GAO-24-107157, COVID-19: Insights and Actions for Fraud Prevention

PDF source document — GAO-24-107157, COVID-19: Insights and Actions for Fraud Prevention, dated 2023-11-14, issued by Government Accountability Office.

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COVID-19
Insights and Actions for
Fraud Prevention

Statement of Rebecca Shea,
Director, Forensic Audits and Investigative Service

Testimony
Before the Subcommittee on Emerging
Threats and Spending Oversight,
Committee on Homeland Security and
Governmental Affairs, U.S. Senate
For Release on Delivery
Expected at 2:45 p.m. ET
Tuesday, November 14, 2023
GAO-24-107157

United States Government Accountability Office

 United States Government Accountability Office

Highlights of GAO-24-107157, a testimony
before the Subcommittee on Emerging
Threats and Spending Oversight, Committee
on Homeland Security and Governmental
Affairs, U.S. Senate

November 14, 2023
COVID-19
Insights and Actions for Fraud Prevention
What GAO Found
Challenges that agencies faced in implementing COVID-19 relief programs
provide insights into fraud prevention for normal operations and future
emergencies. Specifically, understanding fraud schemes that emerged during the
pandemic can provide opportunities for program managers to identify internal
controls that had been circumvented and respond to mitigate the related risks.
Data and system challenges, such as limited data sharing, highlight the value of
data analytics for fraud prevention. Additionally, thoughtful program design
choices that consider fraud vulnerabilities can facilitate fraud prevention.
Insights from COVID-19 Relief to Inform Fraud Prevention
With strategic fraud risk management, agencies are better positioned to manage
fraud during normal operations and emergencies. Sources that provide additional
insight for fraud prevention include recommendations GAO has made to
agencies, actions GAO identified that Congress can take to strengthen fraud risk
management practices across the government, and resources GAO developed to
support strategic fraud risk management. Implementing these recommendations
and taking these actions, along with leveraging available resources, can enable
agencies to carry out their missions and better protect taxpayer dollars from fraud
during normal operations and prepare them to face the next emergency.
An Insight Based on GAO Resources and Recommendations to Agencies and Congress

View GAO-24-107157. For more information,
contact Rebecca Shea at (202) 512-6722 or
shear@gao.gov.
Why GAO Did This Study
Since March 2020, Congress and the
administration have provided trillions of
dollars in COVID-19 relief funding to
help the nation respond to, and recover
from, the pandemic. Agencies across
the federal government acted quickly
to stand up new programs and greatly
scale up existing programs.
While COVID-19 relief programs were
critical for assuring public health and
economic stability, they also created
unprecedented opportunities for fraud
due to the dollars involved and other
risk factors. While the full extent of
fraud associated with the COVID-19
relief funds will never be known with
certainty, estimates are in the
hundreds of billions. In light of what
was likely lost to fraud during the
pandemic, the importance of fraud
prevention cannot be stressed enough.
This testimony discusses (1) insights
for prevention from COVID-19 fraud;
and (2) recommendations, matters,
and resources for improving fraud
prevention in normal operations and
future emergencies.
GAO reviewed its prior COVID-19
findings and recommendations on
internal controls and fraud risk
management practices.
What GAO Recommends
As of August 2023, agencies needed
to take additional action to fully
address 95 GAO recommendations to
help ensure they are effectively
managing fraud risks. Additionally, in
March 2022, GAO identified 10 actions
Congress could take to strengthen
internal controls and financial and
fraud risk management practices
across the government. All 10 remain
open.

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GAO-24-107157
Chair Hassan, Ranking Member Romney, and Members of the
Subcommittee:
I appreciate the opportunity to discuss insights into fraud prevention
based on challenges that agencies faced in implementing COVID-19
relief programs, as well as what can be done to help prevent fraud in the
future.
Since March 2020, Congress and the administration have provided
trillions in COVID-19 relief funding to help the nation respond to and
recover from the pandemic. Agencies across the federal government
acted quickly to stand up new programs and greatly scale up existing
programs. Federal COVID-19 relief funds were distributed broadly to
tribal, state, local, and territorial governments; businesses; and individuals
to combat the effects of the pandemic on the public health system, as well
as the economy.
Most of these funds went to the intended recipients in the intended
amounts, providing needed assistance. For example, COVID-19 relief
funds provided needed assistance to unemployed workers and small
businesses. Timely payments from the Department of Labor’s (DOL)
unemployment insurance (UI) programs allowed unemployed workers to
address financial hardships, such as inability to pay for rent, utilities, and
groceries. The Small Business Administration’s (SBA) Paycheck
Protection Program (PPP) and COVID-19 Economic Injury Disaster Loan
(COVID-19 EIDL) program helped small businesses cover eligible
operating costs, such as payroll and rent, during the pandemic. COVID-
19 relief funding also helped support COVID-19 testing; surveillance; and
contact tracing, among other uses.
While COVID-19 relief programs were critical for assuring public health
and economic stability, they also created unprecedented opportunities for
fraud due to the amount of dollars involved and other risk factors.
Because not all fraud will be identified, investigated, and adjudicated
through judicial or other systems, the full extent of fraud associated with
the COVID-19 relief funds will never be known with certainty.
Despite this, some estimates of fraud in COVID-19 relief programs exist.
For instance, in September 2023, we estimated that the fraud in DOL’s UI
programs during the pandemic—from April 2020 through May 2023—was

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GAO-24-107157
likely between $100 billion and $135 billion.1 The SBA Office of Inspector
General (OIG) estimated that as of June 2023, SBA had disbursed over
$200 billion (approximately 17 percent of SBA’s total COVID-19
spending) in potentially fraudulent pandemic relief loans.2
In light of what was likely lost to fraud during the pandemic, the
importance of fraud prevention cannot be stressed enough. To provide
insight into actions to promote fraud prevention, in a report being released
today, we have highlighted a wide variety of COVID-19 relief program
fraud schemes.3 These schemes illustrate various risk factors, impacts,
and mechanisms used to commit fraud. Insights from these schemes,
along with our other reviews of pandemic program delivery, have led
GAO to make numerous recommendations and matters for congressional
consideration; and to develop resources for improving fraud prevention
and payment integrity.

