Accounts payable — dated read before releasing a payment
Template version 2026-10-06 — adopted by: ____________________  effective: __________  owner: AP Manager (owner); Controller (rule owner); Compliance Officer (oversight)

Template. Written against the public text of the standard cited; the organization adopts, edits and owns it as its protocol. Every threshold, identity, hold or disclosure decision belongs to the organization. We report the findings against the protocol — counts, dates, states — nothing more. Not legal advice, not a compliance determination, not a consumer report.

STANDARDS SERVED
- HHS-OIG — payment for items or services furnished by an excluded person exposes the payer to CMPs (42 CFR 1003) — https://www.ecfr.gov/current/title-42/chapter-V/subchapter-B/part-1003
- 2 CFR 200.214 / 180.300 — covered transactions with federal-award funds — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-I/part-180/subpart-C/section-180.300
- OFAC — U.S. persons may not transact with blocked persons — https://ofac.treasury.gov/
- Internal control over disbursements — your auditor's framework (COSO / 2 CFR 200.303) — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/section-200.303

SCOPE
Payments above $___ (set by the Controller), all payments from federal-award funds, and first payments to any new payee.

FREQUENCY
At the moment of payment-run approval; the read must be dated within ___ days of release (set here).

PROCEDURE
1. Write the hold rule here, in words, owned by the Controller: e.g. 'hold for compliance review if any of sam.count, leie.count, ofac.count, state.count, csl.count or uflpa.count rose since the previous read, or if sam or ofac did not answer'. The rule is the organization's; the read is the record of why it fired or did not.
2. At payment-run approval: for each in-scope payee, obtain a fresh dated read with since=<previous receipt id> so the record carries both the current state and every line that differs from the last read.
3. Release payments the rule does not stop. For payments the rule stops: route to Compliance with the changed lines; Compliance records the decision (release / hold / escalate) and its basis.
4. A source that did not answer is printed on the read; the rule above says what AP does with it (hold, or release with the gap recorded). Never treat it as 'no match'.
5. File each read's id and hash with the payment record so an auditor can reproduce the state at the time of payment.
6. Quarterly: the Controller reviews the rule and the measures below with the Compliance Officer; a rule change is a notation here.

MEASURES (findings reported monthly; the threshold for each is your protocol's)
- In-scope payment coverage: payments in scope with a read dated within ___ days of release ÷ in-scope payments. Data: AP system; receipt created_at. Threshold: your protocol: ________
- Rule firings: payments stopped by the rule; share released after review; median hours to decision. Data: AP hold log; Compliance decisions. Threshold: your protocol: ________
- Silence at payment: payments released while a named source did not answer ÷ payments. Data: receipt did_not_answer. Threshold: your protocol: ________
- Changed-line review before release: payments with a changed line where Compliance decision predates release ÷ payments with a changed line. Data: ENTITY_STATE_DELTA events; AP timestamps. Threshold: your protocol: ________
- Reproducibility: sampled payments whose receipt hash still verifies and whose proof date precedes the payment. Data: receipt verify; timestamp proof. Threshold: your protocol: ________

RECORDS
- Hold rule text and its change notations — kept by Controller — retention indefinite
- Read id + hash per in-scope payment — kept by AP — retention per HOSP-08 and finance retention
- Compliance decisions on stopped payments — kept by Compliance — retention per HOSP-08

WHAT THIS PROCEDURE DOES NOT DECIDE
Whether to pay. The read states what the files printed and what changed; the hold rule and every release decision are the organization's.

CHANGE LOG (add a line for every change; keep superseded versions)
- 2026-10-06: First issue.
- ________: adopted/edited by ____________________

Source template: https://alphacovenantholdings.com/api/public-record/sop-templates/hosp-05-ap-pre-payment-read/html · Duty Sheets: https://alphacovenantholdings.com/api/public-record/duty-sheets · Our own procedures: https://alphacovenantholdings.com/api/trust/sops