Data Brokers and the Federal Government: A New Front in the Battle for Privacy Opens | Discussion and Analysis of the OMB Do Not Pay Guidance
The best starting point for understanding the OMB Do Not Pay memo is with the legal framework behind the Do Not Pay Initiative. The Initiative derives from a combination of little-noticed executive orders and updates to existing laws.
In 2009, Executive Order 13520, Reducing Improper Payments, [29] directed agencies to identify “ways in which information sharing may improve eligibility verification and pre-payment scrutiny.” This was the start of the current Do Not Pay Initiative.