PRAC Update Top Challenges in Pandemic Relief and Response

Summary

Update: Top Challenges in Pandemic Relief and Response, a Pandemic Response Accountability Committee report dated February 3, 2021, revisiting its June 2020 management challenges report. The PRAC adds four new challenges: preventing and detecting fraud against government programs, informing and protecting the public from pandemic-related fraud, data transparency and completeness, and federal workforce safety. It states that within 14 days of the PPP's April 3, 2020 launch lenders approved more than 1.6 million PPP loans totaling nearly $342.3 billion, and identifies self-certification and lack of due diligence into applicants as two primary fraud risks. It reports that as of December 2020 the Department of Justice had initiated 66 criminal fraud investigations involving over $250 million in PPP loans.

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UPDATE
Top Challenges in Pandemic
Relief and Response
FEBRUARY 3, 2021

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Contents
3
 Background
4
Ne
w
 Challenge: Preventing and Detecting Fraud against G
overnment Programs
6
Ne

w Challenge: Informing and Protecting the Public
from Pandemic-Related Fraud
8
New Challenge: Data Transparency and Completeness
10
New Challenge: Federal Workforce Safety
13
Updates to Previously Identified Challenges
13
Challenge: Financial Management of Relief Funding
14
Challenge: Grants and Guaranteed Loan Management
15
Challenge: IT Security and Management
16
Challenge: Protecting the Health and Safety of the Public
17
 Acronyms
18
Appendix A: Special Inspector General for Pandemic Recovery
19
Appendix B: Management Challenges

—Select Offices of Inspectors
General

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Background
Since the beginning of the COVID-19
pandemic, the federal government has spent
over $3 trillion1 to address the public health
and economic crises. Given the amount of
funding at issue, the need to distribute aid
quickly, and the use of grants and loans to
disburse funds, effective management of
the pandemic response programs presents a
significant challenge to many executive branch
agencies. Moreover, these same factors
increase the risk of fraud and misuse of the
funds.
To help provide oversight of those funds,
Congress created the Pandemic Response
Accountability Committee (PRAC) within the
Committee of the Council of the Inspectors
General on Integrity and Efficiency (CIGIE).2
The PRAC is composed of Inspectors General
identified by Congress, Inspectors General
designated by the Chairperson of the
Committee, an Executive Director, a Deputy
Executive Director, and staff. The PRAC leads
the efforts of CIGIE and its Inspectors General
to promote transparency and support and
conduct oversight of the pandemic response
funds.
In June 2020, the PRAC released its first
Management Challenges report, titled
Top Challenges Facing Federal Agencies:
COVID-19 Emergency Relief and Response
Efforts. This report provides insight into the
top management challenges submitted to the
PRAC by 37 Offices of Inspector General (OIGs)
for agencies that received emergency funds
or were involved in the pandemic response.
The PRAC summarized the challenges by
broad issue categories to identify common
themes and key areas of concern. While many
challenges varied from agency to agency, the
analysis identified common concerns across
agencies despite their different sizes and
missions. The challenges included:
• Financial Management of Relief Funding
Grants and Guarant

eed Loan
Management
IT Security and Management
Protecting Health and Safety
•
•
•
Given the changing nature of the pandemic
and the federal government’s response,
we re-visited our original top management
challenges to ensure that the PRAC is
providing timely information to Congress and
the Administration about the response efforts.
To prepare our update, the PRAC reached back
out to OIGs from more than 40 agencies that
received emergency funds or were involved
in the pandemic response and reviewed
Management Challenges reports issued by
OIGs since March 2020. As a result, the PRAC
is adding four new management challenges
and modifying an existing management
1 The more than $3 trillion in pandemic response funds
includes those funds authorized under the new Coronavirus
Response and Relief Supplemental Appropriations Act as well
as the Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020; the Families First Coronavirus
Response Act; the Coronavirus Aid, Relief, and Economic
Security Act; and the Paycheck Protection Program and Health
Care Enhancement Act.
2 The PRAC was established in March 2020 by the Coronavirus
Aid, Relief, and Economic Security Act (Public Law 116-136).

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challenge—protecting health and safety. The
following challenges have been added:
•  Pre

venting and Detecting Fraud against
Government Programs
•  Inf

orming and Protecting the Public from
Pandemic-Related Fraud
•  Data Transparency and Completeness
•  Federal Workforce Safety
The following provides greater detail on the
new Management Challenges and updates the
existing Management Challenges.3
New Challenge:
Preventing and Detecting Fraud against Government Programs
With the unprecedented amount of disaster
response funds appropriated (over $3 trillion
as of January 2021) to support the country’s
pandemic response, the opportunities for
defrauding government programs have
significantly increased. Bad actors have
fraudulently obtained federal funds through
the Pandemic Unemployment Assistance
program, the Paycheck Protection Program
(PPP) loan program, and the Economic Injury
Disaster Loan (EIDL) program, to name a few.
In addition, the urgency with which funds are
being disbursed increases the fraud risk.
For example, the Small Business
Administration (SBA) launched the Paycheck
Protection Program—a new federal program—
on April 3, 2020, and within 14 days lenders
approved more than 1.6 million PPP loans
totaling nearly $342.3 billion. At the same
time, SBA received more COVID-19 relief EIDL
loan applications and approved and disbursed
more EIDL loans than for all other disasters
combined since the agency was founded in
1953. As the SBA OIG reported, to get EIDL
funds to eligible entities quickly, SBA “lowered
the guardrails” by removing or weakening
internal controls.
The Coronavirus Aid, Relief, and Economic
Security Act (CARES Act) provided a substantial
increase in unemployment insurance program
funds—approximately $400 billion. The
Department of Labor (DOL) OIG has reported
that DOL did not intend to measure CARES Act
unemployment insurance program improper
3 CIGIE plans to issue its Top Management and Performance
Challenges Across Multiple Agencies report in February 2021.
Three of the challenges identified in the CIGIE management
and performance challenges report are also discussed in
this report and the direct impact to those challenges by the
COVID-19 pandemic.

