Blueprint for Enhanced Program Integrity, Ch. 3 (Dec. 2024)
- Issuer
- Inspector general and oversight reports
- Document type
- Report
- Date
- 2024-12-10
- Case
- Report Prac Blueprint Enhanced Program Integrity Chapter 3 2024 12 10
Summary
Chapter 3 of the Pandemic Response Accountability Committee's Blueprint for Enhanced Program Integrity, "Fraud Prevention and Detection," dated December 2024. It compiles recommendations from federal and state OIG reports and congressional testimony issued between March 2020 and August 2024, GAO and OMB publications, and listening sessions with OIGs, state comptrollers and auditors, and GAO. Its sections cover preventing, detecting and responding to fraud, with themes including fraud risk assessments, data sharing across agencies, and verifying recipient eligibility and identity. The prevention section cites Gold Standard meetings under OMB Memorandum M-22-12, GAO's Fraud Risk Framework, and DHS OIG-22-69 on more than $3.7 Billion in improper payments from the Lost Wages Assistance Program. Appendix 3-A sets out the objective, scope and methodology.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
PANDEMIC RESPONSE
ACCOUNTABILITY COMMITTEE
Blueprint for Enhanced
Program Integrity
Chapter 3: Fraud Prevention
and Detection
December 2024
Contents
Chapter 3: Fraud Prevention and Detection 1
Executive Summary 1
Section 1: Preventing Fraud 2
Section 2: Detecting Fraud 12
Section 3: Responding to Fraud 18
Appendix 3-A: Objective, Scope, and Methodology 23
Contributing Partners 24
Pandemic Response Accountability Committee ii
Chapter 3: Fraud Prevention
and Detection
Executive Summary:
In this chapter focused on the oversight community and policymakers, we highlight key reports,
guidance, and recommendations issued by federal and state oversight organizations that provide
leading practices for how to better design and implement emergency programs to prevent and
detect fraud in government benefit programs. We also compiled lessons learned from these reports
and interviews with key stakeholders, with a focus on the importance of pre-award and post-award
monitoring.
These best practices and lessons learned highlight key themes, including establishing and
performing fraud risk assessments; sharing resources, information and data across agencies;
verifying recipient eligibility and identity; providing training and clear guidance to staff; and
coordinating oversight by program and oversight officials.
How We Developed Chapter 3
We took the following steps to identify leading practices and lessons learned:
• Reviewed federal and state Offices of Inspectors General (OIGs) reports and congressional
testimonies issued between March 2020 and August 2024 to identify key recommendations
and successful methods for preventing and detecting fraud.
• Reviewed published reports, guidance, and memoranda from the U.S. Government
Accountability Office (GAO) and the Office of Management and Budget (OMB).
• Conducted listening sessions with OIGs, state comptrollers and auditors, and GAO to
incorporate their knowledge and expertise.
For the full methodology, see Appendix 3-A.
In the following sections, we highlight key themes with citations from supporting documents.
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Chapter 3: Fraud Prevention and Detection
Section 1:
Preventing Fraud
Federal agencies can improve fraud risk management and prevent fraud at the outset of emergency
benefit programs in several ways: assess fraud risks, designate a dedicated entity to lead fraud risk
management, design and implement an antifraud strategy, and use data analytics. Beyond eroding
public trust in government, fraud significantly diminishes each agency’s ability to deliver critical
programs to the communities they are intended to serve.
Plan Now
One of the most effective ways to prevent fraud in emergency programs is to first develop plans for
assessing and addressing the risks for fraud and weaknesses in internal controls prior to program
design and implementation.
Assess Fraud Risks and Internal Control Weaknesses.
• Conduct Gold Standard meetings
among staff from the agency, OIG,
What are Gold Standard meetings?
OMB, and other oversight bodies to
reduce the risks of fraud and improper Following a leading practice initiated for pandemic
payments, as recommended in OMB programs under the American Rescue Plan, OMB
Memo M-22-12 directed agencies to engage with
Memorandum M-22-12, pertaining to
OMB and the agency’s IG in a joint meeting during
implementation of the Infrastructure the program design phase to discuss risk mitigation
Investment and Jobs Act. strategies, financial controls, data, and reporting.
• GAO 22-105051, Additional Actions “This process of engagement by senior Executive
Needed to Improve Accountability Branch and agency officials with Inspectors General
and Program Effectiveness of Federal and the PRAC has become a model for how to manage
Response (p. 1, Recommendation 4) large-scale emergency spending initiatives and
balance the need for robust independent oversight
REC 4: Designate a dedicated entity with timely program administration.” Statement of
and document its responsibilities for Michael E. Horowitz, Chair, Pandemic Response
managing the process of assessing Accountability Committee, before the U.S. House
fraud risks to the unemployment of Representatives Select Subcommittee on the
insurance program, consistent with Coronavirus Crisis, June 14, 2022.
leading practices as provided in our
Fraud Risk Framework. This entity
should have, among other things, clearly defined and documented responsibilities and
authority for managing fraud risk assessments and for facilitating communication among
stakeholders regarding fraud-related issues.
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Chapter 3: Fraud Prevention and Detection
• GAO 150593SP, A Framework for Managing Fraud Risks in Federal Programs
The Framework encompasses control activities to prevent, detect, and respond to fraud, with
an emphasis on prevention, as well as structures and environmental factors that influence
or help managers achieve their objective to mitigate fraud risks. In addition, it highlights the
importance of monitoring and incorporating feedback. There is a presumptive requirement
(as outlined in OMB Circular No. A–11 (2024), based on statutory provisions in the
Payment Integrity Information Act) for programs to adhere to the practices outlined in the
Fraud Risk Framework.
• Program Integrity: The Anti-Fraud Playbook
The playbook provides a four-phased approach with 16 plays drawn from successful
practices from the federal government and private sector to help combat the risk of fraud.
For example:
• Adopt strong fraud-risk assessments to include establishing a dedicated entity to lead
fraud-risk management activities.
• Design and implement strategies or plans for how to identify, assess and mitigate fraud
risk and vulnerabilities in program internal controls.
• GAO 22-105397, Current and Future Federal Preparedness Requires Fixes to Improve Health
Data and Address Improper Payments (pp. 2-3, Recommendations 2, 7, and 8)
REC 2: [T]ake action to identify the causes of the gaps in internal controls and design and
implement additional control activities, where needed, to prevent and detect improper
payments and potential fraud.
REC 7: [D]ocument a comprehensive plan that includes timely and sufficient policies and
procedures for monitoring recipients [...] to provide assurance that funds are being used
in compliance with laws, regulations, agency guidance, and award terms and conditions,
including ensuring that funds are being used for allowable purposes.
