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GAO-25-107588, COVID-19: Update on Key Indicators, the Federal Response, and Implementation of GAO Recommendations

Issuer
Government Accountability Office
Document type
Report
Date
2025-03-31

Summary

A U.S. Government Accountability Office report to congressional committees, GAO-25-107588, dated July 2025 with a transmittal letter of July 31, 2025, updating key COVID-19 indicators and the status of GAO recommendations as of March 2025. The report states that the federal government provided about $4.65 trillion in relief funds and that fraud-related charges had been brought against at least 3,205 defendants, of whom 2,331 had been convicted as of March 31, 2025. It reports that GAO's pandemic work produced 484 recommendations to Congress and federal agencies, with at least $43.9 billion in financial benefits, and that 200 recommendations remain open. The report describes its methodology, the six COVID-19 relief laws, and the federal public health and economic response, and it lists tables and figures on spending, deaths, inflation and fraud sentences.

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Full text

                United States Government Accountability Office
                Report to Congressional Committees




                COVID-19
July 2025




                Update on Key
                Indicators, the Federal
                Response, and
                Implementation of
                GAO
                Recommendations




GAO-25-107588
                                   COVID-19

                                   Update on Key Indicators, the Federal Response, and
     Highlights                    Implementation of GAO Recommendations

 GAO-25-107588                     July 2025

 Highlights of GAO-25-107588, a report to congressional committees.

                                                                      Examples of Financial and Non-Financial Benefits from
                                                                      GAO Work Related to the COVID-19 Pandemic as of March
 Why This Matters                                                     2025
 The COVID-19 pandemic caused catastrophic loss of
 life and damage to the economy. The federal
 government provided about $4.65 trillion in relief funds
 for response and recovery efforts. Although the federal
 emergency expired in May 2023, public health and
 economic challenges persist. The CARES Act includes
 a provision for GAO to report regularly on pandemic
 impacts and the federal response.




GAO Key Takeaways
Updates to key COVID-19 indicators as of March 2025
include the following:

Public health. COVID-19 deaths and hospitalizations
have decreased overall, but public health impacts
continued. For example, about 450 deaths were reported
in March 2025.
Economic conditions. The economy has generally
recovered from the downturn, but recovery in some                     How GAO Did This Study
areas has slowed somewhat. For example, inflation
remained elevated compared with pre-pandemic levels.                  To provide key updates on public health, the economy,
Relief spending and fraud. The U.S. spent almost all                  and pandemic-related spending and fraud, GAO
COVID-19 relief funding. The full extent of fraud will                analyzed federal data and public statements and
never be known with certainty, but estimates indicate                 reviewed relevant literature. To provide updates on the
hundreds of billions of dollars in fraudulent payments                status of recommendations, GAO reviewed previously
were made. Fraud-related charges have been brought                    issued CARES Act reports and collected updates from
against at least 3,205 defendants. Of those, 2,331                    federal agencies.
defendants have been convicted as of March 31, 2025.
Extending the statute of limitations for such violations              What GAO Recommends
would provide more time to investigate fraud.
                                                                      Congress and federal agencies are in the unique
GAO work on the pandemic has resulted in over 200                     position to critically consider lessons from the COVID-19
products and 484 recommendations to Congress and                      response to better prepare for inevitable future
federal agencies. Over half of these have been closed.                emergencies. Two hundred GAO recommendations
This has led to at least $43.9 billion in financial benefits,         remain open that may provide such opportunities.
among other improvements. For example, GAO
recommendations helped save over $14.8 billion based
on program integrity improvements to small business
loans and grants.                                                      For more information, contact:Jessica Farb at
                                                                       farbj@gao.gov.

                                                                                   United States Government Accountability Office
Contents


Letter                                                                               1
             Background                                                              3
             Updates to Key Indicators Examining Public Health and Economic
               Effects of the COVID-19 Pandemic and Information on Relief
               Funding, Spending, and Fraud Cases                                    6
             Progress Made Addressing GAO Recommendations from the
               COVID-19 Pandemic Response, but Opportunities for
               Improvement Remain                                                  23
             Conclusions                                                           35
             Agency Comments                                                       35

Appendix I   GAO Contact and Staff Acknowledgments                                 39


Tables
             Table 1. Major Spending Areas Under COVID-19 Relief Funding
                     as of March 31, 2025                                          16
             Table 2: Largest Unexpired Unobligated Balances Under COVID-
                     19 Relief Funding as of March 31, 2025                        18
             Table 3: Prior GAO Matters for Congressional Consideration to
                     Ensure Transparency and Accountability for COVID-19
                     and Beyond that Remain Open and Unimplemented as of
                     March 2025                                                    33

Figures
             Figure 1: COVID-19 Relief Laws                                          4
             Figure 2: Weekly Number of U.S. COVID-19-Associated Deaths,
                      March 2020 Through March 2025                                  7
             Figure 3: Annual Rate of U.S. COVID-19-Associated Deaths, 2020
                      Through 2024                                                   8
             Figure 4: Weekly Rate of COVID-19 Hospitalizations, March 2020
                      Through March 2025                                             9
             Figure 5: Examples of Signs, Symptoms, and Conditions
                      Associated with Long COVID                                   10
             Figure 6: Percentage Change in Inflation Indicators from the
                      Previous Month, March 2019 Through March 2025                13
             Figure 7: Labor Market Trends, March 2019 Through March 2025          15
             Figure 8: Prison Sentences for Defendants Convicted of Fraud-
                      Related Charges Involving COVID-19 Relief Programs,
                      as of March 31, 2025                                         21



             Page i                                  GAO-25-107588 COVID-19 2025 Update
Figure 9: Court-Ordered Restitution for Defendants Convicted of
         Fraud-Related Charges Involving COVID-19 Relief
         Programs, as of March 31, 2025                                                   22




Abbreviations

CDC                     Centers for Disease Control and Prevention
COVID-19 EIDL           COVID-19 Economic Injury Disaster Loan
CPI                     Consumer Price Index
DOJ                     Department of Justice
DOL                     Department of Labor
FEMA                    Federal Emergency Management Agency
GDP                     gross domestic product
HHS                     Department of Health and Human Services
HRSA                    Health Resources and Services Administration
IRS                     Internal Revenue Service
OMB                     Office of Management and Budget
PPP                     Paycheck Protection Program
SBA                     Small Business Administration
SLFRF                   Coronavirus State and Local Fiscal Recovery Funds
UI                      unemployment insurance
VA                      Department of Veterans Affairs


Cover image source: blvdone/stock.adobe.com




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Page ii                                              GAO-25-107588 COVID-19 2025 Update
                       Letter




441 G St. N.W.
Washington, DC 20548




                       July 31, 2025

                       Congressional Committees

                       The COVID-19 pandemic was an unprecedented global crisis that
                       resulted in catastrophic loss of life and substantial damage to the global
                       economy. In the U.S., the pandemic led to over a million deaths and
                       weakened the labor market. While the Secretary of the Department of
                       Health and Human Services (HHS) terminated the federal public health
                       emergency on May 11, 2023, COVID-19 continues to have an impact on
                       the nation’s public health and economy.1

                       Since March 2020, the CARES Act and five additional laws provided
                       about $4.65 trillion in federal funding to help the nation respond to and
                       recover from the pandemic.2 The COVID-19 relief funds provided
                       resources for the federal response. This included a focus on mitigating
                       COVID-19 health risks and providing relief to support individuals and
                       public and private entities. Agencies across the federal government
                       worked to implement this federal response.

                       The CARES Act includes a provision for GAO to report regularly on the
                       public health and economic effects of the pandemic and the federal

                       1HHS first declared the COVID-19 pandemic a public health emergency under section 319
                       of the Public Health Service Act on January 31, 2020. In addition, on March 13, 2020, the
                       President declared COVID-19 a national emergency under the National Emergencies Act
                       and a nationwide emergency under section 501(b) of the Robert T. Stafford Disaster
                       Relief and Emergency Assistance Act (Stafford Act). The President also approved major
                       disaster declarations under the Stafford Act for all 50 states, the District of Columbia, five
                       U.S. territories, and certain Tribes. The national emergency declaration terminated on
                       April 10, 2023, and the Stafford Act declaration terminated on May 11, 2023.
                       2For the purpose of our review, the COVID-19 relief laws consist of the six laws providing
                       comprehensive relief across federal agencies and programs that the Department of the
                       Treasury uses to record and track COVID-19 relief spending in accordance with guidance
                       issued by the Office of Management and Budget (OMB). These six laws are the American
                       Rescue Plan Act of 2021, Pub. L. No. 117-2, 135 Stat. 4; Consolidated Appropriations Act,
                       2021, Pub. L. No. 116-260, div. M and N, 134 Stat. 1182 (2020); Paycheck Protection
                       Program and Health Care Enhancement Act, Pub. L. No. 116-139, 134 Stat. 620 (2020);
                       CARES Act, Pub. L. No. 116-136, 134 Stat. 281 (2020); Families First Coronavirus
                       Response Act, Pub. L. No. 116-127, 134 Stat. 178 (2020); and the Coronavirus
                       Preparedness and Response Supplemental Appropriations Act, 2020, Pub. L. No. 116-
                       123, 134 Stat. 146. Further, the approximate $4.65 trillion accounts for (i.e., subtracts out)
                       the permanent rescissions enacted in the Fiscal Responsibility Act of 2023, Pub. L. No.
                       118-5, 137 Stat. 10, 23-30, div. B, tit. I, as well as rescissions of COVID-19 relief funding
                       enacted in any other applicable law.



                       Page 1                                                 GAO-25-107588 COVID-19 2025 Update
response.3 We have issued 12 comprehensive reports examining the
federal government’s efforts to respond to and recover from the COVID-
19 pandemic. In addition, we have issued over 200 standalone reports,
testimonies, and science and technology spotlights focused on different
aspects of the pandemic.

This report includes information on the status of key indicators examining
public health, the economy, and federal COVID-19 relief funding,
spending, and fraud cases. It also provides an update on the status of
GAO recommendations related to the COVID-19 pandemic and the
federal response as of March 2025.

