Federal agencies participate in the TOP program in the following ways:
As a Payment Agency — An agency making payments that Treasury matches against its
delinquent debtor database and offsets 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 that is owed a debt and submits it to TOP for collection
by offset from a payment agency; and
As both a Payment and Creditor Agency – An agency that participates in TOP as both
a payment agency and creditor agency.
NOTE: 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 that an
agency is in the process of issuing to a debtor, Treasury reduces or withholds the
payment and sends it to the agency 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 from a debtor's Title II payment to
satisfy a delinquent title XVI debt. SSA performs this type of debt collection internally
via mandatory cross program recovery (see SI 02220.020).