SHA-256 of its canonical content and shall conform to the Alpha Covenant Receipt Format v1 (an open specification, CC BY 4.0, at https://alphacovenantholdings.com/spec), so that any party may recompute the hash and re-run the read. The record is evidence of what the files printed on a date; it is not a representation by the record's producer about the party's eligibility, identity or compliance, which remain the responsibility of the party and the reviewing officer. Where any exclusion, debarment or sanctions source shows a row that was not present at the previous read, or a source did not answer, the payment is held for a named reviewer's decision; the receipt id is recorded with the payment.