To provide updates on key indicators of the public health and economic
effects of the pandemic, we used data from the Centers for Disease
Control and Prevention (CDC) and reviewed literature and data on the
economic recovery from the COVID-19 pandemic related to gross
domestic product, inflation, and unemployment. To provide updates on
COVID-19 relief programs and related fraud, we analyzed (1) data from
the Department of the Treasury (Treasury) on federal COVID-19 relief
funding and spending and (2) public statements from the Department of
Justice (DOJ) regarding federal COVID-19 fraud-related cases.4 To
assess the reliability of data on key indicators of the public health and
economic effects of the pandemic, as well as data on federal COVID-19
relief funding and spending, we examined relevant documentation. In
some cases, we also conducted simple data checks. We determined that
these data were sufficiently reliable for the purpose of our objective.



3Pub. L. No. 116-136, § 19010, 134 Stat. at 579–81. The American Rescue Plan Act of
2021 also includes a provision for us to conduct oversight of the COVID-19 response.
Pub. L. No. 117-2, § 4002, 135 Stat. at 78.
4To provide updates on COVID-19 relief program funding and spending, we reviewed data
reported by applicable agencies to Treasury. These data do not include certain tax
expenditures from federal tax relief programs, such as the employee retention credit, paid
sick and family leave credits, and payroll tax deferrals. To determine the status of cases
announced by DOJ that have fraud-related charges involving COVID-19 relief programs,
we reviewed public statements from DOJ from March 2020 through March 31, 2025.
Specifically, we identified cases involving various federal COVID-19 relief programs,
including but not limited to the Paycheck Protection Program (PPP), COVID-19 Economic
Injury Disaster Loan (COVID-19 EIDL), and Unemployment Insurance (UI) programs. We
identified these cases using the official press releases posted on the Offices of the United
States Attorney’s website. We also analyzed corresponding court documentation available
in Public Access to Court Electronic Records to determine the current case status and
obtain additional details.




Page 2                                               GAO-25-107588 COVID-19 2025 Update
             To provide updates on the status of GAO recommendations related to the
             COVID-19 pandemic, we reviewed our previously issued comprehensive
             and standalone CARES Act reports and collected updates from federal
             agencies to monitor their progress toward addressing our
             recommendations.5 We also selected a set of our prior recommendations
             to describe in greater detail in our report. We selected these examples to
             include recommendations—both open and closed—we made to improve
             the public health response, provision of economic relief, and oversight of
             economic relief funds.

             We conducted this performance audit from May 2024 to July 2025 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.

             About $4.65 trillion in pandemic funding was provided through six COVID-
Background   19 relief laws enacted in 2020 and 2021 (see fig. 1).6




             5Recommendations were directed to the relevant agencies and operational divisions at
             the time of the recommendation.
             6For the purpose of our review, the COVID-19 relief laws consist of the six laws providing
             comprehensive relief across federal agencies and programs that Treasury uses to record
             and track COVID-19 relief spending in accordance with guidance issued by OMB. These
             six laws are the American Rescue Plan Act of 2021, Pub. L. No. 117-2, 135 Stat. 4;
             Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. M and N, 134 Stat. 1182
             (2020); Paycheck Protection Program and Health Care Enhancement Act, Pub. L. No.
             116-139, 134 Stat. 620 (2020); CARES Act, Pub. L. No. 116-136, 134 Stat. 281 (2020);
             Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 178 (2020); and
             the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020,
             Pub. L. No. 116-123, 134 Stat. 146. Further, the approximate $4.65 trillion accounts for
             (i.e., subtracts out) the permanent rescissions enacted in the Fiscal Responsibility Act of
             2023, Pub. L. No. 118-5, 137 Stat. 10, 23-30, div. B, tit. I, as well as rescissions of COVID-
             19 relief funding enacted in any other applicable law.




             Page 3                                                GAO-25-107588 COVID-19 2025 Update
                            Figure 1: COVID-19 Relief Laws




                            Note: The COVID-19 relief laws consist of the six laws providing comprehensive relief across federal
                            agencies and programs that the Department of the Treasury uses to record and track COVID-19 relief
                            spending, in accordance with guidance issued by the Office of Management and Budget.


                            These COVID-19 relief funds provided resources for the federal
                            response, which included activities to mitigate the pandemic’s impacts on
                            public health and the economy.

Response to Public Health   The federal government has played a key role in mitigating the
Impacts                     pandemic’s impact on public health. COVID-19 relief funds, combined
                            with existing public health funding streams, provided resources for
                            various components of the public health response, including the following:

                            •    Deployment of Strategic National Stockpile assets. Overseen by
                                 the Administration for Strategic Preparedness and Response within
                                 HHS, the Strategic National Stockpile is a multibillion-dollar federal
                                 inventory of medical countermeasures—drugs, vaccines, devices, and
                                 other medical supplies—that can be used to respond to a broad range
                                 of public health emergencies. The contents of the stockpile may be
                                 deployed to jurisdictions—states, localities, territories—and tribal
                                 governments during actual or potential emergencies when their
                                 supplies are depleted or when the necessary medical
                                 countermeasures are not commercially available. During the COVID-
                                 19 pandemic, jurisdictions and Tribes requested and received a
                                 variety of medicines, medical supplies, and personal protective
                                 equipment.
                            •    Development and distribution of COVID-19 vaccines. COVID-19
                                 vaccine implementation—that is, prioritizing, allocating, distributing,
                                 and administering vaccine doses—has also been a key component in
                                 mitigating the disease’s effect on the public’s health, societal
                                 functioning, and the economy. Federal efforts to support vaccine



                            Page 4                                                    GAO-25-107588 COVID-19 2025 Update
                           development, manufacturing, and distribution to states and other
                           jurisdictions were led by a partnership between HHS and the
                           Department of Defense. The federal government began distributing
                           COVID-19 vaccine doses on December 12, 2020, and 2 days later,
                           the first dose of vaccine was administered.


Response to Economic   COVID-19 relief funding provided relief and assistance to a wide range of
Impacts                entities, including individuals and families, state and local governments,
                       businesses, and health care providers. The examples presented below
                       illustrate some of the COVID-19 relief programs implemented to address
                       a range of COVID-19-related issues.

                       •   Temporary Unemployment Insurance (UI) Programs. Overseen by
                           the Department of Labor (DOL) and administered by the states, the UI
                           program is a federal-state partnership that provides temporary
                           financial assistance to eligible workers who become unemployed
                           through no fault of their own. During the pandemic, the CARES Act
                           created three federally funded temporary programs that expanded
                           benefit eligibility, enhanced benefits, and extended benefit duration for
                           eligible unemployed individuals. In addition, the Consolidated
                           Appropriations Act, 2021 created a fourth federally funded temporary
                           program which was extended by the American Rescue Plan Act of
                           2021.
                       •   Coronavirus State and Local Fiscal Recovery Fund. Administered
                           by Treasury, these funds provided payments to tribal governments,
                           states, the District of Columbia, U.S. territories, and localities to
                           mitigate the fiscal effects stemming from the COVID-19 pandemic,
                           among other things.
                       •   Coronavirus Food Assistance Program. Administered by the U.S.
                           Department of Agriculture, the Coronavirus Food Assistance Program
                           provided financial assistance to farmers and ranchers that gave them
                           the ability to offset sale losses and increased marketing costs
                           associated with the pandemic.
                       •   COVID-19 Economic Injury Disaster Loan (COVID-19 EIDL)
                           Program. Managed by the Small Business Administration (SBA), this
                           program provided low-interest loans and grants to help small
                           businesses and non-profit organizations meet obligations or pay
                           ordinary and necessary operating expenses.
                       •   Paycheck Protection Program (PPP). Administered by SBA through
                           a network of participating lenders, this program provided small
                           businesses with potentially forgivable loans to support payroll costs,


                       Page 5                                       GAO-25-107588 COVID-19 2025 Update
                            including employee benefits, over certain periods of time. A portion of
                            the funds could also be used for other purposes, such as to pay
                            interest on business mortgages, rent, and utilities.
                        •   Provider Relief Fund. Administered by the Health Resources and
                            Services Administration (HRSA), an agency within HHS, this fund was
                            created to ensure access to essential health care services during the
                            pandemic by compensating providers for lower revenues from
                            postponed nonessential care and increased expenses for pandemic
                            supplies.



Updates to Key
Indicators Examining
Public Health and
Economic Effects of
the COVID-19
Pandemic and
Information on Relief
Funding, Spending,
and Fraud Cases

Public Health           While the effects of the COVID-19 pandemic on public health have been
                        profound, key indicators showed overall improvements in recent years.
                        Since June 2020, our comprehensive reports have tracked data related to
                        the public health impacts of the COVID-19 pandemic. The following
                        provides updates to key indicators and identifies trends in public health
                        impacts over time.




                        Page 6                                      GAO-25-107588 COVID-19 2025 Update
Mortality                                                          The weekly number of COVID-19-associated deaths fluctuated over the
                                                                   course of the pandemic but has decreased overall in recent years (see
Mortality                                                          fig. 2). The highest weekly numbers of COVID-19-associated deaths
COVID-19-associated deaths are those with                          occurred during January 2021 (with about 26,000 deaths per week), and
COVID-19 listed as an underlying (i.e.,                            other peaks occurred during January 2022 and April 2020, according to
primary) or contributing cause of death using
the International Classification of Diseases,
                                                                   data from CDC’s National Center for Health Statistics. Since mid-2022,
Tenth Revision (code U07.1).                                       there have been fewer weekly COVID-19-associated deaths. CDC data
Mortality is a commonly used indicator to                          showed that provisional weekly COVID-19-associated deaths had also
measure the progression and severity of a
public health event.
                                                                   declined in more recent months, from about 1,000 deaths in January
Source: Centers for Disease Control and Prevention’s               2025 to about 450 deaths in March 2025.7
National Center for Health Statistics and National Institutes of
Health. I GAO-25-107588




Figure 2: Weekly Number of U.S. COVID-19-Associated Deaths, March 2020 Through March 2025




                                                                   Note: COVID-19-associated deaths are those with COVID-19 listed as an underlying (i.e., primary) or
                                                                   contributing cause of death using the International Classification of Diseases, Tenth Revision (code
                                                                   U07.1). Data are from CDC WONDER as of May 5, 2025. Death counts in January and February
                                                                   2020 were suppressed due to small numbers. Data for 2020–2023 are final. Data for 2024–2025 are
                                                                   provisional and subject to change.




                                                                   7Data for 2025 are provisional and subject to change.