REC 8: [D]evelop and implement written procedures to monitor programs and uses of funds
for compliance with program requirements and improper payments.
• GAO 22-105051, Additional Actions Needed to Improve Accountability and Program
Effectiveness of Federal Response (p. 1, Recommendations 5 and 6)
REC 5: Identify inherent fraud risks facing the unemployment insurance program.
REC 6: Assess the likelihood and impact of inherent fraud risks facing the
unemployment insurance program.
• GAO 21-104542 Additional Risk Assessment Actions Could Improve HUD Oversight of CARES
Act Funds (p. 49, Recommendation 1)
REC 1: The Office of the Chief Financial Officer and the HUD CARES Act Compliance
Response Team should work with relevant program offices for each of the six CARES
Act programs that meet HUD’s front-end risk assessment criteria to reassess the need to
either (1) conduct a full front-end risk assessment, or (2) take and document additional risk
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Chapter 3: Fraud Prevention and Detection
assessment steps to align with key aspects of the front-end risk assessment process, such
as ranking risks and developing plans to mitigate identified risks.
• DHS OIG-22-69, FEMA Did Not Implement Controls to Prevent More than $3.7 Billion in Improper
Payments from the Lost Wages Assistance Program (p. 11, Recommendations 1 and 2)
REC 1: Develop and implement a standard risk assessment process before initiating new
federal grant programs. This risk assessment should focus on identifying and evaluating
program risks that may affect FEMA’s ability to prevent waste, fraud, and abuse in its
programs and mitigating those external risks to the extent practical.
REC 2: Develop a process to assess the program controls and identify risk to the extent
practical.
• National Security Agency (NSA) OIG AU-20-0008, Audit of the Implementation of the CARES
Act, Section 3610 (pp. 16-17, Recommendations 3 and 4)
REC 3: Perform a risk assessment of all invoices and processes to determine, at a minimum,
the nature and extent of testing required to sufficiently identify unsupported payments.
REC 4: Perform a review of invoices to ensure accuracy of hours, billing rates, and contractor
COVID-19 status, and, if necessary, recover costs from inaccurate billing.
• GAO 23-105199, SBA Could Improve Communications and Fraud Risk Monitoring for Its Arts
and Entertainment Venues Grant Program (p. 38, Recommendation 2)
REC 2: The Associate Administrator of SBA’s Office of Disaster Assistance should ensure
that its post-award monitoring procedures [...] specifically address the risks the agency has
assessed, including fraud risks, and clearly link them to monitoring activities. As a part of
this effort, SBA should document its tolerance for the risks it has identified.
• GAO 23-105523, Unemployment Insurance: Data Indicate Substantial Levels of Fraud during
the Pandemic; DOL Should Implement an Antifraud Strategy
(p. 42, Recommendation 1)
REC 1: Design and implement an antifraud strategy for Unemployment Insurance (UI)
based on a fraud risk profile consistent with leading practices as provided in the Fraud Risk
Framework.
• GAO 22-105051, COVID-19 Additional Actions Needed to Improve Accountability and Program
Effectiveness of Federal Response (p.1, Recommendation 8)
REC 8: Examine the suitability of existing fraud controls in the UI program and
prioritize residual fraud risks.
• SBA OIG 21-07, Inspection of SBA’S Implementation of the Paycheck Protection Program
(p. 9, Recommendation 2)
REC 2: Assess vulnerabilities in internal controls and strengthen or implement necessary
internal controls to address ineligible loans and potential fraud.
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Chapter 3: Fraud Prevention and Detection
• SBA OIG 21-09, Flash Report: Duplicate Loans Made Under the Paycheck Protection Program
(p. 8, Recommendations 3 and 4)
REC 3: Strengthen E-Tran [SBA electronic loan application system] controls for future
Paycheck Protection Program (PPP)-type programs, which includes keeping E-Tran controls
that align with program requirements on at all times.
REC 4: Review the issues that SBA identified involving the actions of lenders, such as
providing incorrectly formatted data and submitting the same application through multiple
platforms, and determine how to strengthen controls and guidance as appropriate to ensure
lenders meet program requirements for future PPP-type programs.
• Statement of Rebecca Shea, Director, Forensic Audits and Investigative Service. before the U.S.
Senate Subcommittee on Emerging Threats and Spending Oversight, Committee on Homeland
Security and Governmental Affairs, on “Insights and Actions for Fraud Prevention.” (p. 3)
“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.”
• SBA OIG 22-19, Covid-19 And Disaster Assistance Information Systems Security Controls
(p. 7, Recommendation 4)
REC 4: Enforce the requirement to establish and implement internal controls to ensure
appropriate program officials perform and document contract reviews to ensure that
information security is appropriately addressed in the contracting language, as required by
OMB Circular A-130 […]
• GAO 21-191, COVID 19: Urgent Actions Needed to Better Ensure an Effective Federal
Response (p. 3, Recommendation 11)
REC 11: The Secretary of the Treasury should finish developing and implement a compliance
monitoring plan that identifies and responds to risks in the Payroll Support Program to
ensure program integrity and address potential fraud, including the use of funds for
purposes other than for the continuation of employee wages, salaries, and benefits.
• DOL OIG 19-23-016-03-391, COVID-19: The Employment and Training Administration Needs to
Improve Oversight of Grants Awarded in New Jersey (p. 16, Recommendation 3)
REC 3: Develop and implement guidance to specifically identify the high risk associated with
low enrollment levels in combination with the high burn rate of grant funds.
• DOT OIG ST2023001, FTA Can Enhance Its Controls to Mitigate COVID-19 Relief Funding Risks
(p. 22, Recommendation 1)
REC 1: Design or redesign control activities for the four risks:
• Risk of fraud or abuse.
• Recipients may attempt to use funding for a non-operating expense even though they
have furloughed staff.
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Chapter 3: Fraud Prevention and Detection
• Private sector operators are now eligible to become subrecipients.
• Limited capacity of current oversight contracts.
• DHS OIG 22-73, More than $2.6 Million in Potentially Fraudulent LWA Payments Were Linked
to DHS Employees’ Identities (p. 19, Recommendation 1)
REC 1: Develop and implement a standard risk assessment process before initiating new
federal grant programs. This risk assessment should focus on identifying and evaluating
program risks that may affect FEMA’s ability to prevent waste, fraud, and abuse in its
programs and mitigating those external risks to the extent practical.
• FDIC OIG EVAL-23-001, FDIC Examinations of Government-Guaranteed Loans (p. 38,
Recommendation 5)
REC 5: Issue and implement guidance to require that examination staff conduct a fraud-risk
assessment on future government-guaranteed loan programs involving FDIC-insured and
FDIC-supervised financial institutions to inform policy decisions.