My comments today summarize key findings from our report on COVID-
19 fraud schemes and other reports examining fraud in COVID-19 relief
programs as well as our recent report on the status of agencies’ fraud risk
management.4 Specifically, I will discuss the following:

1. insights from COVID-19 fraud that can be used to inform prevention
efforts; and
2. prior GAO recommendations to agencies, matters for congressional
consideration, and resources for improving fraud prevention in normal
operations and future emergencies.
In preparing this testimony, we reviewed findings from our prior work on
internal controls and fraud risk management practices in COVID-19 relief
programs. Given the government-wide scope of this work, we undertook a

1GAO, Unemployment Insurance: Estimated Amount of Fraud during Pandemic Likely
Between $100 Billion and $135 Billion, GAO-23-106696 (Washington, D.C.: Sept. 12,
2023).
2This includes PPP loans, COVID-19 EIDL program loans, EIDL Targeted Advances, and
EIDL Supplemental Targeted Advances. Small Business Administration Office of Inspector
General, COVID-19 Pandemic EIDL and PPP Loan Fraud Landscape, White Paper
Report 23-09 (June 27, 2023).
3GAO, COVID-19: Insights from Fraud Schemes and Federal Response Efforts, GAO-24-
106353 (Washington, D.C.: Nov. 14, 2023).
4GAO, Fraud Risk Management: Agencies Should Continue Efforts to Implement Leading
Practices, GAO-24-106565 (Washington, D.C.: Nov. 1, 2023).

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variety of methodologies. These methodologies include examining federal
laws and agency documents, guidance, processes, and procedures. We
also reviewed public statements from the Department of Justice (DOJ)
from March 2020 through June 2023 and corresponding court
documentation, to identify and describe federal fraud-related cases.5
More detailed information about the objectives and methodologies on
which this statement is based can be found in the individual reports cited
throughout this statement.
We conducted the work on which this statement is based in accordance
with generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on
our audit objectives.
Challenges that agencies faced in implementing COVID-19 relief
programs provide insights into fraud prevention for normal operations and
future emergencies. However, before discussing the specific challenges
faced and the insights to be gained from the COVID-19 relief programs, it
is important to recognize the nature of fraud and the heightened risks
these programs were facing. With that context, understanding fraud
schemes that emerged during the pandemic can provide opportunities for
program managers to identify internal controls that are needed or were
circumvented, and respond to mitigate the related risks. Also, data and
system challenges, such as limited data sharing, highlight the value of
data analytics for fraud prevention. Additionally, thoughtful program
design choices that consider fraud vulnerabilities upfront can facilitate
fraud prevention.

5These statements from DOJ sometimes announce cases in the later stages of
prosecution. For example, an individual’s guilty plea may be announced without an earlier
public statement announcing the charges being brought. If those charges were brought
from March 2020 through June 2023 but the guilty plea was announced in August 2023,
that case would not be included in the scope of our review, since the public statement was
made after June 2023. See GAO-24-106353.
Insights from
COVID-19 Relief to
Inform Fraud
Prevention

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Fraud is inevitable where there are opportunities for gain—whether in
normal operations or emergencies. (See sidebar for five key principles of
fraud and corruption.) Across COVID-19 relief programs, factors
associated with heightened risk of fraud, waste, abuse, and other
payment integrity issues included6
•
programs that were new to the agency;
•
expansions or major changes in program funding, authorities,
practices, or procedures;
•
a large volume of payments being made;
•
payment or eligibility decisions made outside of the agency, such as
those by state governments;
•
limitations in the experience or training of those making eligibility
determinations or payment certifications; and
•
challenges related to eligibility and identity, such as lack of information
or data systems to confirm eligibility and reliance on self-certification.
New or expanded programs. Congress created new programs or greatly
expanded existing programs in response to the COVID-19 pandemic to
quickly deliver needed funds.
These included (1) a temporary UI program—Pandemic Unemployment
Assistance—which expanded eligibility for unemployment benefits; (2)
PPP, the COVID-19 EIDL program, the Restaurant Revitalization Fund,
and the Shuttered Venue Operators Grant to assist small businesses; and
(3) economic impact payments (EIP) for taxpayer assistance, among
others.
Large volume. COVID-19 relief programs experienced a large volume of
activity. For example, as the nation experienced historic levels of job loss,
the UI programs faced a large volume of claims. PPP and COVID-19
EIDL loans far exceeded SBA’s prepandemic lending volume.

6Payment integrity includes efforts to minimize all types of improper payments—payments
that should not have been made or were made in the incorrect amount—whether from
mismanagement, errors, abuse, or fraud. While all payments resulting from fraudulent
activity are considered improper, not all improper payments are the result of fraud. Fraud
involves obtaining something of value through willful misrepresentation. Willful
misrepresentation can be characterized by making material false statements of fact based
on actual knowledge, deliberate ignorance, or reckless disregard of falsity.
Five Principles and Risk
Factors for Fraud
Five Principles of Fraud and Corruption
• There is always going to be fraud. It is a
fact that some individuals will look to gain
where there is opportunity. Organizations
need robust processes in place to prevent,
detect, and respond to fraud and
corruption.
• Finding fraud is a good thing. If you do
not find fraud, you cannot fight it. This
requires a change in perspective so the
identification of fraud is viewed as a
positive and proactive achievement.
• There is no one solution. Addressing
fraud needs a holistic response
incorporating detection, prevention, and
response, underpinned by a strong
understanding of risk. It also requires
cooperation and collaboration between
organizations.
• Fraud and corruption are ever changing.
Fraud and counter fraud practices evolve
very quickly, and organizations must be
agile and change their approach to deal
with these evolutions.
• Prevention is the most effective way
to address fraud and corruption.
Preventing fraud reduces financial loss and
reputational damage. It also requires fewer
resources than an approach focused on
detection and recovery.
Source: International Public Sector Fraud Forum, Guide
to Managing Fraud for Public Bodies.  |
GAO-24-107157