                                                                   Page 7                                                    GAO-25-107588 COVID-19 2025 Update
Annual rates of COVID-19-associated deaths were lower after the first 2
years of the pandemic (see fig. 3).8 The rate of COVID-19-associated
deaths was about 93.2 deaths per 100,000 in 2020, the first year of the
pandemic, and rose to 115.6 in 2021 before falling to 58.7 in 2022 and
18.3 in 2023. In 2024, the provisional rate of COVID-19-associated
deaths was about 11.4 deaths per 100,000 people. COVID-19 was the
third leading cause of death in 2020 and 2021, fourth in 2022, 10th in
2023, and 15th in 2024.9

Figure 3: Annual Rate of U.S. COVID-19-Associated Deaths, 2020 Through 2024




Note: COVID-19-associated deaths are those with COVID-19 listed as an underlying (i.e., primary) or
contributing cause of death using the International Classification of Diseases, Tenth Revision (code
U07.1). The rates were age-adjusted to facilitate comparisons between years. Data are from CDC
WONDER as of May 5, 2025. Data for 2020–2023 are final. Data for 2024 are provisional and subject
to change.




8The rates were age-adjusted to facilitate comparisons between years.

9Data for 2024 are provisional and subject to change.




Page 8                                                    GAO-25-107588 COVID-19 2025 Update
Hospitalization                                  Similar to COVID-19-associated deaths, the U.S. has experienced peaks
                                                 and lulls in the level of COVID-19 hospitalizations (see fig. 4). The weekly
                                                 rate of COVID-19 hospitalizations peaked during January 2022 at about
 COVID-19 Hospitalizations
 During the pandemic, the Centers for Disease
                                                 35.6 hospitalizations per 100,000 people. As of the end of March 2025,
 Control and Prevention collected and reported   the weekly rate of hospitalizations was about 1.8 hospitalizations per
 data on hospitalizations due to COVID-19.       100,000.10
 Rate of hospitalizations is one way to gauge
 the severity of a disease outbreak and can
 also indicate the burden placed on the health
 care system.
 Source: GAO. I GAO-25-107588




Figure 4: Weekly Rate of COVID-19 Hospitalizations, March 2020 Through March 2025




                                                 Note: Data are from CDC’s COVID-19 Hospitalization Surveillance Network as of May 5, 2025.
                                                 According to CDC documentation, these data for March 2020 through March 2025 are past the 2-
                                                 week provisional period.




                                                 10According to CDC documentation, these data for March 2020 through March 2025 are
                                                 past the 2-week provisional period.




                                                 Page 9                                                  GAO-25-107588 COVID-19 2025 Update
Long COVID   One public health impact of COVID-19 is long COVID, otherwise known
             as post-COVID conditions, which refers to signs, symptoms, and
             conditions that continue or develop after an initial COVID-19 infection,
             according to CDC (see fig. 5).

             Figure 5: Examples of Signs, Symptoms, and Conditions Associated with Long
             COVID




             According to estimates from the Census Bureau’s Household Pulse
             Survey, conducted August 20 through September 16, 2024, about 18
             percent of adults in the U.S. aged 18 and older had ever experienced
             long COVID, and about 5 percent were currently experiencing it at the
             time of the survey.11 These percentages varied by demographic and other
             characteristics. For example, survey estimates indicated that the
             percentage of adult females who ever experienced long COVID was




             11An estimated 17.9 percent (95 percent confidence interval: 17.3 – 18.6) had ever
             experienced long COVID, and 5.3 percent (95 percent confidence interval: 4.9 - 5.7) were
             currently experiencing long COVID at the time of the survey. Questions to assess the
             prevalence of long COVID—meaning that there was a presence of symptoms that lasted 3
             months or longer—on the Household Pulse Survey were developed through an ongoing
             partnership between the Census Bureau and the National Center for Health Statistics. The
             data are released as part of the Census Bureau’s Experimental Statistical Products
             Series. For more information, including limitations, see National Center for Health
             Statistics, U.S. Census Bureau, Household Pulse Survey, 2022–2024: Long COVID.




             Page 10                                             GAO-25-107588 COVID-19 2025 Update
                                                       about 1.6 times higher than that of males.12 CDC and other researchers
                                                       have used multiple approaches to estimate how many people experience
                                                       long COVID. According to CDC, estimates from these different
                                                       approaches can vary widely depending on factors such as who was
                                                       included in the study, as well as how and when the study collected
                                                       information.

Economic Conditions                                    Generally, the economy has improved from the worst of COVID-19
                                                       impacts, but some areas of the economy had not returned to pre-
                                                       pandemic levels as of March 2025. In our comprehensive reports, we
                                                       tracked data related to the economic conditions following the COVID-19
                                                       pandemic. The following updates describe selected trends in economic
                                                       impacts over time.

Gross Domestic Product
                                                       The national economy, measured by real gross domestic product (GDP),
Gross domestic product (GDP) is the value of           has returned to its pre-COVID-19 pandemic trend. After a 2.2 percent
all goods and services produced within the             drop in 2020, real GDP grew by 6.1 percent in 2021. While economic
borders of a country in a given period. The
percentage that GDP grew (or shrank) from
                                                       growth has slowed from its 2021 rate, real GDP rates in 2023 and 2024—
one period to another is one way to gauge              2.9 percent and 2.8 percent, respectively—were in line with pre-pandemic
how well (or poorly) the economy is                    growth rates, according to the Bureau of Economic Analysis. However,
performing. The real GDP is an adjusted
version of the GDP that removes the effects of         the economy weakened in the first quarter of 2025, with real GDP
inflation over time so that different periods can      decreasing by an annual rate of 0.2 percent. This indicates a fall in output
be compared.
                                                       produced domestically. The economic outlook will continue to depend on
Source: Bureau of Economic Analysis. I GAO-25-107588
                                                       factors such as evolving tariff, fiscal, and monetary policy actions.

                                                       Based on data covering price trends through March 2025, inflation had
Inflation                                              continued to decline compared to a year ago but remained elevated
Inflation is the increase in the prices of goods
and services over time and is typically
measured as the percentage change in those
prices over a set period, often 1 year or 1
month. For example, an annual inflation rate
of 2 percent means that the prices of goods
and services, on average, increased 2 percent
over the past year.
Annual inflation provides a longer and
potentially less volatile perspective on
inflation, while monthly inflation is more useful
for assessing whether recent price pressures
are waning or intensifying.
Source: GAO. I GAO-25-107588




                                                       12An estimated 21.8 percent (95 percent confidence interval: 20.9 – 22.8) of adult females
                                                       and 13.9 percent (95 percent confidence interval: 13.0 – 14.7) of adult males had ever
                                                       experienced long COVID. U.S. Census Bureau, Household Pulse Survey 2022-2024:
                                                       Long COVID.




                                                       Page 11                                             GAO-25-107588 COVID-19 2025 Update
compared to pre-pandemic levels.13 Annual inflation indicators were 2.3
percent or higher in March 2025, which was slightly lower than the 2.7
percent or higher in March 2024.14 Yet, inflation is still higher than
averages of about 2 percent in recent decades.15

Indicators of more recent price pressures (measured relative to the
previous month) showed some signs of softening in March 2025, but
underlying inflation trends—trends that omit outliers—continued to
increase moderately.16 The Consumer Price Index saw its first decline in
March 2025 after 8 consecutive months of increases. Meanwhile,
underlying inflation trends ranged from 0.2 to 0.4 percent in January,
February, and March 2025, which had indicated a lack of further progress
toward the easing of inflation until March 2025, when they declined.
Figure 6 shows month-over-month changes in inflation indicators from
March 2019 through March 2025.




13In previous work, we identified a number of indicators of current and expected future
inflation to help us monitor households’ experiences with rising prices and assess the
extent to which prices are likely to continue to rise over time. See GAO, COVID-19:
Additional Actions Needed to Improve Accountability and Program Effectiveness of
Federal Response, GAO-22-105051 (Washington, D.C.: Oct. 27, 2021).
14Annual inflation indicators include the year-over-year changes in the Personal
Consumption Expenditures price index, the Consumer Price Index (CPI), the median CPI,
and the 16 percent trimmed mean CPI. The median CPI and 16 percent trimmed mean
CPI indicators focus on underlying inflation trends by omitting outliers.
15The Federal Reserve System’s Federal Open Market Committee determines the
direction of monetary policy by directing open market operations. Federal Reserve
System’s Federal Open Market Committee aims for annual inflation of 2 percent on
average over time and aims to achieve rates of inflation that are above 2 percent for some
time after periods during which inflation has been persistently below 2 percent. See
Federal Reserve System, Federal Open Market Committee, Statement on Longer-Run
Goals and Monetary Policy Strategy (Washington, D.C.: Jan. 30, 2024).
16Monthly inflation indicators include the month-over-month changes in the Personal
Consumption Expenditures price index, the CPI, the median CPI, and the 16 percent
trimmed mean CPI.




Page 12                                              GAO-25-107588 COVID-19 2025 Update
Figure 6: Percentage Change in Inflation Indicators from the Previous Month, March 2019 Through March 2025




                                        Note: CPI is a measure of the average change over time in the prices paid by urban consumers for a
                                        market basket of consumer goods and services. The median and trimmed mean CPIs omit outliers
                                        and focus on underlying inflation trends.




                                        Page 13                                                  GAO-25-107588 COVID-19 2025 Update
Labor Market Indicators
                                                      DOL data through March 2025 showed that labor market conditions had
The employment-to-population ratio measures           improved since the start of the pandemic, but job growth showed signs of
the share of the civilian labor force currently       cooling, and some labor market indicators were still trending below their
employed relative to the civilian
noninstitutional population over 16 years old.
                                                      pre-pandemic levels. The unemployment rate remained relatively low at
In other words, it is the percentage of the           4.2 percent in March 2025, showing little had changed since a year ago.
population that is currently working. This ratio      This is down considerably from a record high unemployment rate of 14.7
provides information on the ability of the
economy to provide employment, making it a            percent in April 2020 and slightly higher than the 54-year record low of
particularly useful indicator of labor market         3.4 percent in January 2023. Real average hourly earnings for all
stress.
                                                      employees, seasonally adjusted, were 1.4 percent higher in March 2025
The labor force participation rate represents
the number of people in the labor force as a          compared to a year ago, indicating that average wage growth more than
percentage of the civilian noninstitutional           kept up with inflation over this time period. Meanwhile, both the
population. In other words, the participation
rate is the percentage of the population that is
                                                      employment-to-population ratio and labor force participation rate had
either working or actively looking for work.          changed little over the past year and remained lower than in the pre-
The labor force participation rate is an              pandemic period (see fig. 7).17 This difference likely reflects a combination
important labor market measure because it
represents the relative amount of labor               of population aging and other pre-pandemic trends, as well as a lasting
resources available for the production of             negative effect of the pandemic. Additionally, hiring and job opening rates
goods and services.
Source: Bureau of Labor Statistics. I GAO-25-107588
                                                      continued to fall over the past year, suggesting the labor market has
                                                      gradually cooled.