• PRAC 2023-02, FRAUD ALERT: PRAC Identifies $5.4 Billion in Potentially Fraudulent Pandemic
Loans Obtained Using Over 69,000 Questionable Social Security Numbers (p. 5, Next Step 1)
Next Step 1: Given the potential negative impacts on individuals who may be victims of
identity fraud [...]: Assess lessons learned across COVID-19 EIDL [Economic Injury Disaster
Loan] and PPP policies, procedures, and internal controls to help improve program integrity
and prevent identity fraud.
• DOL OIG 19-23-012-03-315, Alert Memorandum: ETA Needs to Incorporate Data
Analytics Capability to Improve Oversight of the Unemployment Insurance Program
(p. 10, Recommendation 3)
REC 3: Establish effective controls, in collaboration with state workforce agencies, to
mitigate fraud and other improper payments to ineligible claimants in high-risk age
categories.
• HHS OIG A-02-21-01013, HRSA Made Covid-19 Uninsured Program Payments to Providers
on Behalf of Individuals Who Had Health Insurance Coverage and for Services Unrelated to
Covid-19 (p. 13, Recommendation 3)
REC 3: [S]trengthen [...] procedures that may apply to future programs of a similar
nature to: Expand insurance verifications using additional data fields on each patient for
whom an SSN [Social Security number] is not submitted as part of a prepayment check
or postpayment review process to identify potential exact matches for health insurance
coverage.
• DHS OIG 22-69, FEMA Did Not Implement Controls to Prevent More than $3.7 Billion in
Improper Payments from the Lost Wages Assistance Program (p. 11, Recommendation 3)
REC 3: FEMA Administrator update the State Administrative Plan template to incorporate a
requirement for grantees to include a description of the steps to prevent improper payments.
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Chapter 3: Fraud Prevention and Detection
• HUD OIG 2022-FO-0801, Fraud Risk Inventory for the CDBG and ESG CARES Act Funds
(p. 10, Recommendation 1F)
REC 1F: Develop and implement a fraud analytics strategy using available data,
including but not limited to data and information collected during the grantee risk
assessment and monitoring processes, to begin conducting data analyses to identify
potential fraud risks for further review.
• DHS OIG-22-73, More than $2.6 Million in Potentially Fraudulent LWA Payments Were Linked to
DHS Employees’ Identities (p. 20, Recommendation 6)
REC 6: We recommend the FEMA Administrator develop and implement a process to review
state administrative plans for consistency and ensure they include fraud prevention and
mitigation strategies.
Additional Key Insights from Listening Sessions
Key federal and state stakeholders told us that there should be strong collaboration between
program administrators and their OIGs beginning on day one of any new or enhanced emergnecy
benefit programs. Enabling greater engagement by OIGs on the front-end introduces a new model
of oversight that is better equipped to rapidly respond to evolving risks and prevent fraudulent
payments, rather than continuing to rely on a back-end pay-and-chase model. These gold standard
meetings should be held prior to major changes to existing programs or launches of new programs.
Stakeholders also noted the benefits of evaluating fraud risks and implementing anti-fraud controls
during the design phase of the program, continuously monitoring for fraud and improving anti-fraud
controls in response to emerging trends, and leveraging all data sources to improve fraud prevention
and detection.
Share Information From Fraud Risk and Internal Control Assessments
Communicating information from fraud risks and internal controls strengthens program integrity and
better protects taxpayer funds.
• GAO-15-593SP, A Framework for Managing Fraud Risks in Federal Programs (p. 17)
Establish collaborative relationships with internal and external stakeholders, including other
offices within the agency; federal, state, and local agencies; private-sector partners; law-
enforcement entities; and entities responsible for control activities to, among other things:
• Share information on fraud risks and emerging fraud schemes,
• Share lessons learned related to fraud control activities, and
• Collaborate and communicate with the OIG to improve understanding of fraud risks and
align efforts to address fraud.
• SBA OIG 23-09, COVID-19 Pandemic EIDL and PPP Loan Fraud Landscape
The white paper identifies common fraud indicators and possible corrective actions to fix
internal control weaknesses in SBA’s pandemic programs.
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Chapter 3: Fraud Prevention and Detection
• GAO 24-10722, Key Elements of Fraud Schemes and Actions to Better Prevent Fraud
(p. 19, 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.
• FDIC OIG EVAL-23-001, FDIC Examinations of Government-Guaranteed Loans
(p. 52, Recommendations 15, 16, and 18)
REC 15: Develop and implement processes and procedures for the routine sharing, receipt,
and storage of confidential information with federal agencies that administer government-
guaranteed loan programs.
REC 16: Develop and implement guidance to provide instruction to FDIC bank examination
staff requiring communication and information sharing with federal agencies that administer
government-guaranteed loan programs to ensure FDIC staff and the federal agencies are
aware of any emerging risks.
REC 18: Develop and implement guidance to ensure relevant risk information exchanged
with federal government agencies that administer government-guaranteed loan programs is
shared internally within the FDIC on an ongoing basis with the appropriate FDIC employees.
• SBA OIG 22-17, COVID-19 Economic Injury Disaster Loan Applications Submitted From Foreign
IP Addresses (p. 14, Recommendation 2)
REC 2: Examine controls related to foreign IP addresses and ensure these controls are more
effective in future disaster processing systems.
• Statement by Hannibal “Mike” Ware, Inspector General, Small Business Administration, on
“Stolen Taxpayer Funds: Reviewing The SBA And OIG Reports Of Fraud In Pandemic Lending
Programs.” before the United States House of Representatives Committee on Small Business,
July 13, 2023 (p. 5)
“Our office knew from the onset of pandemic relief that SBA would face a delicate balancing
act of preventing widespread fraud while ensuring timely disbursement of relief funds to
Americans in immediate need. The biggest concern for our office was SBA’s quick delivery
of capital to qualifying small businesses without first establishing the internal controls
necessary to decrease the risk of fraud. This is why we issued two reports prior to the first
PPP loan, or EIDL, being disbursed, stressing the importance of upfront program controls to
mitigate the risk of fraud.
“We proactively recommended internal control measures to SBA and policymakers in real
time to address the allure of easy money that created the golden opportunity for even
otherwise law-abiding citizens to commit fraud. [...]
“In conducting the fraud landscape review, our office unleashed the power of data
analytics in our oversight function. Fueled by the expertise and experience of our criminal
investigators, auditors, and analysts, the report identifies 11 fraud indicators that we use to
signal potential fraud. I have offered additional insights on the various fraud indicators from
the report in my written statement.”