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payments because department management
considered the funding an episodic, temporary
program.
Federal managers have primary responsibility
for reducing fraud risks and ensuring
program integrity. However, the Government
Accountability Office has reported that federal
managers, in a post-disaster environment
like a global pandemic, have a higher risk
tolerance for making payments to potentially
fraudulent applicants if the managers assess
that the individual has been more negatively
impacted than other individuals. The Office
of Management and Budget (OMB) reminded
agencies in its implementation guidance for
COVID-19 funding, M-20-21, of management’s
responsibility for “balancing the need for
expediency with steps to mitigate risk of fraud,
waste, abuse and improper payments”
When fraud risks can be identified and
mitigated, agencies may be able to improve
fraud prevention, detection, and response.
As such, to help programs detect and prevent
fraud, the Fraud Reduction and Data Analytics
Act requires federal agencies to complete
fraud risk assessments.
OIG oversight work to date has identified
two primary fraud risks associated with the
administration of pandemic response funds:
self-certification of eligibility and lack of due
diligence by the agencies into applicants.
Self-certification.
accurate. Work completed by the OIGs at the
DOL and SBA found that self-certification
served as the sole or a significant control for
pandemic response programs that facilitated
billions of taxpayer dollars to be disbursed
improperly. Specifically, DOL OIG previously
identified self-certification as a top fraud
vulnerability for the pandemic unemployment
assistance program, putting $26 billion4
in taxpayer funds at a higher risk of fraud
and improper payment. Relying solely on
self-certification to demonstrate applicants’
eligibility created a high fraud risk vulnerability,
evidenced by numerous publicly announced
investigations involving high-dollar loan fraud
and multi-victim identity theft schemes.
Lack of Due Diligence into Applicants. In
an effort to increase the speed of disbursing
relief funding, federal agencies and banks
did not conduct full due diligence checks to
ensure that the information, such as social
security numbers or business registration
date, submitted by applicants were correct.
An analysis of virtually every PPP loan fraud
investigation shows the same pattern: the
defendants submitted false business records,
payroll documents, or tax records to lenders
in an attempt to fraudulently obtain the
loans. In certain instances, the false records
contained business formation dates that
made the businesses eligible when, in fact,
the businesses were formed after the eligibility
date. As of December 2020, the Department
of Justice had initiated 66 criminal fraud
investigations involving over $250 million in
PPP loans.
4 DOL OIG has previously estimated an improper payment rate
of 10 percent for unemployment insurance programs. Under
the CARES Act, the Department of Labor received $260 billion
to expand unemployment insurance benefits. Assuming the
improper payment rate continues above 10 percent, at least
$26 billion in expanded unemployment benefits could be paid
improperly.

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While the PRAC recognizes the need to
disperse funds quickly, it is imperative
that federal agencies put in place better
controls to safeguard taxpayer dollars and
prevent improper payments. Failing to heed
the lessons learned in the implementation
of the CARES Act will result in increased
fraud and more dollars diverted from those
desperately awaiting economic relief.
Congress strengthened some controls for the
unemployment assistance program in the
December 2020 coronavirus supplemental
appropriations.5 However, additional oversight
work needs to be conducted to determine the
effectiveness of these controls.
Related Oversight Products. Visit our
website, PandemicOversight.gov, for a list of
all products related to fraud prevention and
detection as well as fraud resources related to
pandemic response.
New Challenge:
Informing and Protecting the Public
from Pandemic-Related Fraud
Not only has the amount of fraud against the
government increased during the pandemic,
but Americans are being targeted in greater
numbers by dishonest people taking
advantage of the crisis to harm individuals and
businesses through scams and harassment.
Various federal agencies are tasked with
appropriately informing and protecting the
public about pandemic-related fraud and
scam attempts, as well as helping them to
understand how and when to file a complaint.
Protecting Identities. With numerous
data- system breaches in the last few years,
identity theft is on the rise and has been
exploited by bad actors to obtain pandemic
response funds, such as unemployment
insurance benefits, PPP loans, and EIDLs. For
example, on December 16, 2020, a woman
pleaded guilty to a federal criminal charge for
fraudulently obtaining more than $500,000
in pandemic-related unemployment benefits
through the use of stolen personal identifiable
5 The Continued Assistance for Unemployed Workers Act
of 2020—which is part of the Consolidated Appropriations
Act, 2021—strengthened internal controls for pandemic
unemployment assistance program extension, requiring
individuals to provide documents substantiating employment
or self-employment status and to recertify eligibility every week
as well as requiring states to have procedures to verify the
identity of applicants to the extent reasonable and applicable.