                                                      17The employment-to-population ratio was 59.9 percent in March 2025, the same as
                                                      February 2025, and 1.2 percentage points lower than in February 2020. The labor force
                                                      participation rate was 62.5 percent in March 2025, 0.1 percentage points higher than in
                                                      February 2025 and 0.8 percentage points lower than in February 2020.




                                                      Page 14                                             GAO-25-107588 COVID-19 2025 Update
Figure 7: Labor Market Trends, March 2019 Through March 2025




COVID-19 Relief Funding,
Spending, and Fraud
Cases
Funding and Spending                                  In our comprehensive reports, we presented data tracking how agencies
                                                      were obligating and expending COVID-19 relief funding. The following are
 Key Budget Terms                                     updates to these data as of March 31, 2025.
 An obligation is a definite commitment that
 creates a legal liability of the U.S. government     The federal government had obligated a total of about $4.59 trillion of the
 for the payment of goods and services
 ordered or received, or a legal duty on the          approximate $4.65 trillion in COVID-19 relief funding, as reported by
 part of the U.S. government that could mature        federal agencies to Treasury, in accordance with Office of Management
 into a legal liability by virtue of actions on the
 part of another party that are beyond the
 control of the U.S. government.
 An expenditure is the actual spending of
 money, or an outlay. Expenditures include
 some estimates, such as estimated subsidy
 costs for direct loans and loan guarantees.
 Source: GAO. I GAO-25-107588




                                                      Page 15                                     GAO-25-107588 COVID-19 2025 Update
                                            and Budget (OMB) guidance.18 Further, the federal government had
                                            expended about $4.51 trillion of this COVID-19 relief funding. For the top
                                            nine spending areas, agencies reported that COVID-19 relief funding
                                            obligations totaled about $3.69 trillion (80 percent of total obligations),
                                            and expenditures totaled about $3.65 trillion.19 Table 1 provides additional
                                            details on government-wide COVID-19 relief funding, obligations, and
                                            expenditures by major spending areas as of March 31, 2025.

Table 1. Major Spending Areas Under COVID-19 Relief Funding as of March 31, 2025

                                                                          COVID-19 relief                   Total               Total
Major spending area (dollars in billions)                                       funding               obligations        expenditures
Economic Impact Payments                                                             862.0                  860.5                860.5
(Department of the Treasury)
Business Loan Programs                                                               830.0                  828.1               828.0a
(Small Business Administration)
Unemployment Insurance                                                               694.0                  693.6                687.3
(Department of Labor)b
Coronavirus State and Local Fiscal Recovery Funds                                    349.8                  349.8                349.8
(Department of the Treasury)
Public Health and Social Services Emergency Fund                                     333.7                  332.9                305.9
(Department of Health and Human Services)
Education Stabilization Fund                                                         277.3                  277.2                272.1
(Department of Education)
Coronavirus Relief Fund                                                              150.0                  149.8                149.8
(Department of the Treasury)
Supplemental Nutrition Assistance Programs                                           121.0                    98.3               102.7
(Department of Agriculture)c
U.S. Coronavirus Refundable Credits                                                  101.5                    98.4                   98.4
(Department of the Treasury)


                                            18Treasury records and tracks COVID-19 relief spending, in accordance with OMB
                                            guidance. Amounts presented are from Treasury’s Governmentwide Treasury Account
                                            Symbol Adjusted Trial Balance System. Federal agencies use this system to provide
                                            proprietary financial reporting and budgetary execution information to Treasury. These
                                            amounts can fluctuate from month to month, and they reflect appropriations, as well as
                                            transfers, adjustments, recoveries, rescissions, and returns of unused indefinite
                                            appropriations. OMB’s guidance for recording and tracking COVID-19 relief spending does
                                            not include increases in Medicaid and Medicare spending; otherwise, the cumulative
                                            amount of funding as of March 31, 2025, would be greater than about $4.65 trillion.
                                            Further, the approximate $4.65 trillion accounts for (i.e., subtracts out) the permanent
                                            rescissions enacted in the Fiscal Responsibility Act of 2023, Pub. L. No. 118-5, 137 Stat.
                                            10, 23-30, div. B, tit. I, and other laws.
                                            19The remaining $928.4 billion in COVID-19 relief funding was used for other spending
                                            areas. Agencies reported obligations totaling $899.6 billion and expenditures totaling
                                            $850.9 billion in these other areas.




                                            Page 16                                              GAO-25-107588 COVID-19 2025 Update
                                                                                                            COVID-19 relief              Total                  Total
 Major spending area (dollars in billions)                                                                        funding          obligations           expenditures
 Other areas (includes over 300 accounts)d                                                                           928.4                 899.6                   850.9
 Totale                                                                                                             4,647.7             4,588.1                  4,505.4
Source: GAO analysis of data from the Department of the Treasury and applicable agencies. | GAO-25-107588

                                                               Note: COVID-19 relief funding, obligations, and expenditure data shown for the major spending areas
                                                               are based on data reported by applicable agencies to Treasury’s Governmentwide Treasury Account
                                                               Symbol Adjusted Trial Balance System. Federal agencies use this system to provide proprietary
                                                               financial reporting and budgetary execution information to Treasury. These amounts can fluctuate
                                                               from month to month. COVID-19 relief funding is the cumulative amount of funding provided in the six
                                                               COVID-19 relief laws that Treasury uses to record and track COVID-19 relief spending, in accordance
                                                               with Office of Management and Budget guidance. These amounts do not include certain tax
                                                               expenditures from federal tax relief programs, such as the employee retention credit, paid sick and
                                                               family leave credits, and payroll tax deferrals. Further, the approximate $4.65 trillion accounts for (i.e.,
                                                               subtracts out) the permanent rescissions enacted in the Fiscal Responsibility Act of 2023, Pub. L. No.
                                                               118-5, 137 Stat. 10, 23-30, div. B, tit. I, and other laws.
                                                               a
                                                                The Small Business Administration’s Business Loan Program account includes activity for Paycheck
                                                               Protection Program loan guarantees and certain other loan subsidies. These expenditures relate
                                                               mostly to the loan subsidy costs (i.e., the loan’s estimated long-term costs to the U.S. government).
                                                               b
                                                                The Department of Labor reported that in fiscal year 2023 and fiscal year 2024 the agency
                                                               deobligated funds for various COVID-19 programs in the amount of $1.8 billion and $2.6 billion,
                                                               respectively, as a result of changes in the estimates of future benefits related to these programs.
                                                               c
                                                                 Department of Agriculture officials told GAO that certain Supplemental Nutrition Assistance Program
                                                               funding and spending amounts were not reported to Treasury’s Governmentwide Treasury Account
                                                               Symbol Adjusted Trial Balance System correctly for March 2025. As of May 22, 2025, the total
                                                               COVID-19 relief funding for the program was $155.5 billion, with obligations of $126.2 billion and
                                                               expenditures of $119.2 billion.
                                                               d
                                                                Several provisions in the Families First Coronavirus Response Act and the American Rescue Plan
                                                               Act of 2021 authorized increases in Medicaid payments to states and U.S. territories. At the time of
                                                               enactment, the Congressional Budget Office estimated that federal expenditures from these
                                                               provisions would total approximately $76.9 billion through fiscal year 2030. The largest increase to
                                                               federal Medicaid spending is based on a temporary formula change rather than a specific
                                                               appropriated amount. Some of the estimated costs in this total are for the Children’s Health Insurance
                                                               Program, permanent changes to Medicaid, and changes not specifically related to COVID-19. This
                                                               increased spending is not accounted for in the funding provided by the COVID-19 relief laws and is
                                                               therefore not included in this table.
                                                               e
                                                                Amounts shown in columns may not sum to the totals because of rounding.


                                                               As of March 31, 2025, about $23.6 billion, or less than 1 percent, of the
                                                               total amount of funding provided for COVID-19 relief remained available
                                                               for obligation (unexpired unobligated balance). Additionally, about $41.9
                                                               billion was expired (expired unobligated balance), meaning that this
                                                               amount was not available for incurring new obligations but was available
                                                               for recording eligible obligation adjustments. Table 2 provides additional
                                                               details on funding, obligations, unobligated balances, and expenditures of
                                                               government-wide COVID-19 relief funding with the largest unexpired
                                                               unobligated balances.




                                                               Page 17                                                        GAO-25-107588 COVID-19 2025 Update
Table 2: Largest Unexpired Unobligated Balances Under COVID-19 Relief Funding as of March 31, 2025

                                                                                                                                   Expired              Unexpired
                                                                    COVID-19                     Total               Total      unobligated            unobligated
 Spending areas (dollars in billions)                           relief funding             obligations        expenditures         balance                balance
 Pension Benefit Guaranty Corporation                                         78.4                    71.4            71.0                 0.0                    7.0
 Funda
 (Pension Benefit Guaranty Corporation)
 Disaster Relief Fundb                                                        94.3                    91.1            85.9                 0.0                    3.2
 (Federal Emergency Management
 Agency)
 Secure and Trusted Communications                                             5.0                      1.9            1.1                 0.0                    3.1
 Networks Reimbursement Program
 (Federal Communications Commission)
 U.S. Coronavirus Refundable Credits                                        101.5                     98.4            98.4                 0.0                    3.1
 (Department of the Treasury)
 Economic Impact Payments                                                   862.0                   860.5            860.5                 0.0                    1.5
 (Department of the Treasury)
 Tenant-Based Rental Assistance                                                6.2                      4.9            4.3                 0.0                    1.3
 (Department of Housing and Urban
 Development)
 Other areas (includes over 250 accounts)                                3,500.4                 3,460.0           3,384.2               41.9c                    4.4
 Totald                                                                  4,647.7                 4,588.1           4,505.4                41.9                   23.6
Source: GAO analysis of data from the Department of the Treasury and applicable agencies. | GAO-25-107588