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Payment decisions made outside of federal agencies. External
entities or agencies made eligibility and payment decisions in many
COVID-19 relief programs. For example, state agencies administered UI
and federal child nutrition programs; lenders were responsible for PPP
loan determinations; and internet service providers offered discounts for
broadband access to low-income households, among others.7
Inexperienced staff. Having new and inexperienced staff was a risk
factor for COVID-19 relief programs. For example, in June 2022, we
reported that DOL officials cited new and inexperienced staff as one of
the factors that provided opportunities for exploitation on UI programs and
system vulnerabilities.8
Eligibility or identity challenges. Several COVID-19 relief programs did
not use data systems to confirm eligibility, while some were prohibited
from doing so. Many programs relied on self-certification to make identity
and eligibility determinations. For example, SBA officials told us the
CARES Act’s restriction on obtaining applicants’ tax returns for the
COVID-19 EIDL program presented a challenge for validating
applications. Therefore SBA relied on self-certification.9
Considering the inevitability of fraud, identifying it is important, but
prevention is ideal, particularly where programs face multiple risk factors,
and losses may be significant. Prevention is the hallmark of GAO’s A
Framework for Managing Fraud Risks in Federal Programs (Fraud Risk
Framework), which agencies should have been adhering to since 2016.10
However, federal agencies did not strategically manage fraud risks in
alignment with the Fraud Risk Framework and were not adequately
prepared to prevent fraud when the pandemic began.

7GAO, Affordable Broadband: FCC Could Improve Performance Goals and Measures,
Consumer Outreach, and Fraud Risk Management, GAO-23-105399 (Washington, D.C.:
Jan. 18, 2023).
8GAO, Unemployment Insurance: Transformation Needed to Address Program Design,
Infrastructure, and Integrity Risks, GAO-22-105162 (Washington, D.C.: June 7, 2022).
9GAO, COVID Relief: Fraud Schemes and Indicators in SBA Pandemic Programs, GAO-
23-105331 (Washington, D.C.: May 18, 2023). The Consolidated Appropriations Act,
2021, enacted on December 27, 2020, removed this restriction.
10GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 28, 2015).

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Managing fraud risk is the responsibility of program managers. This
responsibility includes assessing the potential for fraud and implementing
strategies to appropriately mitigate related risks. Using information from
emerging fraud schemes can support ongoing fraud risk management
efforts.
Program managers can use the details of existing fraud schemes
identified in their programs—including information on the impact of these
schemes—to help identify program vulnerabilities. Moreover, program
managers can leverage details on fraud schemes and their corresponding
impacts to evaluate and adapt fraud risk management activities in
alignment with leading practices outlined in GAO’s Fraud Risk
Framework.
Three components in the Fraud Risk Framework include the following
leading practices related to using past schemes and related information to
help combat fraud:
•
The assess component directs program managers to consider the
financial and nonfinancial impacts of fraud risks and identify specific
tools, methods, and sources for gathering information about fraud
risks, including data on fraud schemes and trends from monitoring
and detection activities.
•
The design and implement component directs agencies to analyze
information on previously detected fraud and consider known or
previously encountered fraud schemes to design data analytics.
•
The evaluate and adapt component directs agencies to collect and
analyze data, including data from reporting mechanisms and
instances of detected fraud.
At least 1,399 individuals or entities were found guilty or liable in fraud-
related cases involving federal COVID-19 relief programs, based on our
analysis of DOJ’s public statements and court documentation from March
2020 through June 2023.11 In addition to those individuals and entities
found guilty or liable, there were also federal fraud-related charges

11The federal government may enforce laws through civil or criminal action. Such action
may be resolved through a trial, a permanent injunction, a civil settlement, or a guilty plea.
Our analysis is limited to the cases we identified from public sources and may not include
all criminal and civil cases charged by DOJ as of June 30, 2023. Additionally, details of
fraud cases and schemes presented in court documents may not be complete. Further,
cases that reach the prosecution stage in the fraud identification life cycle represent a
fraction of the instances of fraud or all possible fraud cases. See GAO-24-106353.
Insights from Fraud
Schemes

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pending against at least 599 other individuals or entities involving federal
COVID-19 relief programs, as of June 30, 2023.12 The number of
individuals or entities facing fraud-related charges related to COVID-19
relief programs has grown since March 2020 and will likely continue to
increase, as these cases take time to develop.
Fraud schemes are achieved through various mechanisms. A mechanism
is a process, technique, or system used by fraudsters to execute
fraudulent activities. Mechanisms include misrepresentation, cybercrime,
and document falsification. A mechanism can be an individual action or a
group of actions working in concert. Fraud schemes result in financial loss
and impacts on taxpayers; agency reputation and integrity; federal
program goals; and other areas, such as public health and safety. During
the pandemic, fraud schemes involved fairly simple mechanisms, as well
as complex schemes and mechanisms involving organized groups and
international crime rings.
Simple fraud schemes circumvented key controls. Many COVID-19
relief program fraud schemes relied on fairly simple misrepresentation
mechanisms. These included document manipulation, false declarations,
and fictitious entities. These types of schemes and mechanisms leave
agencies open to significant fraud risk when they rely on self-certification
of eligibility or identity as an internal control for fraud prevention.
We found that federal and state agencies, in an effort to disburse funds
quickly to those in need, relied on self-attestation or self-certification for
individuals to verify their eligibility or identity to receive assistance from
some COVID-19 relief programs. Even if program design decisions
allowed for self-certification (as discussed in greater detail below),
agencies are responsible for designing and implementing control activities
to prevent fraud. Self-certification alone is not sufficient as a fraud control
(see sidebar).
Our prior work examining PPP and COVID-19 EIDL fraud schemes
identified (1) ineligible, nonoperating businesses that applied for and
obtained program funds; (2) legitimate businesses owners
misrepresenting eligibility regarding their criminal record, federal debt, or
principal place of residence, among others; and (3) falsification of tax or
other documents to obtain more funds.13 In these instances, recipients

12A charge is merely an allegation, and all defendants are presumed innocent until proven
guilty beyond a reasonable doubt in a court of law.
13GAO-23-105331.
Misrepresentation. Fraud
schemes involve a false
statement of a material fact made
by one party that affects another
party’s decisions, such as by
misrepresenting identity and
eligibility.
Insight #1: Self-certification alone is not
sufficient as a fraud control to mitigate
misrepresentation.
Source: GAO (analysis); Icons-Studio/stock.adobe.com
(icon).  |  GAO-24-107157