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information, such as dates of birth and social
security numbers. The woman had purchased
personally identifiable information on the
dark web and watched YouTube videos that
provided instructions on how to commit
unemployment insurance fraud in California.
Protecting Patients. During the pandemic,
it is especially critical that Americans have
access to medical care and understand the
best and safest way to get care. However,
fraud alerts issued by OIGs and law
enforcement entities highlight numerous fraud
schemes that target patients and health care
beneficiaries. For example, some medical labs
targeted retirement communities claiming
to offer COVID-19 tests, only obtained blood
samples, and then, falsely billed health
care programs for their services.6 In another
example, fraudsters hacked social media
accounts to obtain individuals’ personal
information and personal health information in
order to commit medical insurance fraud.7
Protecting Consumers. OIG oversight has
found that programs intended to help protect
the public and consumers have been stressed
by the increase in complaints received and
the additional responsibilities associated with
administering pandemic response-related
programs. In addition, OIG work has continued
to identify instances when unscrupulous
actors have used misleading information for
financial gain, such as enticing individuals
and businesses to purchase defective or
ineffective personal protective equipment or
to pay for advanced access to the COVID-19
vaccine. For example, the Consumer Financial
Protection Bureau, which collects consumer
complaints to help inform the agency’s
supervision activities for financial institutions,
has experienced an increase in consumer
complaints due to the pandemic and faces
operational risk with respect to the timeliness
of its response to those complaints.
Protecting Homeowners and Renters.
The CARES Act provided financial relief
to homeowners and renters experiencing
pandemic-related hardships, to include
allowing forbearance of mortgage payments
for up to 360 days and placing a 120-
day moratorium on eviction filings. These
protections were designed to alleviate the
economic and public health consequences
of homeowner and tenant displacement
during the COVID-19 outbreak. The challenges
in implementing these programs focus on
ensuring that homeowners and renters are
aware of their rights and relief options, and
that servicers and landlords provide consistent
and accurate information, including all
available relief options.
In response to the increase in scams on
the American public, Congress enacted the
Combating Pandemic Scams Act of 2020 on
December 17, 2020. The Act requires the
Federal Trade Commission to develop and
disseminate information to the public about
mail, telemarketing, and internet scams
related to COVID-19, as expeditiously as
possible. The Act requires the scam alerts to
include information about the most common
scams and how to report or file a complaint.
6 Department of Health and Human Services OIG, COVID-19
Fraud Alert, last updated on December 21, 2020.
7 Federal Bureau of Investigation (FBI), FBI Warns of Potential
Fraud in Antibody Testing for COVID-19, June 26, 2020.

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The issuance of timely fraud alerts and
bulletins that are widely accessible to the
public as well as proper processing of
complaints about scams and harassment
during the pandemic will be essential to
informing and protecting the public from
unscrupulous individuals or enterprises.
Related Oversight Products and Information.
OIG partners and the PRAC continue to
release fraud alerts and fraud bulletins to
help educate individuals and businesses,
these alerts can be found on our website,
PandemicOversight.gov. In addition, a list of
all oversight products related to informing and
protecting the public from fraud can be found
on our Reports Library website.
New Challenge:
Data Transparency and Completeness
Federal program management guidance
highlights the need for and use of performance
information data to help drive decision making
and assess program effectiveness. OMB
has released controller alerts8 to encourage
better data quality and controls, but gaps in
pandemic-related data remain. Reports issued
by OIGs from March through December 2020
and a PRAC report, issued in November 2020
on data completeness and transparency gaps,
find that policy makers, senior leaders, and
program managers do not have access to
all the data needed to inform program and
funding decisions for their pandemic response
programs. Specifically, the data completeness
and transparency report commissioned by
the PRAC—Transparency in Pandemic-Related
Federal Spending: Report of Alignment and
Gaps—confirmed that while existing data
satisfies a substantial portion of the CARES
Act transparency requirements for pandemic
relief funds, 16 key gaps in existing data
sources related to completeness, accuracy,
and timeliness may impair the PRAC’s ability
to provide full transparency for all pandemic-
related spending. The report identified 13
actions to mitigate these gaps, ranging from
relatively minor changes to more complex
corrective actions that may require new
policy, legislation, or information technology
8 For example, OMB released Controller Alert: Award
Description Data Quality for Financial Assistance Awards on
August 18, 2020 noting that it is particularly important for
agencies to review the data controls they have in place for
providing transparent spending information to the public.
These alerts are intended to provide information and are not
official guidance.

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(IT) system modifications. In addition, OIGs
identified the following examples as areas of
concern related to pandemic response data.
Limited Demographic Data for Pandemic
Response Programs. The CARES Act requires
that small business concerns in underserved
and rural markets receive priority for PPP
loans; however, the SBA OIG found that the
SBA did not collect the required demographic
data to determine if the loans went to the
intended prioritized markets. In addition,
while data collected by the Centers for
Disease Control and Prevention suggests a
disproportionate burden of COVID-19 cases,
hospitalizations, and deaths among racial
and ethnic minority groups, the Government
Accountability Office identified gaps in this
data.
Incomplete or Missing Coronavirus Relief
Fund Data. The Department of the Treasury
OIG identified challenges surrounding the
completeness and transparency of the
Coronavirus Relief Fund data submitted by its
prime recipients.
Incomplete COVID-19 Testing Data for
Select Federal Health Programs. PRAC’s
data report on COVID-19 testing for six federal
health programs highlighted the importance
of agencies having complete, timely, and
accurate data to help ensure efficient testing
and to detect gaps or vulnerabilities in their
testing efforts. For example, a lack of data on
test turnaround time raised questions about
how the timeliness of processing tests affects
patient care, program integrity, and oversight
activities.
Inaccurate Pandemic Response Procurement
Data. The Department of the Interior OIG
identified instances where purchase card and
contract payments were erroneously recorded
as using pandemic response funds, and $10.5
million in procurements were not properly
classified as pandemic response funds in the
Federal Procurement Data System.
Delayed Data Matching and Controls. The
Railroad Retirement Board OIG identified
delayed data matching and a lack of internal
controls at the Railroad Retirement Board
related to CARES Act payments.
Without complete and accurate data, senior
leaders and program managers are limited
in their ability to make informed funding
decisions, to determine if the pandemic
response program is achieving its goals, and
to make needed program adjustments. In
addition, incomplete data limits the ability of
federal programs to provide full transparency
over pandemic response expenditures to the
public.
Related Oversight Products.
PRAC, COVID-19 Testing Insights from Select
Federal Health Programs, January 14, 2021
SBA OIG, Inspection of SBA’s Implementation
of the Paycheck Protection Program, 20-17,
January 14, 2021
PRAC, MITRE Report: Transparency in
Pandemic-Related Federal Spending: Report
of Alignment and Gaps, November 19, 2020

