Federal agencies participate in the TOP program in the following ways:
As a Payment Agency — An agency making payments that would be matched against a delinquent
debtor database (maintained by Treasury) and then offset to yield the recovery of
a delinquent debt; (See GN 02410.300 for detailed information about Benefit Payment Offset).
As a Creditor Agency — An agency which is owed a debt and submits it to TOP for collection
by offset from a payment agency;
As both a Payment and Creditor Agency – SSA participates in TOP as both a payment
agency and creditor agency.
The TOP process is based on computer matching. TOP uses the taxpayer identification
number (TIN) and a name control (generally the first four characters of the debtor's
last name), to match the debtor and payee records. For SSA, the TIN is the same as
the beneficiary's own account number (BOAN). When TOP identifies a payment about to
be sent to a debtor, Treasury reduces or withholds the payment and sends it to the
agency that is owed the debt (the creditor agency).
NOTE: TOP does not collect delinquent debts owed to SSA by offsetting benefit payments
made by SSA. For example, TOP will not collect a delinquent title XVI debt from that
person's title II payment. This is done internally by SSA in debt collection programs
such as mandatory cross program recovery (see SI 02220.020).