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falsely self-certified eligibility. Other fraud controls to mitigate these
misrepresentations were either not in place or were not effective.
Confirming eligibility of individuals receiving benefits, such as by
confirming wage information or by verifying identity through data and
other checks, are key controls to prevent fraud schemes that rely on
mechanisms such as misrepresentation.
Complex fraud schemes also emerged during the pandemic. Other
COVID-19 relief program fraud schemes relied on more complex
mechanisms, such as conspiracies involving organized groups or
international criminal gangs. Such cases, including those involving
international fraud schemes, continue to emerge, in part because of the
time needed to obtain information from foreign jurisdictions. If agencies
are not prepared to combat simple fraud schemes, they will not be
prepared for emerging complex fraud schemes. As part of assessing their
own fraud risks, agencies can gain insights from examining emerging and
complex schemes that affected other similar programs such as those with
similar mission activities (see sidebar).
Conspiracy. We have previously reported on schemes involving
conspiracies to defraud COVID-19 relief programs. For example, four
individuals associated with a nonprofit organization pleaded guilty to their
roles in a complex scheme to defraud a federal child nutrition program.
Nearly 50 individuals are alleged to have engaged in this scheme. The
ringleaders of the scheme operated a nonprofit organization. Other
individuals—recruited by the nonprofit to participate in the scheme—set
up sham program delivery sites to fraudulently claim reimbursements for
meal delivery. The nonprofit received more than $18 million in
administrative fees to which it was not entitled and, after claiming to open
more than 250 sites, it fraudulently obtained and disbursed more than
$240 million in program funds that the fraudsters used for their own
financial benefit instead of using the funds as intended to feed
underserved children during the pandemic.14
International schemes. U.S. law enforcement officials have been
analyzing and investigating instances of fraud involving foreign actors.
For example, SBA OIG analyzed internet protocol (IP) addresses that
were used to apply for COVID-19 EIDL funds. SBA disbursed 41,638
COVID-19 EIDL loans and grants to applicants with foreign IP addresses,

14GAO-24-106353.
Fraud conspiracy. Involves an
agreement by two or more
individuals to commit a crime,
such as via collusion between a
small group of individuals or
larger scale fraud rings.
Insight #2: Assess fraud risks to include
emerging and complex schemes—such as
those involving conspiracies—from cases
affecting other similar programs.
Source: GAO (analysis); Icons-Studio/stock.adobe.com
(icon).  |  GAO-24-107157

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totaling $1.3 billion. Applications were processed by applicants with IP
addresses from Nigeria, Pakistan, Canada, Mexico, United Kingdom,
Philippines, Dominican Republic, India, and Germany.15
Early in the pandemic, DOL’s OIG worked with DOJ to create the National
UI Fraud Task Force, a nine-agency federal task force that worked
closely with the International Organized Crime Intelligence and
Operations Center (IOC-2). Through data analytics and a leads
generation process, the National UI Fraud Task Force and IOC-2 partner
agencies have identified significant fraud being committed against the UI
program by domestic and international criminal organizations. Many of
these include street-level criminal organizations with ties to illegal guns
and drugs.
Integrated, functional, and secure data and systems are essential for
effective fraud risk management. Agencies’ responses to the pandemic
revealed challenges in leveraging available data, legacy IT systems that
were unable to facilitate fraud detection and recovery, and data breaches
that facilitated identity fraud.
Available data. According to the Fraud Risk Framework, a leading
practice in fraud data analytics is to conduct data mining and matching.
This includes cross-checking of data and using external data sources to
validate information, to identify suspicious activities. There are various
sources of data available for agencies to use. For example, agencies
have access to free payment integrity services provided by the
Department of the Treasury.16 Agencies can also leverage their own
program or agency data. However, these data sources are not always
fully leveraged (see sidebar).
Internal and external data sharing posed challenges in the administration
of COVID-19 relief programs. For example, in May 2023, we determined
that, across its programs, SBA did not fully leverage information to help
prevent fraud and identify applicants who tried to defraud more than one
program. We also found that while SBA obtained access to some

15Small Business Administration Office of Inspector General, COVID-19 Economic Injury
Disaster Loan Applications Submitted from Foreign IP Addresses, Report 22-17 (Sept. 12,
2022).
16Treasury’s Do Not Pay service is an analytics tool that helps federal agencies detect
and prevent improper payments made to vendors, grantees, loan recipients, and
beneficiaries. Agencies can use the service to check multiple data sources to make
payment eligibility decisions.
Insights from Data and IT
System Challenges
Not leveraging available data.
Challenges included not using
existing data that could help
validate payment eligibility.
Insight #3: Leverage the Department of the
Treasury’s free payment integrity services
as well as available program or agency
data.
Source: GAO (analysis); Icons-Studio/stock.adobe.com
(icon).  |  GAO-24-107157

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government databases, such as the Department of the Treasury’s Do Not
Pay service, that was after most of the PPP and COVID-19 EIDL funds
were disbursed. Also, it did not have access to some other external data
sources that could benefit its efforts to detect and prevent fraud. We
recommended that SBA ensure that it has mechanisms in place and use
them to facilitate cross-program data analytics. We also recommended
that SBA identify external sources of data that can facilitate the
verification of applicant information and the detection of potential fraud
across its programs.17
Legacy systems. During the pandemic, due to outdated IT systems,
agencies experienced challenges in detecting and recovering improper
payments, including from fraud. Addressing interoperability issues can
support future use of data analytics for fraud prevention and detection
(see sidebar).
A May 2021 DOL OIG report identified legacy IT systems as one of the
causes of states’ inability to detect and recover improper UI payments,
including fraudulent payments.18 Additionally, in our June 2022 report,
state officials reported that their IT systems did not have the capability to
perform cross-matches—a method used to detect improper payments—
for such a large volume of claims.19
Further, in June 2022, we reported that legacy systems may operate with
known security vulnerabilities that are either technically difficult or
prohibitively expensive to address.20 In the UI programs, this may pose a
privacy risk for claimants as their PII could become more easily
accessible to criminals who target UI. The increased amount of benefits
awarded and legacy IT systems’ inability to adequately guard citizens’
sensitive information gave criminals incentive and opportunities to commit
fraud.

