Comments on Supplemental Guidance for Agency Matching Programs

Comments were provided on the Office of Management and Budget's supplemental guidance for agency matching programs. The guidance provides that both the agency conducting the matching program and the entity or agency which is asked to provide information share the responsibility for determining the appropriateness of releasing information for conducting the match. When other federal agencies supply information, they must transfer such information pursuant to the routine use exemption of the Privacy Act. Nevertheless, the scope of matching programs is generally limited to use as an aid to curtail fraud or unauthorized payments under federal programs, for collecting debts, and for establishing reporting requirements for matching programs carried out by federal agencies. In addition, the supplemental guidance is advisory rather than mandatory.