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Government Accountability Office, COVID-19:
Federal Efforts Could Be Strengthened by
Timely and Concerted Actions, GAO-20-701,
September 21, 2020.
For a list of all Data Completeness and
Transparency related products, visit our
Reports Library website.
New Challenge:
Federal Workforce Safety
Federal offices have remained open with
limited in-person operations throughout
the pandemic and have been reopening
at different rates based upon the type of
emergency or essential work activities
completed by the agency, such as intelligence
oversight and food inspections, as well as
local environments and infection rates. With
the approval of the COVID-19 vaccines9
and the subsequent rollout to the public, it
is anticipated that more federal offices will
begin their reopening phases and expand
the number of employees allowed in their
buildings.
For those offices that maintained in-person
operations during the pandemic, OIGs
identified best practices for federal workforce
safety that included:
•  W
o rk "neighborhoods" within a facility to r
educe expso ure between work units.
•  Re gular, clear communication from senior l
eaders about changes or updates to a
gency guidance and agency operational p
lans.
•  Critical information available to staff in a
centralized manner.
Use of personal protective equipment.
COVID-19 screening prior to entry.
•
•
However, many federal agencies have
faced challenges implementing reopening
procedures. For example, the General
Services Administration’s Public Building
Services did not consistently receive
timely notice of COVID-19 incidents from
CLEAR COMMUNICATION
From Senior Leaders about Changes or
Key Updates Identified as a Best Practice
9 The first COVID-19 vaccination was administered in the
United States on December 14, 2020.

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building occupants and did not consistently
provide timely notification of confirmed
COVID-19 cases. In addition, because Public
Building Services does not have a standard
inspection process for COVID-19 cleaning
and disinfection services, it does not have
assurance that contractors are cleaning
and disinfecting employee workspace. In
addition, work completed by OIGs found
differing guidance and implementation of
policies related to facial coverings; personal
protective equipment; social distancing;
cleaning and disinfecting; contact tracing
programs; and employee health screenings at
federal agencies. In addition, one OIG found
that the agency’s plans did not address anti-
retaliation for raising health-related concerns
with management, as recommended under
the DOL’s Occupational Safety and Health
Administration guidance.
As federal agencies make plans for returning
to in-person work, they will continue to face
challenges in ensuring a safe environment
and healthy workforces during the pandemic.
Clear communication with employees and
incorporation of guidance from the Centers
for Disease Control and Prevention and
from the Occupational Safety and Health
Administration, coupled with concepts from
the Return to Workplace Strategy Book—issued
by the General Services Administration in
September 2020, and best practices identified
by other federal agencies, will help to mitigate
risks to employee safety.
The Executive Order signed on January 20,
2021, and the corresponding OMB memo
(M-21-15) required masks and distancing
consistent with current Centers for Disease
Control and Prevention guidance in all federal
buildings, and created the Safer Federal
Workforce Task Force to provide ongoing
guidance to the heads of agencies on the
safety of the federal workforce and continuity
of operations during the COIVD-19 pandemic.
Federal agency compliance with the order
and memo guidance will need to be assessed
through future oversight work.
Related Oversight Products.
Department of Defense OIG, Audit of the
Disinfection of Department of Defense
Facilities in Response to the Coronavirus
Disease–2019, DODIG-2021-036, December
18, 2020
Environmental Protection Agency OIG, EPA’s
Initial Plans for Returning to the Office
Incorporate CDC Guidance but Differ by
Location, 21-E-0030, November 30, 2020
U.S. Postal Service OIG, Employee Safety-
Postal Service COVID-19 Response, 20-259-
R21, November 20, 2020
National Reconnaissance Office OIG,
Final Report: Evaluation of the National
Reconnaissance Office’s COVID-19 Pandemic
Response, October 13, 2020

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Department of the Interior OIG, CARES
Act Flash Report: The Bureau of Safety
and Environmental Enforcement’s Safety
Inspection Program COVID-19 Response,
2020-CR-047, September 21, 2020
General Services Administration OIG, Alert
Memorandum: Concerns Regarding PBS’s
Communication and Cleaning Procedures
for Coronavirus Disease 2019 (COVID-19)
Exposures, A201018-2, September 3, 2020
For a list of all products related to federal
workforce safety, visit our Reports Library
website.

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10 The top management challenges report to be issued by
CIGIE—Top Management and Performance Challenges Facing
Multiple Federal Agencies—identified Financial Management
as a top challenge for the federal government.
Updates to Previously Identified Challenges
The PRAC identified the following four
management challenges in its first
management challenges report, issued in June
2020. This update provides a brief description
of those challenges. For a more detailed
explanation of each challenge, see Top
Challenges Facing Federal Agencies: COVID-19
Emergency Relief and Response Efforts.
Challenge:
Financial Management of Relief Funding
Even in non-pandemic times, financial
management controls and proper oversight
of government contracts pose a challenge
to federal agencies and programs. The
substantial increase in funding for certain
programs and an expedited timetable for
the distribution of CARES Act and other
pandemic-related funds heightens the risks.
Since the pandemic began in March 2020,
OIGs have found that payments have been
made without the appropriate checks and
controls in place to verify the expenditures. In
addition, OIGs have identified contracts that
have been noncompetitively awarded due to
the exigent circumstances, contracts that pose
potential conflicts of interest, and contractors
that have not delivered products (such as
cleaning supplies) by the specified due dates.
Further, federal agencies may face challenges
maintaining their current capabilities while
balancing their commitments to contractors
who are unable to fulfill existing requirements
due to COVID-19 restrictions. As the pandemic
continues, federal agencies must continue
to ensure they get what they pay for in their
pandemic response-
related contracts as
well as guard against
fraud and improper
payments.
Related Oversight Products. For a list of
all Financial Management of Relief Funding
related products, visit our Reports Library
website.10
$
$22.8 BILLION
Pandemic-Related
Contracts