17GAO-23-105331. As of November 7, 2023, SBA has not yet provided us with information
on the status of its efforts to implement these recommendations.
18Department of Labor, Office of Inspector General, COVID-19: States Struggled to
Implement CARES Act Unemployment Insurance Programs, Report No. 19-21-004-03-
315 (Washington, D.C.: May 28, 2021).
19GAO-22-105162.
20GAO-22-105162.
Legacy systems limit data use.
Challenges included outdated IT
systems that constrained
capabilities for fraud prevention
and detection.
Insight #4: Address interoperability issues
to support future use of data analytics for
fraud prevention and detection.
Source: GAO (analysis); Icons-Studio/stock.adobe.com (icon).
|  GAO-24-107157

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Legacy IT systems made it difficult for many states to prevent
cybersecurity attacks or the use of fraudulently obtained identity
information, according to DOL OIG officials. These officials stated that
some state IT systems were not equipped to handle the volume of claims,
and some may not have been easily compatible with the National
Association of State Workforce Agencies UI Integrity Center’s Integrity
Data Hub resources.21 However, since the onset of the pandemic, many
states have begun using Integrity Data Hub resources, according to DOL
officials. For example, as of October 2022, we reported that there were 41
states using the Integrity Data Hub’s identity verification service,
according to DOL officials.22 According to the DOL OIG, as of February
2023, 53 states had a participation agreement to use the Integrity Data
Hub.23 However, the DOL OIG also noted that the existence of a
participation agreement does not provide information on whether
participants are using these resources or the frequency in which they use.
Data breaches. Stolen personally identifiable information (PII) played a
role in large-scale identity fraud during the pandemic. Given the scale of
this fraud and known data breaches involving PII to date, agencies can
assume that identity information has been compromised. Accordingly,
agencies can develop and apply upfront controls for their programs to
verify applicant identity (see sidebar).
Data breaches provided a source of PII for fraudsters. In a May 2021
fraud alert, the U.S. Secret Service warned that an international crime
ring was filing UI claims in different states using PII belonging to identity
theft victims, including first responders, government personnel, and
school employees. The fraud alert further noted a well-organized Nigerian
fraud ring seeking to commit large-scale fraud against state UI programs.
Washington, North Carolina, Massachusetts, Rhode Island, Oklahoma,

21The Integrity Data Hub is a centralized, multistate data system that the UI Integrity
Center operates in partnership with DOL, using DOL funding. The Integrity Data Hub
provides state workforce agencies with cross-matching capabilities to analyze UI claims
data to detect and prevent UI fraud and improper payments.
22GAO, Unemployment Insurance: Data Indicate Substantial Levels of Fraud during the
Pandemic; DOL Should Implement an Antifraud Strategy, GAO-23-105523 (Washington,
D.C.: Dec. 22, 2022).
23Department of Labor, Office of Inspector General, COVID-19: ETA Can Improve its
Oversight to Ensure Integrity over CARES Act UI Programs, Report No. 19-23-011-03-315
(Washington, D.C.: Sept. 22, 2023).
Identity theft. Fraud schemes
involve stealing personally
identifiable information to
fraudulently apply for benefits.
Insight #5: Assume identity information
has been compromised, and develop and
apply upfront controls to verify applicant
identity.
Source: GAO (analysis); Icons-Studio/stock.adobe.com
(icon).  |  GAO-24-107157

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Wyoming, and Florida were subject to efforts by this ring to defraud their
UI programs.
A stakeholder panel we convened in 2022 also shared concerns about
identity fraud schemes orchestrated during the pandemic.24 One panelist,
who investigated UI fraud at the state level, explained that many
fraudsters who had stolen identity information prior to the pandemic saw
the CARES Act UI programs as an opportunity to use that information to
obtain benefits.

Thoughtful program design choices that consider fraud vulnerabilities
upfront can facilitate fraud prevention. During the pandemic—because the
government needed to provide assistance quickly to those affected by
COVID-19 and its economic effects—initial legislative and policy program
design posed limitations for effective management of fraud risks.
Ensuring that payment integrity checks and fraud controls are part of
program design, including emphasizing data access and use for fraud
prevention, can facilitate fraud prevention (see sidebar).
For one of DOL’s temporary UI programs—Pandemic Unemployment
Assistance—and SBA’s PPP and COVID-19 EIDL pandemic relief
programs, Congress initially allowed reliance on self-certification of
participant eligibility and also eliminated certain verification requirements.
These program design decisions, coupled with the large scale of the
programs, increased fraud risks. For example, the CARES Act allowed
Pandemic Unemployment Assistance applicants to self-certify their
eligibility and did not require them to provide any documentation of self-
employment or prior income. Similarly, for COVID-19 EIDL, Congress
removed safeguards that had been in place prepandemic in an effort to
expedite loan processing. The Consolidated Appropriations Act, 2021,
enacted in December 2020, included provisions to help address these
risks.
Also early in the pandemic, the Internal Revenue Service’s (IRS)
disbursement approach that allowed EIPs to go to decedents presented
improper payment risks related to ineligibility and fraud. This situation
highlights the importance of clearly assuring data use to guide
implementation decisions to prevent unnecessary waste in addition to
fraud. Specifically, we previously reported that the Treasury and IRS did

24 GAO-22-105162.
Insights from Program
Design Limitations
Limiting data access and use.
Challenges included limitations
on data access and use that
constrain agencies’ capabilities to
prevent and detect fraud.
Insight #6: Ensure payment integrity
checks and fraud controls are part of
program design, with an emphasis on
assuring data access and use for fraud
prevention.
Source: GAO (analysis); Icons-Studio/stock.adobe.com
(icon).  |  GAO-24-107157

Page 13
GAO-24-107157
not use the Social Security Administration’s death records to stop
payments to deceased individuals for the first three batches of EIPs
because of the legal interpretation under which IRS was operating.25 The
first three batches of payments accounted for 72 percent of the payments
disbursed as of May 31, 2020. According to the Treasury Inspector
General for Tax Administration, as of April 30, 2020, almost 1.1 million
payments totaling, nearly $1.4 billion, had gone to decedents. According
to IRS officials, IRS counsel determined that IRS did not have the legal
authority to deny payments to those who filed a return for 2019, even if
they were deceased at the time of payment. IRS officials said that, on the
basis of this determination, they did not exclude decedents in their
programming requirement. Treasury officials said that upon learning that
payments had been made to decedents, the Treasury and IRS, in
consultation with counsel, determined that a person is not entitled to
receive a payment if they are deceased as of the date the payment is to
be paid. Such payments were removed, starting with the fourth payment
batch.