                                                               Note: COVID-19 relief funding, obligations, and expenditure data shown for the major spending areas
                                                               are based on data reported by applicable agencies to Treasury’s Governmentwide Treasury Account
                                                               Symbol Adjusted Trial Balance System. Federal agencies use this system to provide proprietary
                                                               financial reporting and budgetary execution information to Treasury. These amounts can fluctuate
                                                               from month to month. COVID-19 relief funding is the cumulative amount of funding provided in the six
                                                               COVID-19 relief laws that Treasury uses to record and track COVID-19 relief spending, in accordance
                                                               with Office of Management and Budget guidance. Further, the approximate $4.65 trillion accounts for
                                                               (i.e., subtracts out) the permanent rescissions enacted in the Fiscal Responsibility Act of 2023, Pub.
                                                               L. No. 118-5, 137 Stat. 10, 23-30, div. B, tit. I, and other laws.
                                                               a
                                                                Under section 9704 of the American Rescue Plan Act of 2021 (classified at 29 U.S.C. §§ 1305(i),
                                                               1432), the Pension Benefit Guaranty Corporation will receive the necessary funding from the General
                                                               Fund of the U.S. Treasury through fiscal year 2030 to provide payments to qualifying multiemployer
                                                               plans, as defined in this law, so that the plans can pay benefits at plan levels through the end of plan
                                                               year 2051. The requested amount will fund the Special Financial Assistance payments to qualifying
                                                               plans and the Pension Benefit Guaranty Corporation’s related administrative and operating expenses.
                                                               Neither the plans nor the Pension Benefit Guaranty Corporation are required to repay amounts
                                                               received from this American Rescue Plan Act of 2021-established program, which is funded by
                                                               appropriations from the General Fund of the U.S. Treasury.
                                                               b
                                                                Funding provided to the Disaster Relief Fund is generally not specific to individual disasters.
                                                               Therefore, Treasury’s methodology for determining COVID-19-related obligations and expenditures
                                                               does not capture obligations and expenditures for the COVID-19 response based on funding other
                                                               than what was provided in the COVID-19 relief laws. Further, Treasury’s methodology includes all
                                                               obligations and expenditures based on funding in the COVID-19 relief laws, including those for other
                                                               disasters. In its Disaster Relief Fund Monthly Report dated April 17, 2025, the Department of
                                                               Homeland Security reported COVID-19-related obligations totaling $140.6 billion and expenditures
                                                               totaling $120.5 billion as of March 31, 2025.




                                                               Page 18                                                       GAO-25-107588 COVID-19 2025 Update
                                                   c
                                                    The Department of Agriculture’s Supplemental Nutrition Assistance Program comprised about $34.1
                                                   billion, or 82 percent, of the total expired unobligated balance as of March 31, 2025.
                                                   d
                                                       Amounts shown in columns may not sum to the totals because of rounding.


Fraud Cases                                        Although COVID-19 relief programs were critical for assuring public
                                                   health and economic stability, they also created unprecedented
Fraud Estimates                                    opportunities for fraud due to the dollars involved, among other risk
Fraud involves obtaining something of value        factors. The full extent of fraud within the COVID-19 relief programs will
through willful misrepresentation. Whether an      never be known with certainty. The scope of the COVID-19 relief
act is fraudulent is determined through the
judicial or other adjudicative system.             response; the inherently deceptive nature of fraudulent activities; and the
Estimates of fraud exist for three of the more     resources needed for detection, investigation, and prosecution of fraud
commonly defrauded programs during the             make it difficult to measure. However, estimates indicate hundreds of
COVID-19 pandemic.
                                                   billions of dollars in fraudulent payments were disbursed.
•    We previously estimated that the fraud in
     Unemployment Insurance (UI) programs
     during the pandemic—from April 2020           While the disbursement of COVID-19 relief funds is largely over, the work
     through May 2023—was likely between
     $100 billion and $135 billion. This           of investigating, prosecuting, and recovering fraudulently disbursed funds
     estimate covers the period from April         is ongoing. DOJ and its law enforcement partners continue to prioritize
     2020 (first full month of payments from all   the investigation and prosecution of defendants that committed these
     UI programs) to May 2023 (end of the
     public health emergency) and all 53           offenses. Once potential fraud is detected and investigated, DOJ may
     states and territories that participated in   bring charges of fraud against the alleged fraudster.
     the regular UI and pandemic UI programs.
•    The Small Business Administration’s
     Office of Inspector General estimated         As of March 31, 2025, DOJ had publicly announced criminal fraud-related
     that, as of June 2023, the agency had         charges against at least 3,205 defendants involving 20 federal COVID-19
     disbursed $200 billion in potentially
     fraudulent funds through its Paycheck
                                                   relief programs.20 Of those, 2,708 defendants (nearly 85 percent) had
     Protection Program and the COVID-19           been found guilty, and 2,331 of these defendants have been convicted as
     Economic Injury Disaster Loan program.
Source: GAO and Small Business Administration. I
GAO-25-107588




                                                   20We analyzed criminal cases identified from DOJ’s public statements and court
                                                   documentation from March 2020 through March 2025. Defendants can be individuals or
                                                   entities.




                                                   Page 19                                                    GAO-25-107588 COVID-19 2025 Update
of March 2025.21 Defendants found guilty of these charges have been
typically sentenced to prison time and ordered to pay restitution.22

Prison sentences. Of the 2,331 defendants convicted of fraud-related
charges involving COVID-19 relief programs as of March 2025, 1,896 (81
percent) received prison time. Prison sentences ranged from 1 day to 30
years, with the majority of sentences between 1 and 5 years. Figure 8
presents the different lengths of prison sentences among the defendants.




21In United States practice, conviction means a finding of guilt (i.e., a jury verdict or finding
of fact by the judge) and imposition of sentence. U.S. DOJ Criminal Resource Manual,
sec. 609 Evidence of Conviction.
22Their sentencing varied based on the circumstances of the offense, as well as other
factors, such as prior convictions and the presence of additional charges beyond fraud.
Sentences ranged from probation to varying prison terms, followed by supervised release,
with more than 81 percent of defendants sentenced to serve time in prison. In addition to
prison time and probation, sentences included community service, fines, and, in a vast
majority of cases, restitution. Courts refer to the United States Sentencing Commission
Guidelines to determine the particular sentence in each individual case. Under 28 U.S.C.
§ 994, the Guidelines should reflect a variety of factors and considerations to determine
an appropriate sentence. The Guidelines set a base offense level and then add or subtract
levels due to aggravating or mitigating circumstances, such as the dollar amount of the
loss caused by offense and the defendant’s criminal history, ultimately arriving at a
suggested sentencing range. Additionally, many of the defendants we reviewed were
convicted on additional charges beyond fraud against COVID-19 relief programs, which
would impact the length of their sentences.




Page 20                                                 GAO-25-107588 COVID-19 2025 Update
Figure 8: Prison Sentences for Defendants Convicted of Fraud-Related Charges
Involving COVID-19 Relief Programs, as of March 31, 2025




Note: Our analysis is limited to cases identified from the Department of Justice’s (DOJ) public
statements and court documentation from March 2020 through March 31, 2025, and may not include
all criminal fraud-related charges involving COVID-19 relief programs initiated by DOJ.


Restitution. Of the 2,331 defendants who had been convicted, 2,196 (94
percent) were ordered to pay restitution. Restitution amounts for those
2,196 defendants varied, with the highest amount being over $71 million.
Four hundred and seventy-nine defendants were ordered to pay $1
million or more in restitution each. See figure 9 for more information on
the amount of restitution defendants have been ordered to repay.




Page 21                                                 GAO-25-107588 COVID-19 2025 Update
Figure 9: Court-Ordered Restitution for Defendants Convicted of Fraud-Related
Charges Involving COVID-19 Relief Programs, as of March 31, 2025




Note: Our analysis is limited to cases identified from the Department of Justice’s (DOJ) public
statements and court documentation from March 2020 through March 31, 2025, and may not include
all criminal fraud-related charges involving COVID-19 relief programs initiated by DOJ. In addition to
the numbers above, ordered restitution amounts for 13 defendants were either unknown or yet to be
determined.


There were also at least 383 defendants with pending COVID-19 relief
program-related fraud charges. This number continues to grow as new
cases are identified and developed. Additionally, extensions to statutes of
limitations may contribute to an increase in cases. For example, in August
2022, the statute of limitations to prosecute individuals who committed
PPP and COVID-19 EIDL-related fraud was extended to 10 years.23 In
January 2025, Congress introduced legislation that would extend the
statute of limitations for violations relating to pandemic UI programs and




23The statute of limitations for mail fraud and wire fraud prosecutions is 5 years, 18 U.S.C.
§ 3282, except for mail and wire fraud schemes that affect a financial institution, in which
case the statute is 10 years, 18 U.S.C. § 3293. The statute of limitations for fraud related
to PPP loans, 15 U.S.C. § 636(a)(36)(W); PPP second draw loans, 15 U.S.C. §
637(a)(37)(P); certain COVID-19 EIDL loans, 15 U.S.C. § 636(b)(16); COVID-19 EIDL
advances, 15 U.S.C. § 9009b(i); and targeted COVID-19 EIDL advances, 15 U.S.C. §
9009b(i), has been extended to 10 years.




Page 22                                                     GAO-25-107588 COVID-19 2025 Update
                        other COVID-19 relief programs to 10 years.24 We support such
                        extensions, which would give our oversight partners and federal law
                        enforcement additional time to investigate and pursue fraudulently
                        obtained payments in these programs.25

                        Although federal agencies and Congress have made progress addressing
Progress Made           recommendations from our COVID-19 oversight work, those that remain
Addressing GAO          open underscore opportunities for further improvements. Our work
                        examining the federal pandemic response has resulted in 484
Recommendations         recommendations to federal agencies and matters for congressional
from the COVID-19       consideration. As of March 31, 2025, 284 (59 percent) of our
                        recommendations and matters had been closed.26 Actions by agencies
Pandemic Response,      and Congress resulting from our work and related recommendations have
but Opportunities for   yielded at least $43.9 billion in financial benefits and demonstrated other
                        improvements in the COVID-19 response. This included $16.8 billion
Improvement Remain      resulting from agency actions and $27.1 billion resulting from
                        congressional actions. The 200 recommendations and matters that
                        remained open as of March 2025 identify further opportunities to address
                        concerns that we have raised related to the pandemic response. These




                        24In January 2025, the Recover Fraudulent COVID Funds Act was introduced, which
                        would extend the statute of limitations for violations relating to all pandemic-relief
                        programs to 10 years. S. 121, 119th Cong. In February 2025, the Pandemic
                        Unemployment Fraud Enforcement Act was introduced, which would extend the statute of
                        limitations for violations related to pandemic UI programs to 10 years. H.R. 1156, 119th
                        Cong. In March 2025, the SBA Fraud Enforcement Extension Act was introduced, which
                        would extend the statute of limitations for fraud under certain pandemic programs—grants
                        for shuttered venue operators and restaurant revitalization—to 10 years. S. 1199, 119th
                        Cong. As of July 17, 2025, Congress had not yet passed bills including these provisions.
                        25GAO, COVID-19 Relief: Consequences of Fraud and Lessons for Prevention,
                        GAO-25-107746 (Washington, D.C.: Apr. 9, 2025).
                        26Of the 284 recommendations we closed, 256 had been implemented. Additionally, we
                        closed 28 recommendations as not implemented or as no longer valid. Reasons for
                        closing recommendations as no longer valid include when a law has been amended or
                        repealed; when a program has been terminated, replaced, or changed; when an office is
                        terminated; or when the opportunity for implementation has passed, such as with a pilot
                        project.