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Challenge:
Grants and Guaranteed Loan Management
The CARES Act and related legislation rely
on grants and loans to distribute assistance
to state and local governments, individuals,
businesses, and other entities impacted by
the pandemic. Like the challenges in financial
management, the substantial increases
in funding for grants under the CARES Act
and related legislation heighten the existing
challenges agencies face in processing and
monitoring these payments, and in assessing
their success. Adding to these challenges,
OMB issued multiple guidance documents
authorizing temporary spending flexibilities
for pandemic funding that greatly expanded
the allowable uses of grant funds. Key areas
of concern cited
by OIGs included
overseeing the
use of grant funds,
obtaining timely
and accurate financial and performance
information from grantees, and assessing
performance to ensure that grants achieve
intended results.
For example, one OIG had concerns about
grantees’ capacity to manage and spend
pandemic funds in a timely manner, as
intended, and found that some of the
pandemic response funds had been awarded
to recipients previously designated as
“slow spenders.” Another OIG found that
the increase in pandemic funds represents
a considerable addition to normal grant
administration
and oversight
responsibilities.
The OIG found that
effective monitoring
and oversight will remain a challenge in the
months and years to come.
In addition, unprecedented challenges have
been interwoven with the administration
of guaranteed loans authorized under the
CARES Act, like the PPP and the EIDL program,
with the SBA attempting to balance prompt
economic relief with ensuring that the funds
went to the intended beneficiaries. As a result,
the SBA OIG identified potentially fraudulent
loans made to applications with differences in
bank account numbers, duplicate information,
or ineligible business registration dates.
Related Oversight Products. For a list of all
Grants and Guaranteed Loan Management
related products, visit our Reports Library
website.11
$117.9 BILLION
Pandemic-Related
Federal Assistance
$548 BILLION
Pandemic-Related
Guaranteed Loans
11 Similarly, the top management challenges report to
be issued by CIGIE—Top Management and Performance
Challenges Facing Multiple Federal Agencies—identified Grant
Management as a top challenge for the federal government.

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Challenge:
IT Security and Management
When federal agencies began implementing
OMB’s March 2020 guidance on maximum
telework flexibilities, IT staff and systems faced
increased demands to ensure networks could
support large numbers of employees working
remotely and provide reliable, stable ways to
communicate and access critical applications
and data. These issues remain a significant
challenge and are impacted by (1) widespread
reliance on maximum telework to
continue agency operations during
the pandemic, which has strained
agency networks and shifted IT
resources, and (2) additional
opportunities and targets for
cyber attacks created by remote
access to networks and increased online
financial activity. For example, multiple alerts12
were issued in 2020 about an increase in
cybersecurity risks during the pandemic,
including attacks to obtain personal health
information and pandemic loan-related
information.
Public health systems maintained by the
Department of Health and Human Services,
its partners and grantees are subject to an
increasing number of cybersecurity threats,
including a larger, distributed denial-of-service
attack that persisted for weeks during 2020.
In addition, federal agencies and banks
need to ensure that pandemic-loan related
information is secure because financial
institutions can be subject to cybersecurity
threats at a rate of 300
times more than most other
businesses.13
While some OIGs have found
that federal agencies have
experienced challenges related
to IT security and management,
other federal agencies have been able to
successfully provide vital functions to the
public, such as the Department of Veterans
Affairs taking important steps to transition
the Veterans Crisis Line to telework-based
operations over the course of six weeks.14
Related Oversight Products. For a list of all IT
Security and Management related products,
visit our Reports Library website.15
98%
Total Workforce
Teleworking at One
Federal Agency
12 Department of Homeland Security Alert, COVID-19 Exploited
by Malicious Cyber Actors, April 08, 2020; and FBI, FBI
Anticipates Rise in Business Email Compromise Schemes
Related to the COVID-19 Pandemic, April 6, 2020.
13 Federal Reserve Bank of New York Staff Report, Cyber
Risk and the U.S. Financial System:  A Pre-Mortem Analysis,
January 2020.
14 Department of Veterans Affairs OIG, Veterans Crisis Line
Challenges, Contingency Plans, and Successes During the
COVID-19 Pandemic, 20-02830-05, October 28, 2020.
15 The top management challenges report to be issued by
CIGIE—Top Management and Performance Challenges Facing
Multiple Federal Agencies—identified Information Technology
Security and Management as a top challenge for the federal
government.

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16
Challenge:
Protecting the Health and Safety of the Public
The COVID-19 pandemic has presented
significant and sustained challenges to the
delivery of healthcare worldwide. While federal
agencies always prioritize health and safety,
the COVID-19 pandemic has created a unique
challenge—namely, preventing transmission
of the virus in federal facilities that provide
regular services to the public, and in private
sector facilities regulated by the federal
government. Activities to protect the health,
safety, and well-being of the public are directly
impacted by the unique circumstances of
the various programs being supported by the
federal government. These programs include
protecting inmates
and detainees
at facilities
operated by the
Departments of
Justice, Homeland
Security, and the
Interior; tourists
at National
Parks, with some parks experiencing an
increase in visitors from September 2019 to
September 2020; and all individuals—patients,
consumers, and private sector workers—in
facilities regulated by the federal government,
including health facilities for veterans and the
military. The pandemic has also increased
the use of telehealth, which presents new
challenges for federal government health
providers to provide sufficient care and
promote the overall well-being of their
beneficiary population.
More broadly, the federal government has
a direct responsibility to facilitate the public
health and safety response to the COVID-19
pandemic. This includes mitigating the loss
of life and negative health consequences
associated with COVID-19 by facilitating
the safe delivery of testing and vaccination
supplies, all while continuing to operate a
range of programs and services.
Related Oversight Products. For a list of all
protecting the health and safety of the public
related products, visit our Reports Library
website.
1 in 20
Americans
Contracted
COVID-19 Since
Pandemic Began

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Acronyms
CARES Act
Coronavirus Aid, Relief, and Economic Security Act
CIGIE
Council of the Inspectors General on Integrity and Efficiency
COVID-19
Coronavirus Disease 2019
DOL

Department of Labor
EIDL

Economic Injury Disaster Loan
FBI

Federal Bureau of Investigation
IT

Information Technology
OIG

Office of Inspector General
OMB
Office of Management and Budget
PRAC
Pandemic Response Accountability Committee
PPP