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Chapter 3: Fraud Prevention and Detection
Assess Recipient Eligibility Prior to Award
Prior to providing a recipient funding, program staff should verify the identity of the recipient
through photo identification and other identity validation tools. Staff should also verify that the
recipient is eligible for the program benefits by checking the Treasury’s Do Not Pay list and death
records and verifying tax information and business registration.
Verify Recipient Identity and Eligibility
• Memorandum from Hannibal “Mike” Ware, Key Recommendations Based on Lessons
Learned from Prior COVID-19 Economic Injury Disaster and Paycheck Protection Program Loan
Programs (p. 2)
“Strengthen or establish controls to ensure multiple loans are provided only to eligible
applicants and prevent the erroneous duplication of loans. At a minimum:
• Obtain a photo ID of the applicant to verify their identity.
• Verify that the applicant is not on Treasury’s Do Not Pay list for delinquent child support
and has not been suspended or debarred.
• Verify the applicant is a legitimate business through tax returns, incorporation, not-for-
profit records with secretary of state offices, or another method.
• Institute a 'rule of two' requiring two people to approve each loan application and
eliminate the batch approval process.
• Require human contact with applicants who submit multiple applications from the same
IP addresses, email addresses, physical addresses, or bank account number to verify
these applicants are legitimate.
• Ensure the system promptly identified all risk factors (fraud, duplicate applications, and
information flags) and require full mitigation of those issues before approval.”
• DOL OIG 19-23-016-03-391, COVID-19: The Employment and Training Administration Needs to
Improve Oversight of Grants Awarded in New Jersey (p. 16, Recommendation 5)
REC 5: Establish and implement a plan to improve monitoring activities to ensure grantees
and sub-recipients are properly documenting eligibility.
• Treasury Inspector General for Tax Administration (TIGTA) OIG, 2022-47-030, American
Rescue Plan Act: Implementation of Advance Recovery Rebate Credit Payments
(p. 7, Recommendation 2)
REC 2: If Congress enacts additional stimulus payments, the Commissioner, Wage and
Investment Division, should consider additional programming changes to prevent ineligible
individuals from receiving advance payments, including individuals claimed as dependents
or dependents claimed on multiple returns, nonresident individuals, individuals who had a
filing status or filing partner change, deceased individuals, and individuals affected by the
mentioned related programming errors.
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Chapter 3: Fraud Prevention and Detection
• SBA OIG 21-06, Management Alert, Paycheck Protection Program Loan Recipients on the
Department of Treasury’s Do Not Pay List (p. 5, Recommendation 3)
REC 3: Review prepayment and pre-award procedures and work with Treasury to formulate
a technical approach to use Treasury’s DNP portal to determine loan applicant eligibility and
prevent improper payments before the release of any federal funds.
• PRAC, Fraud Alert Follow-Up: Improved Sharing of Death Records and Use of the Do Not Pay
System Would Strengthen Program Integrity and Better Protect the Public (pp. 2-3)
Verifying borrower information, including SSN and the date of death, helps prevent identity
fraud and ensures government benefits are paid only to those who are eligible. The DNP
system helps government program administrators identify and prevent improper payments
by allowing agencies to check a variety of data sources to verify an applicant’s eligibility to
receive federal funds.
• DOI OIG 2021-ER-015, The Bureaus of Indian Affairs and Indian Education Have the
Opportunity to Implement Additional Controls to Prevent or Detect Multi-dipping of Pandemic
Response Funds (p. 7, Recommendation 1)
REC 1: Develop and implement policies, procedures, or guidance designed to prevent or
detect multi-dipping [receiving funding from more than one federal program is sometimes
referred to as “multi-dipping”]. The practice is not unusual and is not necessarily an
indication of fraud.
Additional Key Insights from Listening Sessions
Stakeholders told us that verifying recipient eligibility is not only a vital internal control for federal
agencies but also for states. Several states are using tools to verify unemployment insurance
eligibility, including documentation of wages or income and cross-matching data with the Social
Security Administration, Department of Motor Vehicles, or other identity databases.
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Chapter 3: Fraud Prevention and Detection
Do Not Rely Only on Self-Certification for Eligibility Requirements
• Statement by Gene Dodaro, Comptroller General of the United States, before the House of
Representative Committee on Ways and Means, on “The Greatest Theft of Taxpayer Dollars:
Unchecked Unemployment Fraud,” February 8, 2023 (p. 5)
“[T]he urgent need to get the money out led to trade-offs that limited the ability of the
government and the states to achieve the accountability and transparency objectives of
the legislation Congress intended. [...] As a result of these trade-offs, self-certification in
particular, these programs were more susceptible to fraud than they would have been
otherwise during the program.”
• Statement by Larry Turner, Inspector General of the U.S. Department of Labor, before the
House of Representative Committee on Ways and Means, on “The Greatest Theft of Taxpayer
Dollars: Unchecked Unemployment Fraud,” February 8, 2023 (p. 39)
“[S]tates were not prepared to process the historic volume of claims, resulting in significant
delays. And this reliance on claimant self-certification rendered the PUA [Pandemic
Unemployment Assistance] program extremely susceptible to fraud, and the unprecedented
infusion of federal funds gave fraudsters a high-value target to exploit. That, combined with
the ease of identity theft and system weaknesses previously identified by the OIG, allowed
criminals to defraud the program.”
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Chapter 3: Fraud Prevention and Detection
Section 2:
Detecting Fraud
Fraud risk indicators and data analytics
are essential for detecting potential fraud. What was the role of identity theft in
In addition, increasing managers’ and pandemic fraud?
employees’ awareness of potential fraud
Key stakeholders indicated that a significant
schemes through training and education
portion of the pandemic fraud occurred due to
can serve a preventive purpose by helping to identify theft from:
create a culture of integrity and compliance
within programs. Moreover, GAO has • Stolen Social Security numbers purchased from
reported that increasing fraud awareness the dark web and used to fraudulently claim
can help prevent and deter fraud. benefits across multiple states.
• Programs with minimal verification requirements
allowing fraudsters to claim identities with little to
Build Necessary no checks.
Infrastructure • Transnational organized crime groups and insiders
having access to personal data.
Federal and state agencies need up-to- • Fraudsters managing hundreds of applications
date IT tools, core administrative systems, from a single IP address, overwhelming systems
and structures such as data analytics without adequate controls.
capabilities in place to effectively scale up
and manage emergency relief programs to
meet a crisis.
