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Choose a government payment processor only after confirming which rules govern your agency, which payment methods and channels it needs, and how money and transaction data must flow into its operations. For most federal agencies accepting cards, Treasury’s Card Acquiring Service (CAS) is the required route unless an exception applies. State and local agencies must determine their own procurement and payment requirements; the federal CAS rule does not automatically apply to them.
Start with the agency’s jurisdiction and authority to procure
Before inviting proposals or comparing transaction rates, establish which procurement path the agency is allowed or required to use. A processor can meet technical needs and still be an unsuitable choice if the agency cannot use that provider or contract.
Federal agencies: check CAS participation and exceptions
The Treasury Bureau of the Fiscal Service says most federal agencies that accept credit or debit cards must use the Card Acquiring Service (CAS), unless authorized to process independently. Treasury’s FAQ lists the U.S. Postal Service, Army/Air Force Exchange Service, Navy Exchange, and Smithsonian among exceptions to the usual participation rule. Confirm current applicability with Treasury and agency counsel rather than assuming an exception applies. See Treasury’s CAS FAQs and CAS overview.
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CAS is a federal program, not a government-wide mandate for every public entity. Treasury describes a footprint of approximately 10,000 locations and more than 19,000 point-of-sale endpoints; those figures describe CAS, not the size or quality of the broader processor market. The overview was last updated February 25, 2026. Treasury CAS overview
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Federal purchase-card rules are a separate issue. FAR 13.301 authorizes use of the governmentwide commercial purchase card for otherwise lawful purchases and directs agencies to maintain procedures consistent with the Treasury Financial Manual and the current GSA credit card contract. That rule concerns how the government makes purchases; it does not, by itself, select a processor for collecting payments from the public. FAR Subpart 13.3
State and local agencies: identify the applicable local route
There is no single state or local rule established here that determines which processor an agency must use. Check the jurisdiction’s procurement rules, statewide contracts or processing programs, required approvals for payment service providers, and any rules for customer-facing fees. An agency may also have an existing contract or separate legal authority that affects its options. Ask procurement and counsel to confirm the applicable route before treating an open-market vendor proposal as eligible.
Define the payment job before evaluating proposals
Write down what the agency collects, how constituents pay, and what staff must do after a payment arrives. A useful inventory prevents a proposal built around one channel—such as online card checkout—from being mistaken for a complete solution.
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- Channels: online, in person, telephone, mail, recurring, and staff-assisted payments. Identify whether the agency needs physical terminals, an online checkout, or both.
- Payment methods: credit and debit cards, ACH, and any EBT or stored-value acceptance required by the program. Treat ACH as its own payment rail, with its own operating requirements, rather than assuming it is simply a card-processing feature.
- Transaction profile: typical and peak volume, average and maximum ticket, seasonal spikes, and any deadlines for making funds available.
- Exceptions and aftercare: refunds, reversals, disputes, deposits, recurring-payment changes, and the records needed to resolve constituent questions or audit activity.
For federal entities, Treasury’s payment-mechanism guidance describes ACH and Same Day ACH options where same-day settlement benefits the entity and government. Whether ACH fits a particular use case depends on the agency’s payment needs and applicable operating rules. Treasury Financial Experience: Payment Mechanisms
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Understand the transaction lifecycle
A card payment is not a single handoff. In the authorization stage, a request travels from the point where the agency accepts payment through the acquirer or processor and card network to the card issuer. Clearing and settlement then reconcile transactions and move funds through the relevant accounts. These stages determine which parties handle data, where exceptions arise, and what timing information the agency needs for daily close and constituent service. Treasury CAS overview
For CAS, Treasury says prior-day transactions settle to its Federal Reserve account before 2:00 p.m. ET, with next-day funds availability. These are program-specific details, not a service level to assume for a different contract, jurisdiction, or payment rail. Ask each eligible bidder to state the settlement schedule, the receiving account, cutoffs, and how weekends or holidays affect availability.