                        Page 23                                             GAO-25-107588 COVID-19 2025 Update
Recommendations in High Risk Areas
                                               also identify opportunities for the government to enhance its
At the beginning of each new Congress, GAO
                                               preparedness for responding to future public health emergencies.
compiles and updates a list of programs and
operations with serious vulnerabilities to
waste, fraud, abuse, or mismanagement, or in
need of transformation—GAO’s High Risk
List.
Recommendations we made in our COVID-19
oversight work include those related to the
three areas GAO added to its High Risk List
during the pandemic:
1. Department of Health and Human Services’
leadership and coordination of public health
emergencies,
2. Department of Labor’s Unemployment
Insurance system, and
3. Small Business Administration’s emergency
loans to small businesses
Source: GAO. I GAO-25-107588




Actions to Address GAO                         Federal agencies and Congress took various actions in response to
Recommendations                                recommendations we made to improve the COVID-19 pandemic
                                               response. Actions to address some of our recommendations have yielded
Demonstrated
                                               billions of dollars in federal savings. Other actions resulted in benefits that
Improvements in the                            cannot be measured in dollars but led to improvements in the
COVID-19 Response                              government’s activities to respond to the public health and economic
                                               impacts of the pandemic.

Improving the Public Health                    Examples of actions that federal agencies have taken to implement
Response                                       recommendations we made to improve the government’s response to
                                               public health emergencies include:

                                               •   Veterans’ health care. The Department of Veterans Affairs (VA)
                                                   implemented two of our March 2021 recommendations to collect the
                                                   data needed to monitor and improve its vaccination efforts.27 We
                                                   reported that VA had a phased approach to administer COVID-19
                                                   vaccines but had not developed metrics to track vaccination efforts by
                                                   phase. We recommended that the agency take action to address this
                                                   data gap. In June 2021, VA officials provided information
                                                   demonstrating that it had systems in place to obtain the data needed
                                                   to assess vaccination progress by vaccine rollout phase and to make
                                                   any necessary adjustments. We also recommended in March 2021
                                                   that VA collect data on the number of staff and veterans who do not

                                               27GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its Second
                                               Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021).




                                               Page 24                                          GAO-25-107588 COVID-19 2025 Update
                                                       show up for a vaccination appointment to better monitor completion of
                                                       the second dose, consistent with its vaccination goals. In response,
                                                       VA officials told us they were able to identify individuals overdue for
                                                       their second vaccination, which would help them target outreach and
                                                       improve completion of vaccine regimens. We closed both our
                                                       recommendations as implemented.
                                                   •   Federal leadership and coordination. Actions by HHS addressed
Public Health Emergency Preparedness
                                                       some of our recommendations to improve its leadership and
In January 2022, we added the Department of
Health and Human Services (HHS) leadership             coordination of the COVID-19 response. For example, HHS
and coordination of our nation’s preparedness          established a memorandum of understanding with the Department of
for, and response to, public health
emergencies to GAO’s High Risk List.
                                                       Labor to share information related to medical devices with emergency
This high-risk designation was based on over           use authorizations, which allow the temporary use of unapproved
a decade of GAO work that identified systemic          medical products during emergencies. This addressed a
deficiencies at HHS that have hindered the             recommendation we made to HHS in March 2021 to improve its role
nation’s response to the COVID-19 pandemic
and other emergencies. Specifically, our work          leading the response by ensuring consistent guidance was available
has reported that HHS’s efforts have fallen            across agencies related to devices with emergency use authorizations
short in five key areas of an effective national
response: (1) clear roles and responsibilities,
                                                       during the pandemic.28 HHS also took actions that addressed our
(2) complete and consistent data, (3) clear            September 2020 recommendation that it help jurisdictions and tribal
and consistent communication, (4)                      stakeholders enhance their ability to track the status of medical supply
transparency and accountability, and (5)
understanding key partners’ capabilities and           requests and plan for supply needs during the COVID-19 pandemic
limitations.                                           response.29 Specifically, HHS hosted regular calls for health officials
We have identified more than 40 benefits to            and health care and hospital associations to provide the latest
the federal government and American people
due to progress in this high-risk area.                information on COVID-19 therapeutics including changes to ordering
However, as of January 2025, 83 of our                 and distribution processes. HHS also noted it held monthly calls with
recommendations to HHS related to preparing            states to discuss medical countermeasure distribution and dispensing.
for and responding to public health
emergencies remained open.
Source: GAO. I GAO-25-107588




Improving the Provision of                         Federal agencies have implemented recommendations we made to
Economic Relief                                    improve their processes for providing economic relief to entities impacted
                                                   by the economic downturn resulting from the COVID-19 pandemic. For
                                                   example:

                                                   •   Economic impact payments. Treasury and the Internal Revenue
                                                       Service (IRS) implemented our recommendations to improve their
                                                       provision of relief funds to address pandemic-related financial stress.
                                                       In September 2020, we reported that Treasury and IRS had issued
                                                       payments to all eligible individuals for whom IRS had the necessary

                                                   28GAO-21-387.

                                                   29GAO, COVID-19: Federal Efforts Could Be Strengthened by Timely and Concerted
                                                   Actions, GAO-20-701 (Washington, D.C.: Sept. 21, 2020).




                                                   Page 25                                           GAO-25-107588 COVID-19 2025 Update
                                                       information to do so.30 However, we also found some eligible
                                                       individuals did not receive payments. We recommended that Treasury
                                                       and IRS take steps to (1) enhance their estimates of eligible recipients
                                                       who have yet to receive a payment and (2) strengthen their outreach
                                                       and communications efforts to individuals who may be eligible.
                                                       Treasury and IRS subsequently demonstrated that actions were taken
                                                       that addressed our recommendations. For example, the agencies
                                                       used tax return information to identify nearly 9 million individuals who
                                                       had not received a payment. IRS then sent letters to these individuals
                                                       to inform them that they may be eligible for a payment. The letters
                                                       also provided instructions on how to request a payment. In addition,
                                                       IRS publicly released detailed zip code data from the notices to help
                                                       community outreach partners with their own outreach efforts to
                                                       individuals who may be eligible. As of March 31, 2025, $860.5 billion
                                                       of the $862 billion available for economic impact payments had been
                                                       obligated and expended.
                                                   •   UI system. DOL has implemented 13 of the recommendations we
Unemployment Insurance (UI) System
                                                       made to improve the UI system since June 2022, when the UI system
We designated the UI system as high risk in
June 2022. We found that UI’s administrative
                                                       was added to our High Risk List.31 For example, DOL took steps to
and program integrity challenges pose                  improve its role supporting the provision of temporary UI programs in
significant risks to service delivery and expose       response to a recommendation we made in June 2022.32 We reported
the system to significant financial losses
through fraud and improper payments. Long-             that DOL had supported states’ implementation of these programs by
standing challenges with UI administration             issuing guidance, conducting ongoing monitoring, and providing
and outdated IT systems have hindered
states’ ability to meet the needs of                   technical assistance and funding. However, we also found that states
unemployed workers, especially during                  faced numerous customer service challenges due to high UI claims
economic downturns. Such challenges have               volumes, and that DOL could have better assisted states in
also contributed to impaired service, declining
access, and disparities in benefit distribution.       addressing such challenges. We recommended that DOL review the
The Department of Labor has implemented 13             customer service challenges that state UI programs faced during the
of our recommendations to improve the UI               pandemic, identify comprehensive information on customer service
system since June 2022. As of January 2025,
14 recommendations remained open, five of
                                                       best practices, and provide states with this information to assist them
which we consider to be priority                       in improving service delivery.
recommendations.
Source: GAO. I GAO-25-107588                           We closed this recommendation in January 2023 based on actions
                                                       taken by DOL to better support states, and the agency has continued
                                                       to make progress in this area. For example, in response to our
                                                       recommendation, DOL provided multidisciplinary expert teams to
                                                   30GAO-20-701.

                                                   31GAO, Unemployment Insurance: Transformation Needed to Address Program Design,
                                                   Infrastructure, and Integrity Risks, GAO 22 105162 (Washington, D.C.: June 7, 2022).
                                                   32GAO, Unemployment Insurance: Pandemic Programs Posed Challenges, and DOL
                                                   Could Better Address Customer Service and Emergency Planning, GAO-22-104251
                                                   (Washington, D.C.: June 7, 2022).




                                                   Page 26                                            GAO-25-107588 COVID-19 2025 Update
                                  analyze state UI systems and process challenges, and work with
                                  states to identify areas to enhance equitable access and improve
                                  timely delivery of benefits. The teams also encouraged states to
                                  leverage existing tools such as the National Association of State
                                  Workforce Agencies’ Behavioral Insights toolkit, which offers
                                  strategies for accelerating claimants’ responses to information
                                  requests and helping claimants accurately report required information.
Improving the Effective and   Over the course of the pandemic, agencies took steps to address
Appropriate Use of Economic   recommendations we made to improve their controls to mitigate risks of
Relief Funds                  improper payments and fraud in economic relief provided during the
                              pandemic. In some instances, we identified financial benefits resulting
                              from such actions. For example:

                              •   Relief to health care providers. HRSA actions to address a
                                  recommendation we made to improve its post-payment oversight of
                                  Provider Relief Funds have helped it recover billions of improper
                                  payments. In October 2021 we reported that HRSA had taken steps to
                                  initiate its oversight of payments to reimburse eligible providers for
                                  health care-related expenses or lost revenues attributable to COVID-
                                  19.33 However, we found HRSA needed to take additional actions to
                                  help ensure that relief payments were made only to eligible providers
                                  in correct amounts and to identify unused payments or payments not
                                  properly used. We recommended that HRSA finalize its procedures
                                  for recovery and implement post-payment recovery of such payments.
                                  We reported in September 2023 that HRSA had addressed our
                                  recommendation based on our review of its recovery processes and
                                  its plan for seeking recovery of payments. At that time, we found that
                                  HRSA had already recovered nearly half of the $2.6 billion in
                                  payments to non-compliant providers, overpayments, and unused
                                  payments identified for recovery.34 Based on our analysis of HRSA
                                  data, we determined that about $1.3 billion of the amounts the agency
                                  recovered in fiscal years 2022 and 2023 were attributable to our work.