Assess and Develop Information Technology Upgrades
• DOL OIG 19-21-004-03-315, COVID-19: States Struggled to Implement CARES
Act Unemployment Insurance (p. 20, Recommendations 1 and 2)
REC 1: Conduct a study to assess the technological needs of the [...] programs to
determine the capabilities that need to be upgraded or replaced; the features necessary
to effectively respond to rapid changes in the volume of claims in times of emergency or
high unemployment; the capabilities needed to ensure effective and equitable delivery of
benefits; and the capabilities to minimize fraudulent activities.
REC 2: Develop, operate, and maintain a modular set of technological capabilities to
modernize the delivery of [...] benefits that is sufficient to manage and process sudden
spikes in claims volume during emergencies or high unemployment.
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• DOL OIG, Alert Memorandum: ETA Needs to Incorporate Data Analytics Capability to Improve
Oversight of the Unemployment Insurance Program (p. 10, Recommendation 2)
REC 2: Create an integrity program that incorporates a data analytics capability and regularly
monitors state unemployment insurance claims data to detect and prevent improper
payments, including fraudulent payments, and to identify trends and emerging issues that
could negatively impact the unemployment insurance program.
• GAO 23-105331, Fraud Schemes and Indicators in SBA Pandemic Programs
(p. 80, Recommendations 1 and 2)
REC 1: The Administrator of SBA, in coordination with the Fraud Risk Management Board,
should ensure that SBA has mechanisms in place and utilizes them to facilitate cross-
program data analytics.
REC 2: The Administrator of SBA, in coordination with the Fraud Risk Management Board,
should ensure that SBA has identified external sources of data that can facilitate the
verification of applicant information and the detection of potential fraud across its programs.
It should then develop a plan for obtaining access to those sources, which may involve
pursuing statutory authority or entering into data-sharing agreement to obtain such access.
• Written testimony, Charles P. Rettig, Commissioner, Internal Revenue Service, before the
House Oversight Committee and Reform Committee Subcommittee on Government Operations
on the Filing Season and IRS Operations, April 21, 2022
“Limited IT resources preclude us from building adequate solutions for efficiently matching
or reconciling data from multiple sources. As a result, we are often left with manual
processes to analyze reporting information we receive. Such is the case with data from
the Foreign Account Tax Compliance Act (FATCA). Congress enacted FATCA in 2010, but we
have yet to be appropriated any significant funding for its implementation. This situation is
compounded by the fact that when we do detect potential non-compliance or fraudulent
behavior through manually generated FATCA reports, we seldom have sufficient funding to
pursue the information and ensure proper compliance.”
• Statement by Michael Horowitz, Hearing on “The Greatest Theft of Taxpayer Dollars:
Unchecked Unemployment Fraud,” before The Committee on Ways and Means House of
Representatives One Hundred Eighteenth Congress, February 8, 2023 (p. 69)
“Fourth, states experienced challenges verifying eligibility because of outdated IT systems
and the mass influx of claims. [...] Among the best practices that we believe should
be replicated are increased use of cross-matching of data between state agencies;
improved coordination between SWAs [state workforce agencies] and state and federal
law enforcement, local IGs, and state auditors; more effective use of enterprise risk
management; increased IT modernization efforts; and the use of advanced data analytics to
build multi-layer fraud defenses, including identity verification tools.”
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Provide Training, Guidance, and Instruction to Program and Oversight Staff
• USAID OIG 4-000-24-001-P, COVID-19: Enhanced Controls Could Strengthen USAID’s
Management of Expedited Procurement Procedures (p. 12, Recommendation 3)
REC 3: Implement procedures to strengthen training on use of noncompetitive action codes
in the Global Acquisition and Assistance System to ensure consistent reporting of use of
other than full and open competition for new and modified awards in the Global Acquisition
and Assistance System and the Federal Procurement Data System, and track use of the
Expedited Procedures Package for Infectious Disease Outbreaks.
• SBA OIG 22-13, SBA’s Handling of Potentially Fraudulent Paycheck Protection Program Loans
(pp. 7, 10, Recommendations 1 and 2)
REC 1: Establish clearly defined and detailed roles, responsibilities, and processes [...] for
managing and handling potentially fraudulent PPP loans to reduce the risk of ineligible
applicants receiving PPP forgiveness and the risk of fraud and financial loss when
implementing similar future programs.
REC 2: Provide lenders formal guidance to effectively and consistently handle potentially
fraudulent PPP loans and ensure lenders have sufficient guidance when implementing
similar future programs.
• FDIC OIG EVAL-23-001, FDIC Examinations of Government-Guaranteed Loans
(p. 43, Recommendation 10)
REC 10: Develop and implement a training plan to ensure examination staff are trained on
the requirements and risks of government-guaranteed loan programs.
• DHS OIG, 22-28, Management Alert – Reporting Suspected Fraud of Lost Wages Assistance
(p. 2, Recommendations 1 and 2)
REC 1: Direct state workforce agencies participating in its Lost Wages Assistance program to
report suspected, alleged, and identified fraud to DHS OIG’s Office of Investigations.
REC 2: Follow up with state workforce agencies in its Lost Wages Assistance program
to reinforce reporting of suspected, alleged, and identified fraud to DHS OIG’s Office of
Investigations.
• GAO 23-105199, SBA Could Improve Communications and Fraud Risk Monitoring for Its Arts
and Entertainment Venues Grant Program (p. 37, Recommendation 1)
REC 1: The Associate Administrator of SBA’s Office of Disaster Assistance should develop
a comprehensive strategy for communicating with potential and actual grant program
applicants in the event of a disaster or other emergency. Such a strategy should provide
guidelines for how to communicate information in a timely and effective manner during
nationwide emergencies (such as pandemics) and for doing so for any future industry-
specific emergency assistance programs.
Pandemic Response Accountability Committee 14
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
• SBA OIG 24-06, Evaluation of SBA’s Eligibility and Forgiveness Reviews of Paycheck Protection
Program Loans Made to Borrowers with Treasury’s Do Not Pay Data Matches
(p. 10, Recommendation 5)
REC 5: Develop and implement clear guidance requiring responsible officials to maintain
documentary evidence used to support loan decisions in the loan files.
• DOL OIG 19-23-016-03-391, COVID-19: The Employment and Training Administration Needs to
Improve Oversight of Grants Awarded in New Jersey (p. 16, Recommendation 6)
REC 6: Establish and implement a plan to increase the level of technical assistance and
monitoring for grantees and sub-recipients to ensure they properly administer contracts and
reimburse on-the-job training costs.
• SBA OIG 21-03, EVALUATION OF CARES ACT DEBT RELIEF TO 7(A) BORROWERS
(p. 9, Recommendation 2)
REC 2: Establish post-payment audit procedures, using a risk-based approach, to verify
the accuracy and completeness of all subsidy payments to lenders and include reviews of
payments made to loans that changed from liquidation status to regular servicing status,
and remedy improper payments in accordance with the Payment Integrity Act of 2019.
