Federal agencies · CFO offices · Inspectors General
Verify Purchase-Card and Federal Payments Before Funds Leave.
JIL Federal Payment Integrity verifies purchase-card transactions and federal payments against vendor, exclusion, threshold, and improper-payment rules before funds are disbursed, and produces evidence-backed attestation records for every payment decision.
The wedge is GSA SmartPay: roughly 4.6M active cards, about $40B in annual spend, and about 100M transactions a year. The data is bounded, the mandate hooks are already in force (Government Charge Card Abuse Prevention Act of 2012, OMB Circular A-123 Appendix B), and the political attention is at a maximum. JIL moves integrity checks before payment. Identification and evidence; the agency adjudicates and collects.
Business use
Built for payment integrity at the point of payment.
Agencies face pressure from OMB, GAO, IGs, and Congress to reduce improper payments and document the integrity controls in force at the moment of disbursement. The Payment Integrity Information Act (PIIA) emphasizes prepayment review and treats pay-and-chase recovery as the inefficient fallback. JIL provides the prepayment verification layer, a retrospective recovery look-back, and the evidence record that backs every payment decision.
Six business outcomes
Where Federal Payment Integrity moves the needle.
Purchase-card / SmartPay integrity
Transaction-level checks on merchant category, prohibited and high-risk purchases, cardholder limits, and policy compliance across the SmartPay charge-card program.
Vendor and exclusion screening
UEI/SAM.gov resolution, OIG/SAM exclusion screening, OFAC sanctions overlay, beneficial-owner chain, and duplicate-vendor detection at payment time.
Split-purchase and threshold avoidance
Detection of micro-purchase and simplified-acquisition threshold splitting, sequential same-vendor charges, and structuring designed to evade approval limits.
Duplicate and duplicate-vendor detection
Duplicate transaction, duplicate invoice, and shared-bank-account vendor detection across the card ledger and payment extract.
Improper-payment recovery look-back
Retrospective scan of historical payments to quantify recoverable amounts, mapped to A-123 Appendix B control failures, authorized under IPERA recovery audit scope.
Qui-tam / FCA referral capture
Qui-tam-suitability scoring surfaces False Claims Act candidates as a byproduct of attestation, capturing fraud-referral value legacy recovery audits systematically miss.
Two-phase entry
Start the engagement before the authorization clock finishes.
The data sits inside the agency, so the gate is not data acquisition. It is authorization. The framework is built to deliver value during Phase 0 and to fund the authorization for Phase 1.
Retrospective look-back (fast)
Mode B, pay-then-attest. The agency exports a SmartPay ledger and payment extract. JIL ingests it in JIL's own environment alongside public sources, runs the attestation, and returns quantified recoveries plus a CREB sample. A delivered-data engagement, not a live system tie-in, so it sidesteps the heaviest ATO requirements and moves in weeks. Funded as a fixed-price task order.
Live prepayment attestation (scale)
Mode A, authorize-then-execute. Continuous attestation at the point of payment, post-ATO. This is the PIIA-preferred prevention model: prepayment review and Treasury Do Not Pay screening before payment. Gated by FedRAMP or agency ATO; FedRAMP 20x readiness is pursued in parallel during Phase 0.
Use cases
Payment domains covered.
Purchase-card integrity (SmartPay)
The entry wedge. Charge-card transaction attestation across merchant category, prohibited purchases, cardholder limits, split purchases, and duplicate charges, mapped to the Government Charge Card Abuse Prevention Act and A-123 Appendix B.
PIIA improper-payment attestation
Prepayment review and improper-payment screening for federal payments, aligned to PIIA's prevention model and the Treasury Do Not Pay framework, with recoverable-exposure quantification.
MAS defective pricing
GSA Multiple Award Schedule price-reduction and defective-pricing review, comparing invoiced rates against catalog and contract terms to surface overcharges.
Technical deep dive
How it integrates with agency systems.
- SmartPay charge-card ledger and transaction extract
- SAM.gov entity registration and UEI linkage
- USAspending award and outlay data
- FPDS contract action data
- OFAC and Treasury sanctions lists
- GSA MAS catalog and contract pricing
- Payment extract from the financial system / Treasury rails
UEI/SAM.gov resolution, OIG/SAM exclusion screening, OFAC and Treasury sanctions overlay, beneficial-owner graph, duplicate vendor and shared-bank-account detection, and address/identity overlap analysis.
A 234-check attestation mapped to OMB Circular A-123 Appendix B controls. Findings are expressed as control failures with the governing citation, so recoveries and prevention gaps tie directly to the agency's existing internal-control framework.
Detection of micro-purchase and simplified-acquisition threshold splitting, sequential same-vendor same-day charges, and structuring patterns that evade cardholder limits and approval thresholds.
Pass / Review / Block verdict per payment with risk score, triggered checks, reason codes, and rule citations. The verdict is determined by deterministic rules and statutory citations; AVA accelerates operations (drafting narratives, clustering findings, cost-optimizing the Tier 2 plan) but never determines the outcome. Block returns the payment to the agency workflow for review before disbursement is reauthorized.
Every finding carries a sealed Court Ready Evidence Bundle (CREB), self-authenticating under FRE 902(14), anchored on CourtChain with an Ed25519 plus Dilithium-III signature, referencing all checks executed, source citations, reviewer actions, and a cryptographic timestamp. Auditors and the IG retrieve the bundle directly; no reconstruction.
- Phase 0: delivered-data retrospective look-back in JIL's environment (Mode B, pay-then-attest)
- Quantified recoveries plus A-123 Appendix B findings and a CREB sample
- FedRAMP 20x readiness pursued in parallel during Phase 0
- Phase 1: live prepayment attestation at the point of payment (Mode A), post-ATO
- Continuous attestation, Treasury Do Not Pay screening, CREB on demand, cross-network bad-actor registry, and lifecycle monitoring
What this is not
Scope, plainly.
- Not a federal agency
- Not an adjudicator. JIL identifies and evidences; the agency adjudicates and collects, consistent with the IPERA recovery audit scope limits
- Not a final overpayment determination
- Not a payment processor and not a custodian of funds
- Not legal advice and not a substitute for IG review
Commercial model
Three-leg pricing, federal-budget friendly.
A fixed-price retrospective look-back pilot proves recovery value and funds the authorization for live attestation. A recovery share is authorized under IPERA and OMB Circular A-123 Appendix C, conservative against the federal recovery audit caps, with refunds on successful appeal. Live prepayment attestation is offered as an annual fixed-price subscription scaled by transaction volume and card count, for budget predictability. Pricing is shared under engagement; figures are not published here.
Primary contract vehicle: GSA MAS or a GWAC. Phase 0 can run as a fixed-price task order for speed. For federal funds administered by states or grantees, 2 CFR Part 200 procurement justification applies.
Move payment integrity before the disbursement.
Brief your charge-card program manager, CFO office, or IG. We will walk the SmartPay wedge, the two-phase entry, the sealed CREB evidence record, the integration path with your financial system, and the FedRAMP path.
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