Choose a government payment processor only after confirming that your agency is allowed to procure one, identifying the payment methods and channels it needs, and documenting its security, settlement, accounting, and service requirements. Federal agencies that accept cards generally must use Treasury’s Card Acquiring Service (CAS), subject to stated exceptions; state and local agencies must check their own jurisdiction’s rules and contracts. A low quoted transaction rate is not a sound selection basis if the proposal is ineligible, insecure, or difficult to reconcile.
Start with the agency’s legal and procurement route
The first question is not which processor has the best price. It is whether the agency may select one independently, must use an established program, or is required to procure through a particular contract vehicle. The answer depends on jurisdiction, agency type, payment purpose, and applicable procurement authority.
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Federal agencies: check CAS before soliciting providers
The U.S. Department of the Treasury says most federal agencies that accept credit or debit cards must use its Card Acquiring Service (CAS), unless an exception applies. Treasury lists the U.S. Postal Service, Army/Air Force Exchange Service, Navy Exchange, and Smithsonian among exceptions in its CAS FAQ. Those examples do not establish an exception for another agency. Confirm current applicability with Treasury and agency counsel before treating an independent processor as an option. See Treasury’s CAS FAQ.
CAS is a federal program, not a government-wide rule for every public entity. Treasury’s current overview, last updated February 25, 2026, describes a footprint of approximately 10,000 locations and more than 19,000 point-of-sale endpoints. Those figures describe CAS, not the size of the processor market or a requirement that every agency use physical terminals. The CAS overview explains its federal operating model.
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State and local agencies: identify local authority and contracts
There is no universal state-and-local processor rule established here. Check the jurisdiction’s procurement code and payment policies, statewide purchasing contracts, any required payment-provider approvals, and rules for fees charged to constituents. Determine whether a department can contract on its own or must use a central finance, treasury, or IT arrangement. Ask procurement staff to confirm the permitted route before issuing a solicitation or accepting a proposal.
Do not assume that federal CAS participation rules, federal contract terms, or federal exceptions apply to a municipality, county, public university, or state agency. Likewise, do not assume that an existing processor contract held by another public entity is available to your agency.
Keep purchase-card rules separate from public payment acceptance
A government purchase card used by staff to buy goods or services is a different issue from a processor collecting fees, taxes, fines, or other payments from the public. FAR 13.301 addresses governmentwide commercial purchase-card use for otherwise lawful purchases and agency procedures; it does not itself select a public-facing payment processor. Consult the relevant FAR Subpart 13.3 and your agency’s procurement guidance when purchase-card questions arise.
Define the service before comparing proposals
Build a transaction inventory with finance, treasury, program staff, customer service, IT, security, and procurement. A processor proposal can look inexpensive while failing a necessary channel, payment rail, accounting workflow, or operating constraint. Write down the current process and the target process before asking bidders to price a solution.
Inventory channels, payment methods, and transaction patterns
- Channels: online checkout, in-person counter or field payments, telephone, mail, recurring charges, and staff-assisted transactions. Mark which channels are required now and which are genuinely planned.
- Payment methods: credit and debit cards, ACH, and any applicable EBT or stored-value acceptance. Do not treat ACH as merely a card feature; it is a separate payment rail with its own operating considerations.
- Transaction profile: estimate transaction counts, average and maximum ticket, seasonal or deadline-driven peaks, refunds, reversals, disputes, and expected growth. Use agency records where available and label estimates as estimates.
- Service constraints: identify operating hours, locations, connectivity limits, accessibility needs, language or assisted-service needs, and any periods when a payment interruption would materially affect the program.
- Funds and records: document where deposits must arrive, when funds are needed, which accounting codes apply, what level of transaction detail is needed, and who investigates exceptions.
For each use case, trace what happens from the constituent’s payment attempt through authorization, clearing, settlement, deposit, reconciliation, receipt, refund, and dispute handling. Treasury describes card authorization as the request moving from the acceptance point through the acquirer or processor and card network to the issuer. Clearing and settlement then reconcile transactions and move funds through the relevant accounts. This lifecycle is why a checkout screen alone is not an adequate description of the service. See the Treasury CAS overview.
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Consider ACH where it fits the payment and operating rules
ACH may be appropriate for some payments, including cases where a card is unnecessary or the payment workflow benefits from a bank-account payment. Treasury’s payment-mechanism guidance describes ACH and Same Day ACH options for federal entities when same-day settlement benefits the entity and government. Eligibility and operating requirements matter: compare an ACH service on its own terms rather than assuming it is included in a card-processing proposal. The Treasury Financial Experience payment-mechanisms guidance is a starting point for federal entities.
Turn the inventory into pass/fail requirements
Before assigning scores, identify requirements that a proposal must meet to remain eligible for evaluation. A hard requirement should be tied to a documented agency need, policy, or legal obligation—not added because a feature sounds attractive. Record the evidence bidders must provide and who will verify it.
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- Coverage: require the payment methods, channels, locations, transaction limits, and workflows the inventory identified.
- Security: require a clear data-flow description, allocation of compliance responsibilities, evidence of PCI DSS validation where applicable, and incident-response commitments.