With insights for strategic fraud risk management from COVID-19
challenges, agencies are better positioned to manage fraud during normal
operations and emergencies. Other sources that provide additional insight
for fraud prevention include recommendations we have made to
agencies, actions we have identified that Congress can take to strengthen
fraud risk management practices across the government, and resources
we developed to support strategic fraud risk management. Implementing
these recommendations and taking these actions, along with leveraging
available resources, can enable agencies to carry out their missions and
better protect taxpayer dollars from fraud during normal operations and
prepare them to face the next emergency (see sidebar).

25GAO, COVID-19: Opportunities to Improve Federal Response and Recovery Efforts,
GAO-20-625 (Washington, D.C.: June 25, 2020).
Actions and
Resources to Better
Manage Fraud Risks
Actions and resources. Nearly
100 GAO fraud risk management
recommendations remain open.

Insight #7: Take actions to better prevent
fraud by implementing GAO
recommendations and using resources.
Source: GAO (analysis); Icons-Studio/stock.adobe.com
(icon).  |  GAO-24-107157

Page 14
GAO-24-107157
Our work since July 2015 has highlighted areas in which federal agencies
need to take additional actions to help ensure they are effectively
managing fraud risks, consistent with leading practices in GAO’s Fraud
Risk Framework. Specifically, as we reported earlier this month, from July
2015 through August 2023, we made 173 recommendations to over 40
agency or program offices related to certain areas aligned with leading
practices from the Fraud Risk Framework.26 As of August 2023, agencies
needed to take additional action to fully address 95 of these
recommendations. Fully addressing these recommendations can help
ensure that federal managers safeguard public resources, including while
providing needed relief during emergencies.
For example, we found that using data analytics to manage fraud risks is
one area in need of improvement by federal agencies. The Fraud Risk
Framework’s leading practices include implementing data-analytics
activities as part of an overall antifraud strategy. Data-analytics activities
can include a variety of techniques. These techniques include predictive
analytics that can identify potential fraud before making payments. Data
matching and other techniques to verify self-reported information and
other information necessary for determining eligibility for enrolling in
programs or receiving benefits are also important tools. In addition, data-
mining and data matching techniques can enable agencies to identify
potential fraud or improper payments that have already been awarded,
thus assisting agencies in recovering these dollars.
We have made recommendations for agencies to use data analytics to
better manage fraud risk. Specifically, from July 2015 through August
2023, we made 47 recommendations to federal agencies in this area.
These included recommendations to design and implement data-analytics
activities to prevent and detect fraud, such as using data matching to
verify self-reported information. Of the 47 recommendations, 25 had not
been implemented as of August 2023.
In our March 2022 testimony before the Senate Committee on Homeland
Security and Governmental Affairs, we identified actions that Congress
could take to strengthen internal controls and financial and fraud risk
management practices across the government.27 These matters for

26GAO-24-106565.
27GAO, Emergency Relief Funds: Significant Improvements Are Needed to Ensure
Transparency and Accountability for COVID-19 and Beyond, GAO-22-105715
(Washington, D.C.: Mar. 17, 2022).
Agencies Should
Implement GAO
Recommendations to
More Effectively Manage
Fraud Risks
Congress Can Take
Actions to Better Prevent
Fraud

Page 15
GAO-24-107157
congressional consideration remain open. We continue to believe that
such actions will increase accountability and transparency in federal
spending in both normal operations and emergencies. Appendix I
contains a list of the 10 matters for congressional consideration. Below
we highlight three of those matters for which immediate action by
Congress would enhance fraud risk management.
Establish a permanent analytics center for identifying fraud and
improper payments. Responsibilities for planning and implementing
fraud risk management and detection activities start with agency
management officials. The oversight community, however, plays a critical
role in identifying and investigating suspected fraud. The importance of
this role in nonemergency periods is heightened during emergencies,
such as the COVID-19 pandemic, as agencies work to implement large-
scale relief efforts quickly.
At the outset of the pandemic, there was no permanent, government-wide
analytical capability to help inspectors general identify fraud. In March
2021, the American Rescue Plan Act of 2021 appropriated $40 million
dollars to the Pandemic Response Accountability Committee, which
subsequently established the Pandemic Analytics Center of Excellence
(PACE).28 The role of PACE is to help oversee the trillions of dollars in
federal pandemic-related emergency spending. According to the
Pandemic Response Accountability Committee, PACE applies best
practices, with the goal of building an “affordable, flexible, and scalable
analytics platform” to support Offices of Inspector General during their
pandemic-related work, including beyond the organization’s sunset date
in 2025.
In March 2022, we recommended that Congress establish a permanent
analytics center of excellence to aid the oversight community in
identifying improper payments and fraud.29 Without permanent,
government-wide analytics capabilities to assist the oversight community,
agencies will have limited resources to apply to nonpandemic programs
to ensure robust financial stewardship, as well as better prepare for
applying fundamental financial and fraud risk management practices to
future emergency funding.

28Pub. L. No. 117-2, 135 Stat. 4.
29GAO-22-105715.
Open Matter for Congressional
Consideration
Congress should establish a permanent
analytics center of excellence to aid the
oversight community in identifying improper
payments and fraud.
Source: GAO.  |  GAO-24-107157

Page 16
GAO-24-107157
Amend the Social Security Act to make permanent the sharing of full
death data. Data sharing can allow agencies to enhance their efforts to
prevent improper payments to deceased individuals. To enhance identity
verification through data sharing, we have previously recommended that
Congress amend the Social Security Act to explicitly allow the Social
Security Administration to share its full death data with Treasury’s Do Not
Pay system, a data matching service for agencies to use in preventing
payments to ineligible individuals.30 In December 2020, Congress passed,
and the President signed into law, the Consolidated Appropriations Act,
2021, which requires the Social Security Administration to share, to the
extent feasible, its full death data with Treasury’s Do Not Pay working
system for a 3-year period, effective on the date that is 3 years from
enactment of the act.31
In March 2022, we recommended that Congress accelerate and make
permanent the requirement for the Social Security Administration to share
its full death data with Treasury’s Do Not Pay working system.32 Treasury
officials have informed us that by the end of this calendar year, the Do
Not Pay working system should have full access to the full death data.
However, under current law, that access will end in 2026.
Reinstate reporting requirements for fraud risk management.
Congress’s ability to oversee agencies’ efforts to manage fraud risks is
hindered by the lack of fraud-related reporting requirements. The Fraud
Reduction and Data Analytics Act of 2015 and the Payment Integrity
Information Act of 2019 required agencies to report on their antifraud
controls and fraud risk management efforts in their annual financial
reports.33 However, the requirement to report such information ended with
the fiscal year 2020 annual financial report. Since then, there has been no
similar requirement for agencies to report on their efforts to manage fraud
risks.34 In March 2022, we recommended that Congress amend the