                              33GAO-22-105051.

                              34GAO, COVID-19 Provider Relief Fund: HRSA Continues to Recover Remaining
                              Payments Due from Providers, GAO-23-106083 (Washington, D.C.: Sept. 21, 2023).




                              Page 27                                         GAO-25-107588 COVID-19 2025 Update
Emergency Loans to Small Businesses                 •   Emergency loans to small businesses. SBA’s efforts addressing
We added the Small Business                             recommendations we made to improve its controls in providing
Administration’s (SBA) oversight of                     emergency loans and grants to small businesses have resulted in
emergency loans to our High Risk List in                financial and other benefits. Such efforts have better positioned the
March 2021.
SBA quickly set up the Paycheck Protection
                                                        agency to respond to program integrity risks and have already
Program and COVID-19 Economic Injury                    resulted in more than $14.8 billion in financial benefits since we added
Disaster Loan program to respond to the                 SBA to our High Risk List in 2021. For instance, SBA implemented an
adverse economic conditions small
businesses faced during the COVID-19
                                                        oversight plan to identify and respond to risks in PPP in response to a
pandemic. However, we identified significant            recommendation we made in June 2020.35 Through the review of
program integrity risks, potential for fraud, and       loans under this plan, SBA prevented more than $6.4 billion in
the need for improved management and
oversight.                                              potentially fraudulent loans from being forgiven. Further, SBA
We have made 10 recommendations to SBA                  incorporated its fraud-detection screening from this program into two
to improve its pandemic relief programs, of             later pandemic relief programs—the Shuttered Venue Operators
which two remained open as of January 2025.
Source: GAO. I GAO-25-107588
                                                        Grant Program and the Restaurant Revitalization Fund—when the
                                                        programs launched in April and May 2021, respectively. Through
                                                        these efforts, SBA was able to prevent more than $4.8 billion in
                                                        potentially fraudulent applications from being funded.
GAO Recommendations                                 Although the federal public health emergency for COVID-19 expired in
that Remain Open                                    May 2023, recommendations that remained unimplemented as of March
                                                    2025 identify opportunities to further improve the government’s pandemic
Underscore Opportunities
                                                    response. Open recommendations also underscore opportunities to
for Further Improvement in                          improve the government’s ability to respond to future public health
the COVID-19 Response                               emergencies. Addressing these recommendations is paramount as the
and Preparedness for                                nation continues to face threats that could impact public health and the
Future Emergencies                                  economy.

Improving the Public Health                         Our COVID-19 oversight work and related recommendations identify
Response                                            opportunities to address persistent deficiencies in the government’s
                                                    preparedness for responding to public health emergencies, including the
                                                    following examples:

                                                    •   Federal leadership and coordination. Open recommendations
                                                        related to deficiencies in HHS’s leadership and coordination of the
                                                        COVID-19 response and the response to other recent emergencies
                                                        identify ways for the agency to better position the government to
                                                        respond to future threats. For instance, in February 2023, we
                                                        recommended that HHS include an approach to systematically
                                                        assess, and respond to, known challenges and future risks associated
                                                        with advanced development and manufacturing of countermeasures


                                                    35GAO, COVID-19: Opportunities to Improve Federal Response and Recovery Efforts,
                                                    GAO-20-625 (Washington, D.C., June 25, 2020).




                                                    Page 28                                          GAO-25-107588 COVID-19 2025 Update
    in its new program model for rapid countermeasure production.36 By
    fully implementing this recommendation, HHS could better ensure that
    the nation has the domestic infrastructure and expertise to produce
    medical countermeasures—such as drugs and vaccines—to respond
    to future public health emergencies.
    We also have open recommendations for HHS to address deficiencies
    in its management of the Strategic National Stockpile. This includes
    our October 2022 recommendation for HHS to develop an approach
    for regularly managing the risks associated with gaps between the
    Strategic National Stockpile’s inventory levels and recommended
    quantities.37 Additionally, in May 2024, we reported that HHS should
    take steps to address the challenges that jurisdictions identified
    regarding coordination with the federal government around stockpile
    assets during the COVID-19 pandemic and the mpox public health
    emergency.38 Specifically, we recommended that relevant agencies
    within HHS work together to clearly define their respective roles and
    responsibilities related to the Strategic National Stockpile in a formal
    document and share that document with jurisdictions. By improving its
    leadership and coordination related to the stockpile—both internally
    and externally—ahead of the next emergency, HHS will be better
    positioned to understand and manage challenges that might otherwise
    derail future responses.
•   National aviation preparedness plan. Our open 2015
    recommendation identifies opportunities for the Department of
    Transportation to better prepare the aviation system for responding to
    future public health emergencies.39 We have previously reported that
    the absence of a national aviation preparedness plan to address
    communicable disease threats undermined a coordinated response to
    the COVID-19 pandemic. Although we had recommended in 2015 that
    the Department of Transportation develop such a plan, the



36GAO, Public Health Preparedness: HHS Should Plan for Medical Countermeasures
Development and Manufacturing Risks, GAO-23-105713 (Washington, D.C.: Feb. 2,
2023).
37GAO, Public Health Preparedness: HHS Should Address Strategic National Stockpile
Requirements and Inventory Risks. GAO-23-106210 (Washington, D.C.: Oct. 17, 2022).
38GAO, Public Health Preparedness: HHS Should Address Strategic National Stockpile
Coordination Challenges, GAO-24-106260 (Washington, D.C.: May 2, 2024).
39GAO, Air Travel and Communicable Diseases: Comprehensive Federal Plan Needed for
U.S. Aviation System’s Preparedness, GAO-16-127 (Washington, D.C.: Dec. 16, 2015).




Page 29                                          GAO-25-107588 COVID-19 2025 Update
                                 recommendation remained unimplemented as of March 2025.40 With
                                 the recurring threat of communicable diseases quickly spreading
                                 around the globe through air travel, it remains critical that the agency
                                 address this. Doing so would better position the Department of
                                 Transportation and other aviation system stakeholders to reduce the
                                 spread of emerging communicable diseases while also minimizing
                                 unnecessary aviation disruptions in the future.
Improving the Provision of   Open recommendations and matters identify opportunities for the
Economic Relief              government to improve the provision of relief to entities facing economic
                             hardship in response to future emergencies. For example:

                             •   Emergency relief to tribal recipients. Our December 2022 matter
                                 provides a policy option for Congress to consider when it wants to
                                 provide emergency relief to Tribes during future public health
                                 emergencies.41 Federal pandemic relief funding has included at least
                                 $43.6 billion for programs serving Tribes, tribal members, and tribal
                                 organizations. We found that while some agencies were able to use
                                 existing programs to provide this relief, others had to develop new
                                 ones. These new programs generally required more time and
                                 administrative capacity for agencies to implement and for tribal
                                 recipients to access and use, which inadvertently created barriers for
                                 Tribes’ access to relief funds.
                                 Based on our findings we recommended that Congress consider
                                 providing agencies with explicit authority to use established
                                 mechanisms to administer relief to Tribes in the future. By doing so,
                                 Congress could better ensure that agencies distribute these funds
                                 quickly and with minimal additional administrative burden on tribal
                                 recipients and agencies.
                             •   UI system. DOL has not fully implemented our recommendations to
                                 strengthen the UI system; addressing these recommendations would
                             40In June 2020, we urged Congress to take legislative action to require the Secretary of
                             Transportation to work with relevant agencies and stakeholders to develop a
                             national aviation-preparedness plan to limit the spread of communicable disease threats
                             and minimize travel and trade impacts. The Consolidated Appropriations Act, 2023,
                             included a requirement for the Secretary of Transportation, in coordination with the
                             Secretary of Health and Human Services, the Secretary of Homeland Security, and the
                             heads of other federal departments or agencies as the Secretary of Transportation
                             considers appropriate, to develop a national aviation-preparedness plan for communicable
                             disease outbreaks by Dec. 29, 2024, as we had recommended. See Pub. L. No. 117-328,
                             § 105 136 Stat. 4459, 5253 (2022).
                             41GAO, COVID-19 Relief Funds: Lessons Learned Could improve Future Distribution of
                             Federal Emergency Relief to Tribal Recipients, GAO-23-105473 (Washington, D.C.: Dec.
                             15, 2022).




                             Page 30                                              GAO-25-107588 COVID-19 2025 Update
    improve service to unemployed workers and reduce the system’s
    exposure to financial risks. For example, in June 2022 we
    recommended that DOL develop and execute a transformation plan.42
    Long-standing challenges associated with regular UI—including
    administrative challenges with providing customer service and timely
    processing of UI benefits, and outdated IT systems—had hindered the
    program’s ability to efficiently and effectively fulfill its purpose. During
    the COVID-19 pandemic, historic levels of job loss exacerbated these
    issues in all UI programs, and the risk of payment errors—including
    those resulting from fraud—greatly increased.
    In April 2024, DOL released a comprehensive plan for transforming
    the UI system with strategies to address our recommendation. This
    plan includes strategies to deliver high-quality customer service, build
    resilient and responsive state IT systems, and bolster state UI
    programs against fraud. As of December 2024, DOL officials said that
    47 of the 53 strategies in the plan have been completed or are in
    progress. DOL’s plan also includes recommended legislative reforms
    for congressional action. We will close this recommendation after DOL
    fully executes its plan by working with states to complete actions that
    are currently in progress or planned, and assisting Congress as
    needed to further pursue efforts to transform the UI system.
    We also recommended in June 2022 that DOL study and advise
    Congress and other policymakers on various options to systematically
    support self-employed and contingent workers during periods of
    involuntary unemployment.43 Without doing so, workers involved in
    short term, intermittent, or contract work may miss out on this vital
    lifeline. Additionally, Congress and other policymakers will lack
    important information for considering options to support these workers
    during future periods of involuntary unemployment.
    DOL agreed with this recommendation and has begun taking steps to
    address it. Specifically, DOL’s April 2024 comprehensive plan for
    transforming the UI system recommended legislative reforms to
    extend UI to serve workers that fall outside of the traditional UI
    system. As of January 2025, DOL continued to implement the efforts
    outlined in its plan. This recommendation will remain open until DOL
    completes its planned efforts, including to explore policy and
    implementation issues related to extending UI to self-employed and

42GAO-22-105162.