- Finance operations: require the deposit destination, settlement schedule, transaction-level records, reconciliation method, refund and reversal handling, and audit trail needed to close accounts.
- Integration: require a feasible connection to named finance, treasury, case-management, or line-of-business systems, including ownership of interface changes and error handling.
- Continuity: require support and escalation arrangements, recovery planning, accessible alternatives, and a workable way to retrieve agency data at contract end.
Set pass/fail requirements first, then score the proposals that satisfy them. An attractive rate cannot compensate for an ineligible procurement path or a security design the agency cannot accept.
Evaluate security as an ongoing operating responsibility
For federal agencies, Treasury states that agencies processing, storing, or transmitting credit- and debit-card transactions must comply fully with the Payment Card Industry Data Security Standard (PCI DSS). Treasury also identifies PCI DSS, EMV, encryption, and tokenization as elements of CAS security. These are not reasons to assume that outsourcing card handling transfers every responsibility away from the agency. Review Treasury’s CAS rules and security requirements, last updated March 8, 2026, and determine the agency’s obligations for its actual architecture.
Ask bidders to map data and responsibilities
Require a diagram or written data-flow explanation showing where cardholder data enters, which systems and parties handle it, what reaches agency-controlled equipment, and how data is protected in transit and at rest. Ask what tokenization does in the proposed design, where encryption is applied, who can access payment data, and how access is logged and reviewed. Require the bidder to explain how a change to the checkout flow, terminal, integration, or service could alter the agency’s compliance scope.
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Request the evidence needed to assess validation, the division of responsibilities between provider and agency, and the controls that continue between formal validation events. Ask how incidents are detected, reported, investigated, and escalated; who contacts affected parties when required; and how the agency receives a post-incident account. Put response times and notification duties in the contract rather than relying on a general assurance that the service is secure.
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Prohibit retention of sensitive authentication data after authorization
Treasury says not to retain full magnetic-stripe track content, card verification codes such as CVV or CVC, or PINs and encrypted PIN blocks after authorization. Confirm what the processor, gateway, terminal, and agency applications store, including logs and support tools. Tokenization can reduce exposure in an architecture, but the agency still needs to understand its own handling, validation, and ongoing controls.
Compare the full cost, not a headline rate
Ask each bidder for a complete price schedule in the same format. Rates are only comparable when the services, channel mix, payment types, contract terms, and cost assumptions are comparable. Apply each proposal’s charges to the agency’s own estimated volume and transaction pattern; the available official material does not establish a market-wide average processor price.
| Cost area | What to request | Why it affects the comparison |
|---|---|---|
| Transaction processing | Percentage and per-transaction charges by payment type, channel, and transaction outcome, with the basis for each charge. | A proposal’s effective cost depends on the agency’s actual mix, not a single advertised rate. |
| Platform and equipment | Gateway, terminal, reader, software, connectivity, monthly, minimum, and setup charges. | Channel-specific equipment or recurring fees may change the cost of an otherwise similar offer. |
| Exceptions and service | Refunds, reversals, disputes or chargebacks, reporting, customer support, and other separately billed services. | Exception handling and operational support are part of the service, not peripheral costs. |
| Implementation and exit | Integration, migration, training, contract termination, and data-export charges and conditions. | One-time transition costs and exit restrictions affect the total commitment and future flexibility. |
Ask bidders to show the calculation for multiple agency-defined scenarios, such as an ordinary month and a peak period, using identical assumptions. Separate one-time implementation costs from recurring charges. Clarify whether a quote includes taxes or other pass-through items, whether minimums apply during low-volume periods, and what happens to price at renewal. Do not compare a price that includes equipment and support with one that excludes them without accounting for the difference.
Understand the limited role of Regulation II
Federal Reserve Regulation II sets standards for specified debit-card interchange fees and routing. It does not set all processor charges or provide a complete schedule of payment costs. The Federal Reserve explains that the standards do not cover fees for credit-card or ACH transactions, and that transactions in government-administered payment programs can qualify for an exemption. Therefore, do not treat Regulation II as a cap on an agency’s total processing expense or use it to infer the rate a bidder should charge. See the Federal Reserve’s Regulation II overview, last updated May 17, 2024.
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If a proposal assumes that a convenience fee, surcharge, or other charge will be paid by constituents, get jurisdiction-specific legal and policy review before relying on that revenue model. The legality and permitted structure of such charges are not resolved by the general processor-selection guidance here.
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Settlement speed is useful only if it matches the agency’s deposit and close processes. Treasury’s CAS program describes prior-day transactions settling to Treasury’s Federal Reserve account before 2:00 p.m. Eastern Time, with next-day funds availability. That is a CAS-specific program detail, not a service-level guarantee for another processor, state, or locality. Ask each bidder to state its own timing, cutoffs, calendar assumptions, deposit destination, and treatment of weekends, holidays, exceptions, and delayed transactions.
Require a sample report and walk through a realistic reconciliation. Staff should be able to match each payment and adjustment to the bank deposit, program or accounting code, and constituent record without relying on unexplained batch totals. Specify how the service identifies partial settlements, failed deposits, duplicate records, late presentments, refunds, and disputes, and how staff can research them later.