• DOL OIG 19-23-014-03-315, COVID-19: Pandemic Unemployment Assistance for Non-
Traditional Claimants Weakened by Billions in Overpayments, Including Fraud
(p. 23, Recommendations 1 and 2)
REC 1: Develop a document that captures lessons learned from the implementation of the
pandemic-related UI programs that can be used to provide legislative technical assistance
and operational guidance to Congress and states on any future emergency UI programs,
including an assessment of fraud and fraud prevention methods in programs that allow for
self-certification.
REC 2: Provide guidance to states regarding the criminal statute of limitations, which could
impact the ability to criminally charge individuals that engaged in pandemic-related UI fraud.
Guidance should recommend that states identify and promptly refer pandemic-related UI
fraud cases for criminal investigation. This directive should also emphasize the importance
of cooperation between states and law enforcement agencies, making specific reference to
Unemployment Insurance Program Letter 04-17.
• HUD OIG 2022-FO-0801, Fraud Risk Inventory for the CDBG and ESG CARES Act Funds
(p. 9, Recommendation 1D)
REC 1D: Implement efforts to increase the awareness of fraud at all levels (headquarters,
field offices, grantees, subrecipients, etc.), including but not limited to regularly publishing
articles on known fraud schemes and identified instances of fraud [...], providing recurring
fraud risk trainings.
Pandemic Response Accountability Committee 15
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
Institute Federal to Federal, State to State, Federal to State Data Sharing
• DOL OIG 19-22-006-03-315, COVID-19: ETA and States Did Not Protect Pandemic-Related UI
Funds from Improper Payments Including Fraud or from Payment Delays
(p. 26, Recommendation 4)
REC 4: Work with National Association of State Workforce Agencies to ensure the Integrity
Data Hub cross-matches are effective at preventing the types of fraud that were detected
during the pandemic and regularly update using the results of state fraud investigations.
• DOL OIG 19-23-011-03-315, COVID-19 – ETA Can Improve its Oversight to Ensure Integrity over
CARES Act UI Programs (p. 7, Recommendation 3)
REC 3: Determine the best threshold for flagging multistate claims in conjunction with the
National Association of State Workforce Agencies (NASWA).
• GAO 21-191, COVID 19: Urgent Actions Needed to Better Ensure an Effective Federal
Response (p. 2, Recommendation 8)
REC 8: The Secretary of Labor should ensure the Office of Unemployment Insurance pursues
options to report the actual number of distinct individuals claiming benefits, such as by
collecting these already available data from states, starting from January 2020 onward.
• DOL OIG 19-23-012-03-315, Alert Memorandum: ETA Needs to Incorporate Data Analytics
Capability to Improve Oversight of the Unemployment Insurance Program
(p. 10, Recommendation 1)
REC 1: Obtain direct access to unemployment insurance claims data from all state
workforce agencies.
• DOL OIG 19-21-004-03-315, COVID-19: States Struggled to Implement CARES Act
Unemployment Insurance (p. 21, Recommendation 3)
REC 3: Assist states with claims, overpayment, and fraud reporting to create clear and
accurate information. Then use the overpayment and fraud reporting to prioritize and assist
states with fraud detection and recovery.
• DOJ OIG 22-109, Audit of the Management and Coordination of Pandemic-Related Fraud
Allegations and Referrals Between the Criminal Division and Executive Office for U.S. Attorneys
(pp. 22-23, Recommendations 1 and 6)
REC 1: Implement a system to ensure regular and uniform communication for pandemic-
related updates, to include informing USAO [U.S. Attorney Office] districts on information
shared within national coordinating bodies.
REC 6: Work with the Executive Office for U.S. Attorneys to implement methods to share
pandemic fraud case information, particularly regarding PPP-related matters, for reference in
possible overlap with USAO-led UI matters.
Pandemic Response Accountability Committee 16
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
• DOL OIG 19-23-014-03-315, COVID-19: Pandemic Unemployment Assistance for
Non-Traditional Claimants Weakened by Billions in Overpayments, Including Fraud
(p. 23, Recommendation 2)
REC 2: Provide guidance to states regarding the criminal statute of limitations, which could
impact the ability to criminally charge individuals that engaged in pandemic-related UI fraud.
Guidance should recommend that states identify and promptly refer pandemic-related UI
fraud cases for criminal investigation. This directive should also emphasize the importance
of cooperation between states and law enforcement agencies, making specific reference
to Unemployment Insurance Program Letter 04-17, Change 1 - Attachment I, concerning
activity that must be reported to the OIG.
Ensure Data Accuracy and Integrity
• SBA OIG 21-02, Inspection of Small Business Administration’s Initial Disaster Assistance
Response to the Coronavirus Pandemic (p. 28, Recommendation 6)
REC 6: Strengthen data integrity to make it possible to determine if the inaccurate
information allowed loans to be made to ineligible entities and to strengthen SBA’s ability to
service loans appropriately.
• DHS OIG, 23-42, Ineffective Controls Over COVID-19 Funeral Assistance Leave the Program
Susceptible to Waste and Abuse (p. 20, Recommendation 4a)
REC 4a: Design internal controls that distinguish between legitimate sources of potential
program duplications, such as program applications that share decedents’ names or Social
Security numbers, from system-generated potential duplications that arise due to using re-
purposed data processing systems.
• Statement of David Smith, Assistant Director, Office of Investigations, U.S. Secret Service,
before the House of Representatives Committee on Oversight and Accountability, on “Federal
Pandemic Spending: A Prescription for Waste, Fraud, and Abuse,” February 1, 2023 (p. 80)
“What we were doing was sharing indicators of compromise with those entities, such as if
an individual was using an IP address that was from an overseas originating point, or if a
financial institution saw, if you happen to see an account being opened fairly recently and
that account was being used to move a substantial amount of money in a short period of
time, that would be something you would flag.”
Pandemic Response Accountability Committee 17
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
Section 3:
Responding to Fraud
In addition to attempting to prevent and detect fraud at the outset, the government can stop
suspicious payments, put fraudsters in prison, and recover illegally obtained funds. These
actions require that federal agencies have policies in place to suspend payments, efficiently
recover funds, and retain data necessary to investigate loans and prosecute individuals who
fraudulently received benefits.
Stop Payments and Recover Funds
When fraud does occur, it is important that federal agencies take action to minimize the funding
that bad actors are able to access. This can be done by stopping all payments once fraud is
suspected and recovering funds where possible. In addition, agencies can take administrative
actions against those committing fraud through suspension and debarment.