30GAO, Improper Payments: Strategy and Additional Actions Needed to Help Ensure
Agencies Use the Do Not Pay Working System as Intended, GAO-17-15 (Washington,
D.C.: Oct. 14, 2016); and GAO-20-625.
31Pub. L. No. 116-260, div. M and N, 134 Stat. 1182 (2020).
32GAO-22-105715.
33Pub. L. No. 114-186, §3(c); Pub. L. No. 116-117, codified at 31 U.S.C. §3357(d).
34The Payment Integrity Information Act of 2019 includes multiple ongoing reporting
requirements for agencies related to improper payments generally, but none specifically
mention fraud.
Open Matter for Congressional
Consideration
Congress should amend the Social Security
Act to accelerate and make permanent the
requirement for the Social Security
Administration to share its full death data with
the Department of the Treasury’s Do Not Pay
working system.
Source: GAO.  |  GAO-24-107157
Open Matter for Congressional
Consideration
Congress should amend the Payment
Integrity Information Act of 2019 to reinstate
the requirement that agencies report on their
antifraud controls and fraud risk management
efforts in their annual financial reports.
Source: GAO.  |  GAO-24-107157

Page 17
GAO-24-107157
Payment Integrity Information Act of 2019 to reinstate reporting
requirements.35
In the absence of reporting on agencies’ fraud risk management efforts
through annual financial reports, earlier in 2023, we surveyed the 24
Chief Financial Officers Act of 1990 (CFO Act) agencies about steps they
have taken to manage fraud risks.36 In response to our survey, 18 of the
CFO Act agencies reported that they have regular and ongoing activities
to identify and assess risks to determine the fraud risk profile for
programs or operations. Twenty of the agencies indicated that they have
regular and ongoing activities to design and implement specific control
activities to prevent and detect fraud.
As part of our survey, agencies also rated challenges that could impede
their efforts to manage fraud risks. For instance, agencies reported the
availability of resources (such as staff and funding) and tools for data
analytics as being great or moderate challenges. CFO Act agencies’
survey responses indicated the following factors as a great or moderate
challenge to their fraud risk management efforts:
•
Having available staffing, funding, or other resources to conduct fraud
risk management activities;
•
Having and using tools and techniques for data analytics; and
•
Having available expertise to conduct fraud risk management
activities.
Agencies also rated factors that could motivate them to manage fraud
risk. For example, agencies cited the ability to counter reputational
impacts as a factor that would motivate their efforts a lot or somewhat.
CFO Act agencies’ survey responses indicated the following factors as
highly or somewhat motivating to their fraud risk management efforts:
•
Congressionally directed prioritization of budget funds for program
integrity improvements;
•
Ability to counter reputational impacts if fraud is found; and
•
Ability to demonstrate financial returns from fraud risk management.

35GAO-22-105715.
36GAO-24-106565.

Page 18
GAO-24-107157
Agencies have the opportunity to learn from the experiences during the
pandemic and ensure that they are strategically managing their fraud
risks in the future. Doing so by leveraging available resources and
adhering to requirements will enable them to carry out their missions and
better protect taxpayer dollars from fraud during normal operations and
prepare them to face the next emergency.
One such resource is GAO’s Fraud Risk Framework, issued in July 2015.
This framework provides a comprehensive set of key components and
leading practices to help agency managers combat fraud in a strategic,
risk-based way. The Payment Integrity Information Act of 2019 requires
that the guidelines for federal agencies established by the Office of
Management and Budget (OMB)—which incorporate the leading
practices from the Fraud Risk Framework—remain in effect.37
As depicted in figure 1, the Fraud Risk Framework describes leading
practices for managing fraud risk and includes four components: commit,
assess, design and implement, and evaluate and adapt. These leading
practices are applicable during normal operations, as well as during
emergencies.

37Pub. L. No. 116-117, § 2(a), 134 Stat. 113, 131 - 132 (2020), codified at 31 U.S.C. §
3357. The act requires these guidelines to remain in effect, subject to modification by
OMB as necessary, and in consultation with GAO. The Fraud Reduction and Data
Analytics Act of 2015 required OMB to establish guidelines for federal agencies to create
controls to identify and assess fraud risks and to design and implement antifraud control
activities. The act further required OMB to incorporate the leading practices from the
Fraud Risk Framework in the guidelines. Pub. L. No. 114-186, 130 Stat. 546 (2016). In
October 2022, OMB issued a Controller Alert reminding agencies that, consistent with the
guidelines contained in OMB Circular A-123, which are required by Section 3357 of the
Payment Information Integrity Act of 2019, Pub. L. No. 116-117, they must establish
financial and administrative controls to identify and assess fraud risks. In addition, OMB
reminded agencies that they should adhere to the leading practices in GAO’s Fraud Risk
Framework as part of their efforts to effectively design, implement, and operate an internal
control system that addresses fraud risks. Office of Management and Budget, CA-23-03,
Establishing Financial and Administrative Controls to Identify and Assess Fraud Risk (Oct.
17, 2022).
Resources Available to
Better Manage Fraud
Risks