Paycheck Protection Program
SIGPR
Special Inspector General for Pandemic Recovery
SBA

Small Business Administration

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18
Appendix A:
Special Inspector General for Pandemic Recovery
As part of the Pandemic Response Accountability Committee’s initial management challenges
report—Top Challenges Facing Federal Agencies: COVID-19 Emergency Relief and Response
Efforts—issued in June 2020, we highlighted specific management challenges identified by Offices
of Inspector General. However, the Special Inspector General for Pandemic Recovery (SIGPR) was
not operational until after the report’s issuance. As such, we have included the management
challenge identified by SIGPR in this update.
The Special Inspector General for Pandemic Recovery was established by Section 4018 of the
CARES Act. Under the CARES Act, the SIGPR conducts, supervises, and coordinates audits and
investigations of: (1) loans, loan guarantees, and other investments by the Secretary of the
Treasury under any program established by the Secretary under Division A of the CARES Act and
(2) the management by the Secretary of programs established under Division A of the CARES
Act.16
Double/Multiple Dipping of CARES Act Funds
Creating multiple programs resulting in multiple forms of financial support to a single individual
or entity may be sound policy, but this framework also increases the risk of fraud and abuse.
Questions have been raised about the potential for widespread double and triple dipping under
the CARES Act. It is not immediately obvious, for example, that an entity should receive both a
Paycheck Protection Program loan and a Payroll Support Program payment—two programs that
offer relief funds for the same payroll justification. Yet several entities have. Some of whom,
moreover, may arguably have had a third funding source available to them—the Department of the
Treasury’s direct loans under the CARES Act, Section 4003, or the Federal Reserve’s Main Street
Lending Program.
Monitoring and policing the multiple dipping of CARES Act funds creates unique challenges for
both the administering agencies and the relevant oversight entities. These challenges stem from
the need to identify, share, normalize, and analyze the relevant datasets.

For more information on the Special Inspector General
for Pandemic Recovery, visit https://www.sigpr.gov/.
16 All authority granted to SIGPR comes from the CARES Act and the Inspector General Act of 1978.

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Appendix B:
Management Challenges—Select Offices of Inspectors General
The following section provides a summary of pandemic-related challenges identified by Offices of
Inspectors General (OIGs) in their management challenges reports issued since March 2020. See
the full reports for more information about each challenge or office.
U.S. Agency for International Development OIG, Top Management Challenges Facing the
U.S. Agency for International Development in Fiscal Year 2021, November 13, 2020; and
Challenges the U.S. Agency for International Development Faces in Responding to the
COVID-19 Pandemic, July 17, 2020
The U.S. Agency for International Development OIG work highlights the unique challenges the U.S.
Agency for International Development faces delivering humanitarian assistance to those in need—
challenges that have been exacerbated by the coronavirus disease 2019 (COVID-19) pandemic.
These challenges include managing risks to humanitarian assistance amid a public health
emergency; maintaining responsibilities for planning, monitoring, and sustaining development;
maximizing stakeholder coordination for a global COVID-19 response; and addressing
vulnerabilities and implementing needed controls in core agency management functions.
Amtrak OIG, Amtrak: Top Management and Performance Challenge for Fiscal Year 2021, OIG-
SP-2021-002, October 23, 2020
Amtrak OIG’s management challenges report stated that this year the challenge of responding
to the COVID-19 pandemic supersedes and permeates the company’s ability to address all
other challenges, especially the challenge of reducing pandemic-related risks to employees and
passengers. Until a vaccine or cure mitigates the threat of COVID-19, ensuring safety from the
virus will continue to complicate all the company’s other safety initiatives and operations.
Department of Agriculture OIG, U.S. Department of Agriculture Management Challenges,
September 28, 2020; and U.S. Department of Agriculture Management Challenges for
Pandemic-Related Responsibilities, June 15, 2020
Both management challenges reports issued by the U.S. Department of Agriculture OIG in 2020
identify challenges faced by the U.S. Department of Agriculture in its administration of more than
$34 billion in pandemic response funding. These challenges include collecting sufficient and
reliable data to assess the safety of its inspectors and the food supply chain, as well as to assess
overall program effectiveness. In addition, the U.S. Department of Agriculture should focus its
efforts on strengthening internal controls to decrease the number of improper payments and to

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ensure that assistance funds are delivered and used as intended. Given that the U.S. Department
of Agriculture relies on states to implement and deliver its food assistance programs, the U.S.
Department of Agriculture needs to provide effective oversight to the states to ensure that funding
is used as intended.
Department of Commerce OIG, Top Management and Performance Challenges Facing the
Department of Commerce in Fiscal Year 2021, OIG-21-003, October 15, 2020
In its management challenges report, the Department of Commerce OIG stated that in the midst
of the COVID-19 pandemic, the Department of Commerce faces an additional set of oversight
challenges to ensuring that CARES Act funds are timely and appropriately spent. These include
ongoing disaster relief efforts as well as award monitoring and file management challenges. In
addition, the Department of Commerce OIG highlighted the additional challenges and impacts on
completing the 2020 census and other Department of Commerce programs.
Council of the Inspectors General on Integrity and Efficiency, Top Management and
Performance Challenges Across Multiple Federal Agencies, [To be Issued: February 2021]
The Council of the Inspectors General on Integrity and Efficiency issued an update to its
management and performance challenges report which identifies seven total challenges—one
of which is specific to Homeland Security, Disaster Preparedness, and COVID-19. The report also
notes that several Inspectors General identified the COVID-19 pandemic as a challenge their
agencies faced in the past year and looking forward. Specifically, the report notes that COVID-19
complicated some agencies’ efforts to manage finances, complete procurements, or distribute
grants.
Department of Defense OIG, Fiscal Year 2021, Top Department of Defense Management
Challenges, October 15, 2020
The Department of Defense OIG’s management challenges report discusses the impact of the
pandemic on overall operations and the readiness of Department of Defense personnel. The
pandemic has also stressed supply chains and challenged the Department of Defense’s ability to
maintain the readiness of its stockpiles, impacting the health, safety, and security of Department
of Defense personnel and their families. In addition, the Department of Defense has provided
unprecedented levels of remote access and telecommunication capabilities to support maximum
teleworking and facilitate remote network connections. Further, the COVID-19 pandemic has
directly impacted resourcing decisions.

