When a cash assistance program fails, it rarely fails on eligibility rules alone. It fails in the last step: getting the right amount to the right person, quickly, with a record of what happened. The large-scale efforts of recent years, from Economic Impact Payments to emergency rental assistance, offer a detailed look at where that last step breaks down, and the public record on them is solid enough to learn from.
For agency, nonprofit, and program leaders, three questions come up repeatedly. Can the program reach people who do not have a bank account? Can it move money at the speed the need requires? And can it prove, afterward, that payments went where they should? This article takes each in turn, draws on findings from federal oversight and research sources, and lists what to ask any disbursement partner.
A note on scope: these programs were designed and run by governments, with state, local, and tribal grantees and a range of private-sector and nonprofit partners. The lessons below come from published oversight and research, not from any one vendor's experience.
Lesson 1: Reach Depends on the Delivery Method
Most recipients in a large program can be paid by direct deposit. The harder cases determine whether the program works for the people who need it most.
The FDIC's 2023 household survey found that 4.2 percent of U.S. households, about 5.6 million, were unbanked, and 14.2 percent, about 19.0 million, were underbanked. The same survey found that unbanked households used prepaid cards at a much higher rate than the general population, at 21.6 percent.
Those numbers are small as a share of households but large in raw numbers. A program that works well for banked recipients can still fail the households that need help most, especially when they have no account on file, and the program does not know where to send the money.
The takeaway for program design is to offer more than one way to receive funds and to plan for the recipients who are hardest to reach before launch, not after the first wave of payments.
Lesson 2: Speed Is an Administrative Capacity Problem
Speed is often treated as a technology question. The record suggests it is as much about staffing, data, and process.
The Government Accountability Office's review of the Emergency Rental Assistance program is a useful case. Treasury administered nearly $46.55 billion in funding to tribal, state, territorial, and local grantees. GAO reported that by June 2021, about one-quarter of grantees had not made any payments, and that grantees had spent less than half of their funds by the September 30, 2021 deadline for reallocating excess money. GAO pointed to limited staff and technology, difficulty gathering eligibility information from tenants, and unclear guidance as contributing factors.
The implication is that a faster payment channel helps only if the steps before it, intake, verification, and approval, are ready to feed it. Leaders evaluating a disbursement partner should ask how the platform fits into the program's existing intake and approval workflow, and how long implementation realistically takes.
Lesson 3: Data and Payment Integrity Need to Be Designed In
Speed and reach mean little if a program cannot show where the money went. The same GAO review found that Treasury was missing data on 26% of payments made to households in 2021, and that 2 percent of households served by the first appropriation received payments from more than one grantee, which suggests possible duplicate payments. GAO noted that Treasury's risk assessment had focused on grantee allocations and did not address the missing payment data or the possible duplicates.
GAO's December 2022 report made three recommendations, which Treasury agreed with: collect complete payment data, publish complete program data, and assess susceptibility to improper payments in more detail. GAO's page now lists all three as implemented, notes that Treasury completed a quantitative risk assessment in September 2024, and reports that Treasury closed out all awards under the Consolidated Appropriations Act, 2021 as of January 31, 2025. The findings above describe the program as it stood in 2021 and 2022. They concern one program and one period, and they do not show that all programs have the same gaps. They do show where reporting problems can arise when payments are made through many separate grantees.
For program managers, the practical lesson is to define data requirements at the start: what each payment record must contain, how duplicates are detected across channels, and how reporting reaches the oversight body.
Lesson 4: Electronic by Default, With Exceptions Built In
Federal policy has been moving toward electronic payments. A March 2025 executive order, Modernizing Payments To and From America's Bank Account, directed Treasury to stop issuing paper checks for federal disbursements beginning September 30, 2025, "to the extent permitted by law," and directed agencies to move to electronic methods such as direct deposit and prepaid cards. The order also requires procedures for limited exceptions, including individuals without access to banking or electronic payment systems and certain emergency payments where electronic disbursement would cause undue hardship, and says qualifying recipients must be given alternative payment options.
Implementation is still under way. In an April 2026 interview, a Bureau of the Fiscal Service official said the bureau disbursed more than 1.3 billion payments worth more than $6 trillion in fiscal 2025, 96% of them electronically, and reported a 30% reduction in check volumes so far that year. Treasury also pointed to alternatives for people without bank accounts, including Direct Express prepaid debit cards and digital wallets. The interview did not say how many payments remain on paper.
That structure, electronic by default with a defined exception path, is a useful model beyond the federal level. Program leaders should check how the order applies to their funding stream and their state's rules, and should confirm current details with counsel, since agency guidance on exceptions was still being published when these sources were written.
What Agencies and Nonprofits Should Ask a Disbursement Partner
The lessons above translate into criteria that can be verified during procurement:
- Multiple delivery options. Can recipients receive funds in more than one way, including a path for people without bank accounts?
- Implementation timeline. How long does onboarding take, and what does the program need to provide to meet it?
- Workflow fit. How does the platform connect to intake, eligibility, and approval systems?
- Record-keeping. What data does each payment record contain, and can reports be produced for auditors and oversight bodies?
- Duplicate and error controls. How does the platform detect duplicate payments and handle returned or failed payments?
- Recipient support. Who helps a recipient who cannot access funds, and how are issues resolved?
- Security and compliance. Which controls apply to a regulated organization moving money in real time, and how are they documented?
- Cost transparency. What costs apply to the program and to recipients, and are they disclosed in advance?
Putting the Lessons Into Practice
Before launch, program teams can turn these lessons into a short working plan:
- Map the recipient population. Estimate how many recipients are likely to lack a bank account or reliable contact information, and plan alternative delivery paths for them from day one.
- Define the payment record. Agree on the data each payment must carry, such as recipient identifier, amount, date, channel, and status, so reporting does not have to be reconstructed later.
- Plan for duplicates across channels. If several agencies, grantees, or partners can pay the same person, decide in advance how overlaps will be detected and resolved.
- Test the full path. Run a small pilot from intake through approval, payment, and reconciliation to find bottlenecks before volume arrives.
- Set up recipient support. Decide who answers questions about missing, delayed, or failed payments, and how quickly.
- Agree on oversight reporting. Confirm what auditors and funders will need and how often, then build those reports into the contract with the provider.
Why Organizations Choose Rellevate
Rellevate is a digital banking and disbursement solutions provider. Its proprietary digital banking platform is designed for secure, real-time money movement, and its disbursement solutions are built for organizations that need to make payments at scale. Rellevate also offers government disbursements for public-sector needs.
Program leaders can use the criteria above to evaluate Rellevate or any other provider against their own program requirements and applicable rules. Ask for specifics on delivery options, reporting, and implementation timing during procurement, and confirm them in writing.
The Bottom Line for Program Leaders
The record on large-scale cash assistance points to the same conclusions. Reach depends on offering more than one way to receive funds. Speed depends on the whole process, not only the payment channel. And integrity depends on data requirements set at the start. Programs that treat disbursement as a design decision, not a final step, are better placed to deliver on their purpose.
Learn how Rellevate's disbursement solutions help government agencies and nonprofits move money securely and keep clear records of every payment.
