Alpha Covenant Holdings · Evidence Clause · model language · CC BY 4.0 · https://alphacovenantholdings.com/clause

State comptroller / treasurer — pre-payment eligibility record for federally funded disbursements (PIIA; 2 CFR 200.214; 42 CFR 455.436)

For: State comptrollers, treasurers, Medicaid fiscal agents and state auditors, in payment-system requirements and fiscal-agent contracts

Pre-payment eligibility record. For each disbursement of federal or federally matched funds, the payment system shall obtain, before funds release, a dated read of the SAM.gov Exclusions public extract, the HHS-OIG List of Excluded Individuals/Entities, the OFAC Specially Designated Nationals list and, for medical-assistance payments, the State's own exclusion 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. The record is retained with the payment and made available to the State Auditor and to federal reviewers under the Payment Integrity Information Act. Checks of Treasury's Do Not Pay portal are performed and recorded separately by the agency.

The clause does not name a vendor and does not make any producer of the record a gatekeeper of award or payment. Any platform that publishes a conforming record satisfies it. Alpha Covenant Holdings issues conforming records free at https://alphacovenantholdings.com/screening; that is why we publish the clause.