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21
Department of Education OIG, FY 2021 Management Challenges Facing the U.S. Department
of Education, November 30, 2020
The Department of Education OIG found that the funding and authority provided under the CARES
Act (including the use of waivers of statutory and regulatory requirements) posed new challenges
for the Department of Education to effectively oversee and monitor new grant programs and
additional Federal education funds, implement additional student financial assistance program
requirements and ensure that quality data is reported. While the CARES Act provided additional
funds for student aid and program administration, the Department of Education must timely and
effectively design and implement these processes to help ensure the overall success of its CARES
Act activities.
Department of Health and Human Services OIG, 2020 Top Management and Performance
Challenges Facing the Department of Health and Human Services, November 2020
The Department of Health and Human Services OIG highlighted the unprecedented challenges
the Department of Health and Human Services faces because of the emergence of COVID-19. As
the lead Federal agency for medical support and coordination during public health emergencies,
the Department of Health and Human Services has numerous significant responsibilities to assist
communities throughout the United States to prepare for, respond to, and recover from the fast-
moving COVID-19 pandemic. The Department of Health and Human Services’ responsibilities
include working with federal, state, tribal, local, and international governments to effectively
respond; supporting the development of vaccines, treatments, and other research on COVID-19;
assisting the health care system by providing flexibility, resources, and funding; ensuring the safety
of the health care workforce; and protecting the health and well-being of the public.
Department of Homeland Security OIG, Major Management and Performance Challenges
Facing the Department of Homeland Security, OIG-21-07, November 10, 2020
The Department of Homeland Security OIG identified “Performing Fully and Effectively during
COVID-19” as one of the most serious management performance challenges facing the
Department of Homeland Security and relates to every aspect of the Department of Homeland
Security’s mission. Within this challenge, the Department of Homeland Security OIG has previously
raised concerns about the Department of Homeland Security’s ability to purchase pandemic
preparedness supplies and to manage its stockpile of personal protective equipment and antiviral
countermeasures. In addition, the management challenges report raises concerns about the
heightened risk of exposure to COVID-19 certain Department of Homeland Security components
staff face given the nature of their work, and detained individuals face due to the congregate
nature of the facilities.

UPDATE: TOP CHALLENGES IN PANDEMIC RELIEF AND RESPONSE  |  FEBRUARY 2021
22
Department of Housing and Urban Development OIG, Management and Performance
Challenges for Fiscal Year 2021, November 25, 2020
The Department of Housing and Urban Development OIG added two challenges this year, one of
which focused on the Department of Housing and Urban Development’s response to the COVID-19
pandemic. The management challenge report notes that the Department of Housing and Urban
Development, like all Federal agencies, was challenged initially with implementing the substantial
program changes required by the CARES Act and communicating to the public and program
administrators about those changes during a rapidly evolving pandemic that required nearly all
staff to work remotely. Additionally, the pandemic presented new challenges for the Department
of Housing and Urban Development and its program participants in implementing necessary
changes to their programs’ operations. The Department of Housing and Urban Development OIG
expressed concerns that the pandemic will exacerbate the existing management challenges.
Department of Justice OIG, Top Management and Performance Challenges Facing the
Department of Justice–2020, October 16, 2020; and Pandemic Response Report: COVID-19
Challenges for the U.S. Department of Justice, 20-072, June 17, 2020
Department of Justice OIG determined that the most immediate challenges to Department of
Justice operations involved preventing the spread of the virus among its approximately 170,000
federal inmates and 61,000 detainees in Bureau of Prisons and U.S. Marshals Service custody,
respectively; operating its immigration courts in a manner that minimizes the risk to participants;
and ensuring robust oversight of $850 million in pandemic-related CARES Act grant funding being
disbursed by Department of Justice to fund state, local, and tribal efforts to combat COVID-19—all
while also protecting the health and safety of the tens of thousands of employees who oversee
these particular operations.
Department of the Interior OIG, Inspector General’s Statement Summarizing the Major
Management and Performance Challenges Facing the U.S. Department of the Interior,
FY 2020, 2020-ER-043, November 12, 2020
The Department of the Interior OIG found that the Department of the Interior has faced challenges
in continuing to fulfill its mission during the COVID-19 pandemic, including providing expedient
assistance to vulnerable populations while ensuring the money reaches intended recipients
for intended purposes; balancing public and employee safety with access to public lands; and
guarding against increasing cybersecurity threats