Suspend Potential Improper or Fraudulent Payments
• SBA OIG 22-17, COVID-19 Economic Injury Disaster Loan Applications Submitted From Foreign
IP Addresses (p. 14, Recommendation 1)
REC 1: Thoroughly review each grant and advance application submitted from foreign IP
addresses that were approved and funded and verify eligibility. If ineligibility or evidence of
potential fraud is found, SBA should stop any further or future disbursements, recover any
disbursed funds, and refer fraudulent loans to OIG for investigation.
• SBA OIG 21-02, Inspection of Small Business Administration’s Initial Disaster Assistance
Response to the Coronavirus Pandemic (pp. 18, 28, 30, Recommendations 1, 3, and 7)
REC 1: Review all loans that had a bank account number changed from that shown on
the original application to determine if the changes were legitimate or fraudulent. If not
legitimate, work to recover the funds, de-obligate any undisbursed funds, and refer to the OIG.
REC 3: Review duplicate loans to IP addresses, email addresses, business addresses, and
bank accounts to determine if there are undisbursed funds that should be suspended until
the duplicate loans are assessed for eligibility.
REC 7: Review the applicants with approved loans to determine if there are undisbursed
funds remaining that should be suspended until the business start date is verified and the
applicant is deemed eligible based on the CARES Act eligibility requirements. If the applicant
is deemed ineligible, recover any disbursed funds, de-obligate any undisbursed funds, and
flag the application as ineligible.
Pandemic Response Accountability Committee 18
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
• SBA OIG 23-08, Serious Concerns Regarding the Return of PPP Funds
(p. 5, Recommendation 4)
REC 4: Provide detailed guidance to financial institutions that receive PPP fund deposits for
borrowers regarding how to return PPP funds if there is suspected fraud or other issues that
would warrant returning funds.
• SBA OIG 23-10, SBA’s Administrative Process to Address Potentially Fraudulent Restaurant
Revitalization Fund Awards (p. 8, Recommendation 1)
REC 1: Prioritize and complete the review of [...] awards that were flagged by the point-of-
sale partner as having unsupported gross sales and take appropriate administrative actions
to recover improper payments, which includes 110 awards that were suspected of fraud.
Mandate Data and Record Retention
• SBA OIG 23-15, SBA’s Oversight of Restaurant Revitalization Fund Recipients
(p. 13, Recommendation 3)
REC 3: Extend the record retention period and notify all RRF award recipients in writing in
accordance with 2 CFR 200.334.
• SBA OIG 24-06, Evaluation of SBA’s Eligibility and Forgiveness Reviews of Paycheck Protection
Program Loans Made to Borrowers with Treasury’s Do Not Pay Data Matches
(p. 10, Recommendation 5)
REC 5: Develop and implement clear guidance requiring responsible officials to maintain
documentary evidence used to support loan decisions in the loan files.
Recover Funds Obtained Fraudulently or Improperly
• DHS OIG 22-69, FEMA Did Not Implement Controls to Prevent More than $3.7 Billion in
Improper Payments from the Lost Wages Assistance Program (p. 11, Recommendation 7)
REC 7: FEMA Administrator de-obligate and recover any monies determined to have been
obtained fraudulently or other improper payments through Lost Wages Assistance from the
state workforce agencies.
• SBA OIG 21-02, Inspection of Small Business Administration’s Initial Disaster Assistance
Response to the Coronavirus Pandemic (p. 18, Recommendation 1)
REC 1: Review all loans that had a bank account number changed from that shown on
the original application to determine if the changes were legitimate or fraudulent. If not
legitimate, work to recover the funds, de-obligate any undisbursed funds, and refer to
the OIG.
• SBA OIG 21-06, Management Alert, Paycheck Protection Program Loan Recipients on the
Department of Treasury’s Do Not Pay List (p. 5, Recommendation 2)
REC 2: Strengthen [...] controls to ensure that loans to ineligible recipients are not forgiven.
Pandemic Response Accountability Committee 19
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
• SBA OIG 21-09, Flash Report: Duplicate Loans Made Under the Paycheck Protection Program
(p. 8, Recommendation 2)
REC 2: Review SBA controls related to all PPP loan reviews to ensure that duplicate loans
are not forgiven and not subject to an SBA guaranty, as appropriate.
• SBA OIG 24-02, SBA’s Internal Controls to Prevent Shuttered Venue Operators Grants to
Ineligible Applicants (p. 16, Recommendation 2)
REC 2: Implement additional controls to ensure that, during the monitoring, auditing, and
compliance phases, awards are carefully screened to verify eligibility and to recover grant
funds from ineligible entities.
• SBA OIG 21-15, SBA’s Handling of Identity Theft in the COVID-19 Economic Injury Disaster
Loan Program (p. 9, Recommendation 5)
REC 5: Review returned billing statements and resolve any that involve identity theft, then
refer fraudulent loans to OIG.
• SBA OIG 23-08, Serious Concerns Regarding the Return of PPP Funds
(p. 5, Recommendation 1)
REC 1: Provide detailed guidance to borrowers on returning PPP funds to lenders if the loan
was forgiven or guaranty purchased.
• SBA OIG 23-10, SBA’s Administrative Process to Address Potentially Fraudulent Restaurant
Revitalization Fund Awards (p. 8, Recommendation 1)
REC 1: Prioritize and complete the review of [...] awards that were flagged by the point-of-
sale partner as having unsupported gross sales and take appropriate administrative actions
to recover improper payments, which includes 110 awards that were suspected of fraud.
• SBA OIG 23-15, SBA’s Oversight of Restaurant Revitalization Fund Recipients
(pp. 13, 15, Recommendations 4 and 6)
REC 4: Assess the post-award review process and manpower requirements to ensure post
award reviews are conducted in a prompt manner. Use the results of the assessment to
improve processing times to ensure reviews are completed before the statute of limitations
expire.
REC 6: Establish and implement procedures to recover unused funds or recover funds paid
to ineligible recipients and prioritize this effort.
• SBA OIG 21-06, Management Alert, Paycheck Protection Program Loan Recipients on the
Department of Treasury’s Do Not Pay List (p. 5, Recommendation 2)
REC 2: Strengthen SBA controls to ensure that loans to ineligible recipients are not forgiven.
Pandemic Response Accountability Committee 20
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
• SBA OIG 24-06, Evaluation of SBA’s Eligibility and Forgiveness Reviews of Paycheck Protection
Program Loans Made to Borrowers with Treasury’s Do Not Pay Data Matches
(pp. 6, 10, Recommendations 1 and 3)
REC 1: Review [...] PPP loans [...] that matched a DNP data source, to ensure eligibility
requirements were met and seek remedy or repayment of all loans deemed ineligible.