Set security and compliance requirements as pass/fail conditions
Security is an operating responsibility, not a feature to infer from a sales description. Treasury states that federal agencies processing, storing, or transmitting card transactions must fully comply with the Payment Card Industry Data Security Standard (PCI DSS). Treasury identifies PCI DSS, EMV, encryption, and tokenization among the security elements of CAS. These federal statements do not replace an agency’s own assessment of applicable obligations. Treasury CAS rules and security requirements
Require a documented data-flow and responsibility map
Ask bidders to show where cardholder data enters, which systems and parties can access it, where it is transmitted or stored, and what data reaches agency systems. Require a clear division of responsibilities between the agency, processor, gateway, terminal provider, and any other service provider. The proposal should explain encryption and tokenization, access controls, incident response, and what changes to the processing design would do to the agency’s compliance scope.
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Request evidence of the bidder’s PCI DSS validation and specify what evidence the agency will receive, how often it is refreshed, and how ongoing controls are maintained. Validation evidence and ongoing compliance are different things; outsourcing processing or using tokens does not, by itself, establish that the agency has no duties. Treasury’s FAQ and security page discuss these responsibilities separately. Treasury CAS FAQs
Prohibit retention of sensitive authentication data after authorization
Treasury says not to store full magnetic-stripe track content, card verification codes such as CVV or CVC, or PINs and encrypted PIN blocks after authorization. Put this requirement into the solicitation and require bidders to explain how their design prevents prohibited retention, including in logs, support tools, exports, and backups. Treasury CAS rules and security requirements
Compare total cost, not a headline transaction rate
Ask every eligible bidder for a complete schedule of charges by payment method and channel. Then apply those charges to the agency’s own transaction mix. A percentage rate alone will not show the cost of small-ticket, high-volume payments, terminals, refunds, dispute handling, or implementation.
- Percentage-based and per-transaction charges for each payment type and channel
- Gateway, terminal, hardware, monthly, and minimum charges
- Fees or retained amounts associated with refunds, reversals, and chargebacks
- Reporting, implementation, training, and support costs
- Contract-end charges, data-export terms, and any costs of transition or termination
Model the likely total cost using the agency’s volumes, average and maximum ticket, channel mix, and expected refunds or disputes. If bidders structure fees differently, ask them to price the same representative scenarios and disclose assumptions. No market-wide average processor price is established here, so do not treat an advertised rate or a single proposal as a government-wide benchmark.
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Keep debit interchange rules in scope
Federal Reserve Regulation II covers specified debit-card interchange fee standards and routing. It is not a complete processor price schedule, does not establish all costs an agency will pay, and does not cover credit-card or ACH fees. Government-administered payment-program transactions can qualify for an exemption, so assess the relevant transaction and program rather than applying a general assumption. The Federal Reserve explains that fees for checks, credit cards, and ACH are outside section 920 or Regulation II. Federal Reserve Regulation II overview
Do not assume that interchange treatment determines whether the agency may add a convenience fee, surcharge, or other customer charge. That question requires review under the rules that apply to the jurisdiction and transaction; the Federal Reserve’s Regulation II materials do not settle every customer-fee question.
Specify settlement, reconciliation, and daily operations
Translate the finance team’s daily work into proposal requirements. A processor should be evaluated on whether staff can match payment activity to deposits, resolve exceptions, and close the books—not just whether a transaction can be authorized.
- Funds and deposits: required settlement timing, deposit destination, cutoff times, and the treatment of weekends and holidays.
- Reconciliation: transaction-level records, batch and deposit totals, fees, refunds, reversals, and dispute status, with enough detail to trace a deposit to source transactions.
- Accounting: support for agency accounting codes, reporting formats, and the finance and line-of-business systems that need payment data.
- Constituent and audit records: clear receipts, searchable transaction histories, role-based access, and audit trails for staff actions.
- Service continuity: uptime commitments, incident escalation, support hours, disaster recovery, and a practical alternative when a channel is unavailable.
- Exit and access: data portability and usable records at contract end, including any transition responsibilities.
