Alpha Covenant Holdings · Duty Sheet · generated 2026-10-25 16:55 UTC · free · all sheets

Payment Integrity Information Act (31 U.S.C. 3351–3358; OMB M-21-19) — pre-payment eligibility record for federal and federally funded disbursements

Applies to: Federal disbursing officers and payment-integrity leads; state comptrollers, treasurers and auditors paying out federal pass-through funds (Medicaid, highway, education, housing) · Rule text: https://www.congress.gov/bill/116th-congress/senate-bill/375

The question the rule asks

PIIA requires agencies to identify programs susceptible to improper payments, to prevent payments to ineligible recipients — including excluded, debarred or deceased payees — and to report on the controls that do so. OMB M-21-19 asks for pre-payment eligibility verification and documentation of the check. The record a reviewer or Inspector General asks for: what did the eligibility sources print for this payee at the time of payment, and how do you know?

The party this sheet is about

Wellpath LLC · keys supplied: UEI JL99G1YPJKK9 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_e876ec2554ba4020 · read 2026-10-25 16:55:10 UTC · SHA-256 afe015cbb1aceb92458e4e21e75b9ac76d2086e8a613482ef42148a9a7051857 · verify: https://alphacovenantholdings.com/r/r_e876ec2554ba4020

The official files that answer it, as read on that date

Source	Role	State	Records	What it printed
SAM.gov Exclusions — Public Extract V2 (GSA, daily)	answers the question	answered	0	No entry under this exact name/UEI in the SAM extract fetched 2026-10-24 (SAM_Exclusions_Public_Extract_V2_26297.ZIP).
HHS Office of Inspector General — LEIE (monthly downloadable file)	answers the question	answered	0	No entry under this exact name in the OIG file fetched 2026-10-18.
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)	answers the question	answered	0	No entry under this exact name or listed alias on the SDN list fetched 2026-10-24.
State Medicaid exclusion / termination lists (each state's own published file)	supporting	answered	0	No entry under this exact name/NPI in the 13 state lists read (latest fetch 2026-10-24); 29 state lists are published in forms we cannot read and were not checked.
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directly	supporting	answered	0	0 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
USAspending.gov (recipient name equals this name)	supporting	answered		1 registered recipient(s) equal this name; 24 active prime award(s), $3,830,809 obligated
IRS Tax Exempt Organization Search — Automatic Revocation of Exemption list and Publication 78 data (bulk files)	supporting	answered	0	0 automatic-revocation entries under this exact printed legal name. Publication 78: no organization listed under this exact printed legal name (absence is not a statement about exemption).

What to record in the file

The receipt read at payment time with the payment id as the reference and since set to the payee's previous receipt — SAM exclusions, LEIE and OFAC SDN with file dates, the state list where the program is Medicaid, and the line-by-line change since the prior read. Treasury's Do Not Pay portal (which also carries the Death Master File and credit-alert data) is restricted to agencies and is not read here; record that check separately. The payment decision is the disbursing officer's; this sheet records the files.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections