Accounts payable — dated read before releasing a payment

Template version 2026-10-06 · for: Hospital and health-system AP / treasury; any organization disbursing federal-award funds · owner role: AP Manager (owner); Controller (rule owner); Compliance Officer (oversight) · adopted by organization effective date . Editable .txt · JSON

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

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.
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.
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.
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'.
File each read's id and hash with the payment record so an auditor can reproduce the state at the time of payment.
Quarterly: the Controller reviews the rule and the measures below with the Compliance Officer; a rule change is a notation here.

Findings reported — computed from your own records; the threshold is your protocol's

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

Records

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

Date	Change
2026-10-06	First issue.
date	adopted / edited by name

Other templates: 01 · 02 · 03 · 06 · 07 · 08 · 09 · 10 · 01 · Duty Sheets (one page per rule, generated on any receipt) · our own procedures · 2026-10-25