CAS’s settlement flow illustrates why these questions matter, but it does not establish the integration needs of an individual agency or a service commitment for another provider. Define those needs in the solicitation, including expected implementation effort and accessibility requirements for constituent-facing services. Treasury CAS overview
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Use a pass/fail screen before scoring proposals
First exclude proposals that fail a legal, program, security, or operational requirement. Then score the proposals that remain against criteria tied to the agency’s actual work. This keeps an attractive transaction rate from compensating for an ineligible contract path or an unacceptable data-handling design.
| Evaluation area | Questions for the agency’s review |
|---|---|
| Eligibility and contract route | May the agency use this provider and procurement vehicle? Are the term, renewals, exit rights, and any required program participation acceptable? |
| Payment coverage | Does the proposal support the required methods, card types, channels, workflows, and transaction limits? |
| Security and compliance | Are responsibilities, data handling, validation evidence, incident response, and changes to agency scope documented and acceptable? |
| Economics | What is the modeled total cost for the agency’s actual mix, including setup, hardware, refunds, disputes, reporting, and termination? |
| Settlement and accounting | When and where are funds available, how are deposits reconciled, and does reporting support the agency’s close process? |
| Integration and operations | What connections, staff effort, accessibility provisions, support, uptime, and continuity arrangements are required? |
| Constituent experience and resilience | Can people use the needed payment channels, receive clear receipts, and access a workable alternative if a digital or in-person service is unavailable? |
Set mandatory minimums and a scoring method before reviewing prices. Keep bidder responses and assumptions in the evaluation record so procurement staff can explain why a proposal passed, failed, or scored as it did.
Turn the framework into a defensible acquisition
- Confirm authority. Document the agency’s jurisdiction, applicable program rules, procurement vehicle, existing contract constraints, and any required approvals. For federal agencies, resolve CAS participation and exceptions first.
- Map the payment service. Record every channel and payment method, transaction pattern, refund and dispute workflow, and operational deadline. Identify which systems need payment or accounting data.
- Write mandatory requirements. Define minimum security evidence, prohibited data retention, settlement and reconciliation needs, accessibility, continuity, reporting, and data portability.
- Request comparable proposals. Ask eligible bidders to answer the same questions, disclose all fees, describe the processing and data flows, and price the same agency-specific scenarios.
- Screen, model, and score. Apply pass/fail requirements before calculating weighted scores. Model cost on the agency’s transaction profile, then evaluate the remaining proposals on operations, integration, security, and constituent access.
- Validate representations before award. Have procurement, finance, IT/security, payment operations, and counsel verify current program requirements, solicitation terms, security evidence, and bidder commitments at the time of purchase.
Common selection mistakes to avoid
- Applying federal CAS rules to a state or local agency. Confirm the rules and contract route for the agency’s own jurisdiction.
- Choosing on price before eligibility. A low fee does not make an unauthorized provider or contract path acceptable.
- Assuming card acceptance covers ACH. Specify ACH as a separate rail when needed and confirm the relevant operating rules.
- Equating outsourcing with compliance. Map data flows and responsibilities, and verify ongoing controls rather than relying on a general promise that the processor is secure.
- Using a CAS timing detail as a universal service promise. The before-2:00 p.m. ET settlement and next-day availability details apply to CAS’s federal program.
- Treating Regulation II as a cap on all processing costs. Its scope is specified debit interchange and routing; it is not a full processor price schedule.
- Leaving the exit plan until renewal. Require data portability and transition terms in the solicitation and contract.
What the federal CAS figures do—and do not—tell you
Treasury’s CAS rules state a maximum credit-card transaction of $24,999.99 for agencies using those CAS rules. Treasury’s FAQ separately gives a $9,999.99 limit for government cards. These are program and payment-type limits, not general limits for every public agency or every processor; confirm the applicable rule before designing a workflow around either figure. Treasury CAS rules and security requirements and Treasury CAS FAQs
Treasury’s FAQ, last updated November 10, 2021, said that more than 60 federal agencies used CAS. Because that figure is from an older FAQ, retain the date if citing it and verify it before treating it as current. It is not a measure of available vendors or a reason to select a processor. Treasury CAS FAQs
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