UPDATE: TOP CHALLENGES IN PANDEMIC RELIEF AND RESPONSE  |  FEBRUARY 2021
23
Department of Labor OIG, Top Management and Performance Challenges Facing the U.S.
Department of Labor, November 2020
The Department of Labor OIG determined that the Department of Labor continues to face
challenges in ensuring unemployment insurance improper payments are timely and accurately
detected, prevented, and reported. The Department of Labor also needs to continue its work with
states to identify and implement strategies designed to reduce the unemployment insurance
program’s improper payment rate, including sharing best practices identified by states. In
addition, the Department of Labor OIG identified that the Department of Labor faces challenges
in determining how to best use its resources to help protect the safety and health of workers,
particularly in high-risk industries, such as health care, meat packing, agriculture, construction,
fishing, forestry, manufacturing, and mining. This challenge has been exacerbated by the current
COVID-19 pandemic and the limitations imposed on traditional inspection or investigation
activities.
Department of Transportation OIG, Department of Transportation’s Top Management
Challenges, FY 2021, October 21, 2020
The Department of Transportation OIG’s management challenges report identified key challenges
related to awarding pandemic relief and other Department of Transportation contracts and grants
efficiently, effectively, and for intended purposes, and enhancing contract and grant management
and oversight to achieve desired results and compliance with requirements.
Department of the Treasury OIG, Management and Challenges Facing the Department of the
Treasury, OIG-CA-21-006, October 29, 2020
The Department of the Treasury OIG’s management challenges report recognized the need for the
Department of the Treasury to continue to navigate through its COVID-19 response, administer
the Coronavirus Relief Fund, and prepare for another fast-paced relief package, if legislated.
Going forward, the Department of the Treasury may experience difficulties in balancing its new
responsibilities and workloads while managing several other ongoing challenges identified by the
Department of the Treasury OIG.
Environmental Protection Agency OIG, FYs 2020-2021 U.S. Environmental Protection Agency
Top Management Challenges, 20-N-0231, July 21, 2020
The Environmental Protection Agency OIG management challenges report focuses on the need
to provide a safe workplace and execute a safe return to the workplace. The Environmental
Protection Agency OIG also raises the procurement of personal protective equipment and
provisions as a concern. Further, cybersecurity is identified as a continuing challenge that has
become more critical during the COVID-19 pandemic with the need to support a primarily virtual
workforce.

UPDATE: TOP CHALLENGES IN PANDEMIC RELIEF AND RESPONSE  |  FEBRUARY 2021
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National Aeronautics and Space Administration OIG, 2020 Report on the National Aeronautics
and Space Administration’s Top Management and Performance Challenges, November 12,
2020
The National Aeronautics and Space Administration OIG’s management challenges report
emphasized the management and mitigation of heightened, cybersecurity risk because the
National Aeronautics and Space Administration’s information technology infrastructure has seen
an uptick in cyber threats, with phishing attempts doubled and malware attacks exponentially
increasing during the COVID-19 pandemic.
National Science Foundation OIG, Management Challenges for the National Science
Foundation in Fiscal Year 2021, October 15, 2020
The National Science Foundation OIG found that COVID-19 brought new and unique challenges
across the Foundation, including (1) oversight of major multi-user research facilities; (2) managing
the Intergovernmental Personnel Act programs; (3) oversight of the Antarctic Infrastructure
Modernization for Science (AIMS) project; (4) increasing diversity in science and engineering
education and employment; (5) mitigating threats posed by foreign government talent recruitment
programs; and (6) oversight of grants during a pandemic. Grant oversight, for example, is more
challenging because of temporary spending flexibilities that greatly expanded the allowable
uses of grant funds. These temporary spending flexibilities combined with the fiscal challenges
universities are facing increase the risk of losing accountability of grant funds.
Office of Personnel Management OIG, Top Management Challenges: Fiscal Year 2021, October
16, 2020
The Office of Personnel Management continues to face challenges with the opioid and drug
abuse epidemic that affects Federal Employee Health Benefits Program members, with progress
potentially reversing because of the COVID-19 pandemic’s societal and health environment
ramifications. In addition, while the Healthcare and Insurance program office has been proactive
in working with Federal Employee Health Benefits Program health carriers to address issues
related to care in the pandemic, increased program integrity functions would further protect those
reliant on this insurance program from schemes and bad actors.
Peace Corps OIG, Fiscal Year 2020, Management and Performance Challenges, November 10,
2020
Peace Corps OIG’s management challenges report discusses the impact of the pandemic on
overall operations of the agency after suspending all Volunteer activities and evacuating nearly
6,900 Volunteers from approximately 60 countries of service. In resuming fully its overseas
Volunteer program, the agency faces tremendous challenges of planning and effectively

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implementing its plan to redeploy Volunteers worldwide while maintaining the health and safety of
the Volunteers and the communities they serve. Further, the systemic issues OIG has identified in
the areas of planning and implementation could impede the agency’s ability to effectively respond
to the unprecedented challenges presented by the pandemic.
Small Business Administration OIG, Top Management and Performance Challenges Facing the
Small Business Administration in Fiscal Year 2021, 21-01, October 16, 2020
The Small Business Administration (SBA) OIG found that managing the COVID-19 stimulus is the
greatest overall challenge currently facing the SBA. This crucial new challenge is exacerbated
by persistent management and performance challenges. The pandemic response has, in
many instances, magnified the challenging systemic issues in the SBA’s mission-related work.
During large-scale disasters, the SBA brings on new loan officers to match the volume of loan
applications, but it has been a challenge for the SBA to add significant numbers of staff and
provide them with the proper level of training.
Social Security Administration OIG, Fiscal Year 2020 Inspector General’s Statement on the
Social Security Administration’s Major Management and Performance Challenges, A-02-19-
50825, November 6, 2020
The Social Security Administration OIG identified Social Security Administration’s response to
the COVID-19 pandemic as a management challenge. The report states that in response to
the pandemic, and to ensure the safety of its customers and employees, the Social Security
Administration limited its field office operations to in-person service by appointment only for
certain dire need situations and maximized telework. The report further states that the Social
Security Administration needs to keep the public and its employees aware of: (1) how it plans to
provide customer service safely throughout the pandemic; and (2) the status of its efforts to return
all employees to work on-site and return to normal operations.

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PRAC Point of Contact
Brooke Holmes
Associate Director of Oversight and Accountability
Brooke.Holmes@cigie.gov
Visit our website at
https://PandemicOversight.gov
REPORT FRAUD, WASTE, ABUSE, AND MISMANAGEMENT
To report allegations of fraud, waste, abuse, or misconduct
regarding funds or programs covered within the following Acts,
please go to the PRAC website at PandemicOversight.gov.
CARES Act
Paycheck Protection Program and Health Care Enhancement Act
Families First Coronavirus Response Act
Coronavirus Preparedness and Response Supplemental Appropriations Act
Coronavirus Response and Relief Supplemental Appropriations Act, 2021
A Committee of the
Council of the Inspectors General
on Integrity and Efficiency
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@COVID_Oversight

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