43GAO, Pandemic Unemployment Assistance: Federal Program Supported Contingent
Workers Amid Historic Demand, but DOL Should Examine Racial Disparities in Benefit
Receipt, GAO-22-104438 (Washington, D.C.: June 7, 2022).




Page 31                                           GAO-25-107588 COVID-19 2025 Update
                                  contingent workers, shares the results of those efforts publicly, and
                                  provides related technical assistance to Congress.
Improving the Effective and   While the disbursement of COVID-19 relief funds is largely complete, our
Appropriate Use of Economic   open recommendations identify opportunities for federal agencies to
Relief Funds                  improve their oversight of these funds and efforts to recover any improper
                              and fraudulent payments. For example:

                              •   Financial aid for funeral expenses. Addressing our April 2022
                                  recommendation to improve the consistency and accuracy of COVID-
                                  19 Funeral Assistance data would help the Federal Emergency
                                  Management Agency (FEMA) with identifying potential fraud and
                                  control deficiencies.44 We found that FEMA did not sufficiently
                                  maintain the quality of the application data for COVID-19 Funeral
                                  Assistance in a way that would facilitate effective oversight of these
                                  funds and help the agency to prevent and detect potential fraud. We
                                  recommended that FEMA ensure that consistent and accurate data
                                  are available for monitoring potential fraud trends and identifying
                                  control deficiencies by updating data records as data are verified and
                                  adding data fields, where necessary.
                                  Although FEMA agreed with the recommendation and has taken steps
                                  to address it, the recommendation remained open as of March 2025.
                                  Specifically, as of March 2025, FEMA did not have plans to change
                                  how data are recorded on whether applications were paid, and the
                                  amount of funeral assistance awarded for specific decedents on an
                                  application with multiple decedents. FEMA officials stated that the
                                  data are of sufficient quality such that no further action is needed,
                                  particularly given the resources that would be required to change its
                                  data system.
                                  To support these statements, the agency would need to perform a
                                  formal fraud risk assessment to determine risk tolerance and a cost
                                  estimate of the resources required to make the necessary changes.
                                  Absent those assessments, we maintain that the agency should make
                                  targeted efforts—such as updates to how data are entered in the
                                  system of record—to improve the consistency and accuracy of
                                  COVID-19 Funeral Assistance data to facilitate oversight and prevent
                                  and detect fraud.
                              •   Emergency relief to Tribes, states, localities and territories.
                                  Treasury could enhance its oversight of Coronavirus State and Local

                              44GAO, COVID-19: Current and Future Federal Preparedness Requires Fixes to Improve
                              Health Data and Address Improper Payments, GAO-22-105397 (Washington, D.C.: Apr.
                              27, 2022).




                              Page 32                                         GAO-25-107588 COVID-19 2025 Update
                                               Fiscal Recovery Funds (SLFRF) by addressing recommendations we
                                               made in our December 2023 report.45 While we found that Treasury
                                               had developed a plan to ensure accountability of these funds, the
                                               department had not fully implemented its plan. We recommended that
                                               Treasury (1) conduct timely and systematic reviews of recipients’
                                               single audit reports and (2) issue timely management decisions
                                               pertaining to SLFRF findings in recipients’ single audit reports.46 Until
                                               Treasury issues timely management decisions to SLFRF recipients
                                               with relevant single audit findings, there is an increased risk that
                                               potential findings related to unallowable uses of program funds may
                                               remain unidentified and uncorrected for significant periods of time,
                                               which, in turn, increases the risk of losses to the government in the
                                               form of federal improper payments.
                                          Actions by Congress to address previously reported matters for
                                          congressional consideration can further improve the federal government’s
                                          capabilities for safeguarding funds when providing economic relief in the
                                          future. In March 2022, we identified the following 10 matters for
                                          congressional consideration to enhance the transparency and
                                          accountability of federal spending.47 See table 3.

Table 3: Prior GAO Matters for Congressional Consideration to Ensure Transparency and Accountability for COVID-19 and
Beyond that Remain Open and Unimplemented as of March 2025

                   Matter
Matter 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 2           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.



                                          45GAO, COVID-19 Relief: Treasury Could Improve Its Administration and Oversight of
                                          State and Local Fiscal Recovery Funds, GAO-24-106027 (Washington D.C.: Dec. 14,
                                          2023).
                                          46The Single Audit Act and OMB implementing single audit guidance require nonfederal
                                          entities that receive federal awards to undergo a single audit (an audit of an entity’s
                                          financial statements and federal awards) or, in limited circumstances, a program-specific
                                          audit, when their award expenditures annually exceed a certain amount. See 31 U.S.C.
                                          ch. 75; 31 C.F.R. pt. 200, subpart F. These single audits help agencies reasonably ensure
                                          that federal funds are used in accordance with applicable legal requirements.
                                          47GAO, 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).




                                          Page 33                                               GAO-25-107588 COVID-19 2025 Update
                           Matter
Matter 3                   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 4                   Congress should establish a permanent analytics center of excellence to aid the oversight community in
                           identifying improper payments and fraud.
Matter 5                   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, include internal controls over spending data and improper payment
                           information.
Matter 6                   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 development and implementation of any corrective action plans;
                           and (2) approve any methodology that is not designed to produce a statistically valid estimate.
Matter 7                   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 8                   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 9                   Congress should amend the DATA Act to clarify the responsibilities and authorities of OMB and Department of
                           the Treasury for ensuring the quality of data available on USAspending.gov.
Matter 10                  Congress should amend the Social Security Act 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. I GAO-25-107588



                                                  As of March 2025, all 10 of these matters for congressional consideration
                                                  remain open, although there have been bills introduced in recent
                                                  Congresses that contain provisions that would address many of them. For
                                                  example:

                                                  •    A number of bills introduced in both the 118th Congress, such as H.R.
                                                       8343, H.R. 877, and S. 2924, and the 119th Congress, such as H.R.
                                                       1533 and S. 80, would address both our second and third matters. If
                                                       enacted, these provisions could help enhance oversight of newly
                                                       initiated programs, including those responding to emergencies, as
                                                       well as facilitate congressional oversight and focus agency attention
                                                       on strategic fraud risk management, both during normal operations
                                                       and in emergencies, to better align agencies’ efforts with leading
                                                       practices.
                                                  •    The Ending Improper Payments to Deceased People Act would
                                                       address our 10th matter. See S. 269, 119th Cong. (2025); S. 2492,
                                                       118th Cong. (2023). If enacted, it would make permanent the
                                                       requirement for the Social Security Administration to share its full




                                                  Page 34                                               GAO-25-107588 COVID-19 2025 Update
                      death data with the Department of the Treasury’s Do Not Pay working
                      system, effective December 28, 2026.


                  The COVID-19 pandemic brought significant challenges to the nation’s
Conclusions       public health and economy. The federal government has provided about
                  $4.65 trillion in federal funds through the CARES Act and other laws to
                  help the nation respond to and recover from the pandemic. We have
                  issued 12 comprehensive reports tracking data related to the public
                  health and economic effects of the COVID-19 pandemic and examining
                  the status of COVID-19 funding and spending. In addition, we have
                  issued over 200 standalone reports, testimonies, and science and
                  technology spotlights focused on different aspects of the pandemic.

                  As of March 31, 2025, 200 of the 484 recommendations and matters we
                  made in our work since the beginning of the pandemic remain open and
                  unimplemented. While the federal public health emergency for COVID-19
                  expired in May 2023, our open recommendations and matters underscore
                  further opportunities to improve the federal response.

                  Open recommendations and matters also identify opportunities to help
                  the U.S. better prepare for inevitable future emergencies. Congress and
                  federal agencies are in the unique position to critically consider lessons
                  across the government from the COVID-19 response. It is important that
                  Congress and federal agencies address the problems we have raised in
                  our COVID-19 oversight work not only to continue progress made with
                  public health and economic recovery, but also to help avoid repeating
                  past mistakes when responding to future emergencies.

                  We provided a draft of this report to the Office of Management and
Agency Comments   Budget for review and comment. The Office of Management and Budget
                  did not provide comments on the report.

                  We are sending copies of this report to the appropriate congressional
                  committees and the Office of Management and Budget. In addition, this
                  report is available online at no charge on the GAO website at
                  https://www.gao.gov.




                  Page 35                                     GAO-25-107588 COVID-19 2025 Update
If you or your staff have any questions about this report, please contact
me at farbj@gao.gov. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this report.




Jessica Farb
Managing Director, Health Care




Page 36                                     GAO-25-107588 COVID-19 2025 Update
List of Committees

The Honorable Susan Collins
Chair
The Honorable Patty Murray
Vice Chair
Committee on Appropriations
United States Senate

The Honorable Mike Crapo
Chairman
The Honorable Ron Wyden
Ranking Member
Committee on Finance
United States Senate

The Honorable Bill Cassidy, M.D.
Chair
The Honorable Bernard Sanders
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Rand Paul, M.D
Chairman
The Honorable Gary C. Peters
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Tom Cole
Chairman
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable Brett Guthrie
Chairman
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives


Page 37                                 GAO-25-107588 COVID-19 2025 Update
The Honorable Andrew Garbarino
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable James Comer
Chairman
The Honorable Robert Garcia
Ranking Member
Committee on Oversight and Government Reform
House of Representatives

The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives




Page 38                               GAO-25-107588 COVID-19 2025 Update
Appendix I: GAO Contact and Staff
                  Appendix I: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Jessica Farb, farbj@gao.gov
GAO Contact

                  In addition to the contacts named above, Kate Nast Jones (Assistant
Staff             Director), Raymond Sendejas (Assistant Director), Derry Henrick
Acknowledgments   (Analyst-in-Charge), Sonia Chakrabarty, Annie Chou, Lynda Downing,
                  Gabrielle Fagan, Brian Harechmak, Ying Hu, David Jones, Eric Peterson,
                  Haley Samuel-Jakubos, Amber Sinclair, and Sirin Yaemsiri made key
                  contributions to this report.




                  Page 39                                  GAO-25-107588 COVID-19 2025 Update
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