Payment Feedback

2.6 Out of Scope Assumptions

Regarding bullet #7. In all WB financed projects for PFMIS implementation, where they impose implementation of TSA, there is no more data flow from the Ministry/Department (MDA) directly to the bank. Payment Orders is entered in budget institution, controlled against budget and moves to Treasury, who based on cash flow schedule sends it at some point of time bank. That means that there is no connectivity and information flow between MDA and bank. This kind of scenario can be added in the future to the scope as I know there are still a lot of big countries, who need such implementation. Iraq, for example.

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4.1 General Key Functionalities of the Payments Building Block

regarding p.5: I suggest to have explicit reference to support anti-corruption controls ensuring transparency to external stakeholders over internal controls applied to every transaction: every dollar of public budgets money should be possible to scrutinise not only by internal audit of Ministry of Finance but also by general public.

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4.1

I suggest to add capability to handle payments on behalf of different budgets (i.e. central government, social funds, local governments). In low income states that is needed (I saw such requirement, for example, in Moldova).

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6.1 Payments BB Components

Current architecture does not support multi-tenant architecture where tenant is a specific budget. Like that, system does not support seamless delivery of G2P and P2G services on behalf of different segments of public administration (central government, municipalities, social funds etc.) from one deployment.

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6.1.6 Account Lookup Directory service

I suggest in future to add to this component not only payee account lookup but also payer account lookup. Also, cash availability service could be instrumental. Then, public sector can have better transparency over cash flow fo so called budget institutions “own resources“ i.e. budget institutions' revenues from commercial activities, which they may retain and used autonomously.

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6.1.9 Payment Portal

If budget institution is allowed to make G2P payment through the portal, then there should be a cash flow management capability for the Treasury. That is the must for all countries, where budget and cash flow are not really in sync (all low-income countries).

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7.2 Incoming Government Payment Resource

In the transaction, which is payment of for example, customs duties, taxes, police fines, there should be mandatory element Transaction Type or Reference Number, which could be used in public administration organisation for automatic reconciliation with outstanding liability.

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PAY-215: Update to 7.2 Incoming Government Payments ResourceDone