Page 19
GAO-24-107157
Figure 1: The Four Components of the Fraud Risk Framework

Another resource is the Bureau of the Fiscal Service’s Antifraud Playbook
that provides a how-to guide for implementing the Fraud Risk
Framework’s leading practices.38 The playbook consists of a four-phased
approach—aligned with the four components of the Fraud Risk
Framework—and 16 best-practice plays for combatting fraud.
In addition to the Fraud Risk Framework, we have developed other
resources—specifically our web-based Antifraud Resource and A
Framework for Managing Improper Payments in Emergency Assistance
Programs (Managing Improper Payments Framework)—to help agencies
combat fraud and improve payment integrity.39 These resources can help
agencies better understand and combat the causes and impacts of fraud.
Antifraud Resource. Our prior work found that agencies have had
challenges in effectively assessing and managing their fraud risks and
that federal managers may not fully understand how fraud affects their
programs. GAO created the online Antifraud Resource to help federal
officials and the public better understand and combat federal fraud. The
Antifraud Resource is based on a conceptual fraud model and provides

38Bureau of the Fiscal Service, Program Integrity: The Antifraud Playbook (Oct. 17, 2018).
39GAO, “The GAO Antifraud Resource” (Washington, D.C.: Jan. 10, 2022), accessed Nov.
3, 2023, https://gaoinnovations.gov/antifraud_resource/; and A Framework for Managing
Improper Payments in Emergency Assistance Programs, GAO-23-105876 (Washington,
D.C.: July 13, 2023).

Page 20
GAO-24-107157
insight on fraud schemes that affect the federal government, their
underlying concepts, and how to combat such fraud. Figure 2 references
the online location of this antifraud resource.
Figure 2: Reference to GAO’s Antifraud Resource

Managing Improper Payments Framework. When the federal
government provides emergency assistance, the risk of improper
payments may be higher because the need to provide such assistance
quickly can detract from the planning and implementation of effective
controls. Our past work has shown that federal agencies should better
plan for, and take a more strategic approach to, managing improper
payments in emergency assistance programs. In response, in July 2023,
we published the Managing Improper Payments Framework.40
This framework includes principles and corresponding practices to help
federal agencies mitigate improper payments, including those stemming
from fraud, in emergency and nonemergency programs before they
occur. It is also intended as a resource for Congress to use when
designing new programs or appropriating additional funding in response
to emergencies. It includes an overall five-step approach, as described in
figure 3, that includes principles aligned with leading practices from our
Fraud Risk Framework, such as identifying and assessing fraud risks that
cause improper payments.

40GAO-23-105876. This framework can also be useful for managing improper payments in
nonemergency assistance programs or during normal program operations. This
framework should be used by federal agencies in conjunction with existing requirements
related to managing improper payments, including those stemming from fraud.

Page 21
GAO-24-107157
Figure 3: Framework for Managing Improper Payments in Emergency Assistance
Programs

Chair Hassan, Ranking Member Romney, and Members of the
Subcommittee, this concludes my prepared statement. I would be
pleased to respond to any questions.

Page 22
GAO-24-107157
For further information about this testimony, please contact Rebecca
Shea, Director, Forensic Audits and Investigative Service, at (202) 512-
6722 or shear@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this statement.
GAO staff who made key contributions to this testimony are Irina
Carnevale (Assistant Director), Paulissa Earl (Analyst in Charge),
Gabrielle Fagan, Lauren Kirkpatrick, Barbara Lewis, Maria McMullen,
Tina Paek, and Sabrina Streagle.

GAO Contact and
Staff
Acknowledgments

Page 23
GAO-24-107157
In a March 2022 testimony before the Senate Committee on Homeland
Security and Governmental Affairs, we recommended the following 10
matters for congressional consideration:1

•
Congress should pass legislation requiring the Office of Management
and Budget (OMB) to provide guidance for agencies to develop plans
for internal control that would then immediately be ready for use in, or
adaptation for, future emergencies or crises and requiring agencies to
report these internal control plans to OMB and Congress. (Matter for
Congressional Consideration 1)
•
Congress should amend the Payment Integrity Information Act of
2019 to designate all new federal programs making more than $100
million in payments in any one fiscal year as “susceptible to significant
improper payments” for their initial years of operation. (Matter for
Congressional Consideration 2)
•
Congress should amend the Payment Integrity Information Act of
2019 to reinstate the requirement that agencies report on their
antifraud controls and fraud risk management efforts in their annual
financial reports. (Matter for Congressional Consideration 3)
•
Congress should establish a permanent analytics center of excellence
to aid the oversight community in identifying improper payments and
fraud. (Matter for Congressional Consideration 4)
•
Congress should clarify that (1) chief financial officers (CFO) at CFO
Act agencies have oversight responsibility for internal controls over
financial reporting and key financial management information that
includes spending data and improper payment information; and (2)
executive agency internal control assessment, reporting, and audit
requirements for key financial management information, discussed in
an existing matter for congressional consideration in our August 2020
report,2 include internal controls over spending data and improper
payment information. (Matter for Congressional Consideration 5)
•
Congress should require agency CFOs to (1) submit a statement in
agencies’ annual financial reports certifying the reliability of improper
payments risk assessments and the validity of improper payment
estimates, and describing the actions of the CFO to monitor the

1GAO, Emergency Relief Funds: Significant Improvements Are Needed to Ensure
Transparency and Accountability for COVID-19 and Beyond, GAO-22-105715
(Washington, D.C.: Mar. 17, 2022).
2GAO, Federal Financial Management: Substantial Progress Made since Enactment of the
1990 CFO Act; Refinements Would Yield Added Benefits, GAO-20-566 (Washington,
D.C.: Aug. 6, 2020).
Appendix I: Matters for Congressional
Consideration

Page 24
GAO-24-107157
development and implementation of any corrective action plans; and
(2) approve any methodology that is not designed to produce a
statistically valid estimate. (Matter for Congressional Consideration 6)
•
Congress should consider legislation to require improper payment
information required to be reported under the Payment Integrity
Information Act of 2019 to be included in agencies’ annual financial
reports. (Matter for Congressional Consideration 7)
•
Congress should amend the DATA Act to extend the previous
requirement for agency inspectors general to review the
completeness, timeliness, quality, and accuracy of their respective
agency data submissions on a periodic basis. (Matter for
Congressional Consideration 8)
•
Congress should amend the DATA Act to clarify the responsibilities
and authorities of OMB and the Department of the Treasury for
ensuring the quality of data available on USAspending.gov. (Matter for
Congressional Consideration 9)
•
Congress should amend the Social Security Act to accelerate and
make permanent the requirement for the Social Security
Administration to share its full death data with the Department of the
Treasury’s Do Not Pay working system. (Matter for Congressional
Consideration 10)

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