Make integration requirements testable
- Identify the systems that must send or receive payment information and the records each system needs.
- Specify required transaction identifiers, timestamps, amounts, statuses, refund links, and accounting dimensions.
- Define how failed messages, duplicate submissions, outages, and manual corrections are detected and resolved.
- Ask who builds, tests, monitors, and maintains each interface, and how changes are approved and communicated.
- Set acceptance criteria for reconciliation, role-based access, audit records, and data export before implementation begins.
Do not assume Treasury’s CAS information describes a particular agency’s accounting integration. Define those details from the agency’s systems and reporting obligations, then ask bidders to demonstrate how their service meets them.
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Compare proposals on consistent criteria
Once mandatory requirements are met, evaluate each eligible proposal against the same evidence and scenarios. A useful comparison records both the answer and its source—proposal section, demonstration, contract clause, or security evidence—so evaluators can distinguish a commitment from a sales explanation.
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| Evaluation area | Evidence to compare | Decision question |
|---|---|---|
| Eligibility and contract route | Provider authority, program participation, procurement vehicle, term, renewal, termination, and exit terms. | Can the agency lawfully and practically use this arrangement? |
| Payment coverage | Supported methods, channels, card types, locations, recurring workflows, and transaction limits. | Does it cover the agency’s required use cases without unacceptable workarounds? |
| Security and compliance | Data flow, responsibility matrix, PCI DSS evidence, encryption and tokenization design, incident response, and scope changes. | Can the agency meet its obligations and verify the provider’s commitments? |
| Total economics | Comparable scenario pricing, setup and equipment, exceptions, support, renewal, and exit costs. | What is the cost under the agency’s transaction profile over the proposed term? |
| Settlement and accounting | Cutoffs, deposit timing, deposit destination, report detail, reconciliation, and exception handling. | Can finance staff confirm receipts and close accounts using the service’s records? |
| Integration and operations | Interface fit, implementation plan, accessibility, uptime commitments, support coverage, and continuity arrangements. | Can the agency operate and support the service through routine work and disruption? |
| Constituent experience | Checkout clarity, receipts, payment alternatives, assisted access, and recovery when a payment fails. | Can people complete the payment reliably through the channels the agency serves? |
Weights should reflect the agency’s priorities and be set before scoring begins. Document why an area matters, how evidence will be judged, and how evaluators will handle unanswered or qualified responses. Run a consistent demonstration using agency-relevant tasks: complete a payment, issue a refund, find a transaction, reconcile a deposit, and retrieve an audit record. A demonstration should verify stated requirements, not replace contract language or security review.
Put service and exit commitments in the contract
Translate the selected proposal into measurable obligations. Define what counts as service availability, how it is measured, which planned maintenance is excluded, and how incidents are classified and escalated. Specify support hours, contact paths, response and restoration expectations, status communications, and reporting. Require a continuity and recovery approach appropriate to the payment program, including how the agency will handle a disruption and communicate alternatives to constituents.
Contract terms should also address implementation milestones and acceptance, data ownership and permitted use, access controls, audit cooperation, incident notification, subcontractor responsibilities, price changes, renewal, termination, and transition assistance. Specify the format and timing for transaction and audit-data exports at exit, and how the agency can verify that data is returned or disposed of according to its requirements. Procurement, counsel, security, finance, and operations should review commitments that affect their responsibilities.
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Use CAS-specific limits only when the program applies
Treasury’s CAS materials state a maximum credit-card transaction amount of $24,999.99 for agencies using CAS rules. The CAS FAQ separately gives a $9,999.99 limit for government cards. These are program-specific limits, not universal caps for all government payment processors or all payment types; verify which applies to the agency and transaction before designing a workflow. Sources: CAS rules and security requirements and the CAS FAQ.
If agency receipts can exceed an applicable limit, identify the affected payment types and amounts during requirements definition. Ask the governing program or authorized provider how the payment should be handled rather than assuming that splitting transactions is permitted or operationally appropriate.
Quick Recap
A practical selection sequence
- Confirm authority. Establish whether federal CAS rules apply, whether a documented exception is relevant, or which state or local contract and procurement rules govern.
- Map payments end to end. Inventory channels, rails, transaction patterns, deposits, refunds, disputes, accounting, and constituent needs.
- Set pass/fail criteria. Define legal, security, coverage, reconciliation, integration, and continuity requirements before examining price.
- Issue a comparable request. Provide the same transaction assumptions, scenarios, contract questions, reporting needs, and evidence requirements to each eligible bidder.
- Evaluate evidence consistently. Score only proposals that pass mandatory criteria; verify claims through contract terms, demonstrations, security documentation, and sample reporting.
- Validate the operating model. Test payment, refund, settlement matching, exception handling, reporting, and data export with the staff who will perform those tasks.
- Complete reviews and contract controls. Obtain procurement, counsel, finance, IT, security, and program approval, then preserve explicit service, security, pricing, and exit commitments in the agreement.
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