REC 3: Conduct a review of PPP loans, in which the DNP hold-codes were cleared to identify
(1) those cleared using pre-decisional memos and (2) those cleared without sufficient
evidence to support the reviewer’s loan decision and seek remedy or repayment of loans
deemed ineligible.
• GAO -20-625, Covid-19 Opportunities to Improve Federal Response and Recovery Efforts
(p. 2, Recommendation 2)
REC 2: The Commissioner of Internal Revenue should consider cost-effective options for
notifying ineligible recipients on how to return payments.
• PRAC, FRAUD ALERT: PRAC Identifies $5.4 Billion in Potentially Fraudulent Pandemic Loans
Obtained Using Over 69,000 Questionable Social Security Numbers (p. 5, Next Step 2)
Next Step 2: Further examine the potential identity fraud we have identified using
collaborative verification methods to determine which instances are likely fraud, with SBA
taking appropriate action to recover fraudulently obtained funds.
• United States Department of Agriculture (USDA) OIG Inspection Number 03801-0001-31,
COVID-19 – Coronavirus Food Assistance Program – Direct Support (p.5, Recommendation 1)
REC 1: Review and recover the questioned Coronavirus Food Assistance Program payments
of $1,286,786 resulting from inaccurate and/or unsupported producer certifications.
• DOL OIG 19-23-015-03-315, Covid-19: ETA Needs a Plan to Reconcile and Return to the
U.S. Treasury Nearly $5 Billion Unused by States for a Temporary Unemployment Insurance
Program (p. 20, Recommendation 1)
REC 1: Work with Oregon, Louisiana, Delaware, and Mississippi to ensure the appropriate
return of approximately $105.1 million in TFFF [Temporary Full Federal Funding]
reimbursements for first-week regular UI compensation paid that were associated with
ineligible weeks.
• TIGTA 2022-47-030, American Rescue Plan Act: Implementation of Advance Recovery Rebate
Credit Payments (p. 5, Recommendation 1)
REC 1: The Commissioner, Large Business and International Division, should coordinate
with the territories to share information that will enable the territories to recover duplicate
payments that the territories have issued, to the extent permitted under the relevant
territory’s domestic law.
Pandemic Response Accountability Committee 21
Blueprint for Enhanced Program Integrity
Chapter 3: Fraud Prevention and Detection
• Statement of Gene L. Dodaro, Comptroller General of the United States, before the House of
Representatives Select Subcommittee on the Coronavirus Crisis, Committee on Oversight and
Government Reform, on “COVID-19 Opportunities to Improve Federal Response and Recovery
Efforts,” June 26, 2020
GAO identified challenges with the federal response to the crisis, including:
“Economic impact payments. The Internal Revenue Service and the Department of the
Treasury faced difficulties delivering payments to some individuals, and made some
payments to ineligible individuals, such as decedents. GAO recommends that IRS should
consider cost-effective options for notifying ineligible recipients how to return payments.”
Pandemic Response Accountability Committee 22
APPENDIX 3-A:
Objective, Scope,
and Methodology
The objective of Chapter 3 was to compile leading practices, resources, and lessons learned
from reports and recommendations issued by the oversight community related to detecting and
preventing fraud in pandemic programs.
The goal was to provide solutions for the design and implementation of future programs that can
be adopted by federal and state agencies prior to or at the outset of an emergency.
Our review period was January 2020 through August 2024. We reviewed reports from the oversight
community to identify recommendations applicable to Chapter 3. In addition, we reviewed all of the
Pandemic Response Accountability Committee’s (PRAC) Semiannual Reports to Congress and
reports published by federal OIGs. To ensure we identified an accurate and complete list of reports
and recommendations, we compared our document review with reports posted on Oversight.gov.
We also reviewed published reports from the Government Accountability Office and guidance
memoranda from the Office of Management and Budget. We held listening sessions with key
stakeholders, OIG officials, state officials, and national associations. During each listening session,
we asked the stakeholders to identify reports, key takeaways, lessons learned, and best practices
from their experiences during the pandemic that could be used in the future. We do not consider
the reports used in this product to be an exhaustive list.
Based on the foundational work above, we identified key themes in the recommendations and
added links to supporting reports. Stakeholders across the federal oversight community reviewed
a draft of this report prior to publication. This work was completed between March and October
2024.
Pandemic Response Accountability Committee 23
Blueprint for Enhanced Program Integrity
Chapter 2: Opportunities for Policymakers to Improve Program Integrity
Contributing Partners
With our thanks to the following stakeholders for sharing key recommendations, leading practices,
and lessons learned, which are incorporated throughout Chapter 3 of the Blueprint:
Pandemic Response Accountability Committee Members
Inspector General Sandra D. Bruce, Department of Education
Inspector General Joseph Cuffari, Department of Homeland Security
Inspector General Rae Oliver Davis, Department of Housing and Urban Development
Deputy Acting Inspector General Richard Delmar, Department of the Treasury
Inspector General Jennifer L. Fain, Federal Deposit Insurance Corporation
Inspector General Phyllis K. Fong, Department of Agriculture
Inspector General Mark Lee Greenblatt, Department of the Interior
Inspector General Christi A. Grimm, Department of Health & Human Services
Acting Inspector General, Heather Hill, Treasury Inspector General for Tax Administration
Inspector General Michael J. Missal, Department of Veterans Affairs
Inspector General Eric J. Soskin, Department of Transportation
Inspector General Robert P. Storch, Department of Defense
Inspector General Larry D. Turner, Department of Labor
Inspector General Hannibal “Mike” Ware, Small Business Administration
Chapter 3 Team
From SBA OIG: From the PRAC:
Michelle Blank, Co-Lead Eugene Gray, Co-lead
Mitchell Palmertree, Co-lead
From DHS OIG: Alice Siempelkamp
Yesenia Starinsky Sansara Cannon
Noelle Zinkgraf
From VA OIG: Tyrone Gillins
Victorial Coleman Jessica Hatter
Ashley Wilson
From HHS OIG: Carly Schippits
Chris Covington Jenn Contreras
Lynn Houston
Jarrett Fussell
Kirstyn Flood
Pandemic Response Accountability Committee 24
For more information:
Lisa Reijula
Associate Director of Outreach and Engagement, PRAC
Lisa.Reijula@cigie.gov
Visit us at:
PandemicOversight.gov
Follow us at:
Report Fraud, Waste, Abuse, or Misconduct:
To report allegations of fraud, waste, abuse, or misconduct regarding
pandemic relief funds or programs please go to the PRAC website at
PandemicOversight.gov.
A Committee of the
Council of the Inspectors General
on Integrity and Efficiency
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