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GAO-23-105876: A Framework for Managing Improper Payments in Emergency Assistance Programs

Summary

GAO report GAO-23-105876, "A Framework for Managing Improper Payments in Emergency Assistance Programs," a report to congressional committees dated July 2023. It cites $2.4 trillion in estimated improper payments since 2003 for certain federal programs and activities, and explains that while all payments resulting from fraudulent activity are improper, not all improper payments result from fraud. The framework sets out five principles: commit to managing improper payments; identify and assess improper payment risks, including fraud; design and implement effective control activities; monitor the effectiveness of controls; and provide and obtain information to manage improper payments. It recommends steps such as developing internal control plans in advance of future emergencies and avoiding overreliance on "pay and chase" controls.

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“GAO-23-105876: A Framework for Managing Improper Payments in Emergency Assistance Programs.” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-23-105876-a-framework-for-managing-improper-payments-in-emergency-81fbd98618/, SHA-256 df3c81a134f900954f5c6c19fed4470ea89649856e95f62acfd94c49f5ea1bad.

Full text

    A Framework for Managing
    Improper Payments in Emergency
    Assistance Programs

                




$




    July 2023                  GAO-23-105876
   A Framework for Managing Improper Payments
   in Emergency Assistance Programs
   July 2023, Highlights of GAO-23-105876, a report to congressional committees


                                                               IMPROPER PAYMENTS 101                                                     BY THE NUMBERS
    Why GAO Did This Study
    Natural disasters are projected to                          $      What are improper payments?                                       $2.4 trillion
    increase in frequency and intensity.                               Improper payments are any payments that
    These events, as well as pandemics,                                                                                                  Estimated improper
                                                                       should not have been made or that were made
    cyberattacks, and terrorism, have                                                                                                    payments since 2003 for
                                                                       in an incorrect amount—such as overpayments                       certain federal programs
    highlighted challenges federal                                     and underpayments.                                                and activities
    agencies face in responding to
    emergencies. In emergencies, the                                   Are they the same as fraud?
    risk of improper payments may be                                   While all payments resulting from fraudulent
    higher because the need to provide                                 activity are considered improper, not all improper
    assistance quickly can hinder the                                  payments are the result of fraud. For example,
    implementation of effective controls.                              they can result from lack of agency oversight,
                                                                       mismanagement, errors, and abuse.


          What are the five principles that can help federal program managers mitigate
                    improper payments in emergency assistance programs?
                      This framework provides principles to help Congress and federal program managers. When properly
                               and promptly applied, these principles can successfully reduce improper payments.




                      1                                    2                            3                              4                                5

           Commit to                                   Identify and              Design and                      Monitor the                Provide and obtain
        managing improper                           assess improper              implement                    effectiveness of                information to
           payments                                  payment risks,           effective control            controls in managing             manage improper
                                                     including fraud              activities                improper payments                   payments

       • Develop internal control      • Leverage prior risk              • Establish control             • Establish timely ongoing      • Provide improper
         plans in advance to             assessments                        activities at the beginning     monitoring and separate         payment information
         prepare for future            • Quickly identify and               of the program                  evaluations                     to nonfederal entities
         emergencies                     assess new improper              • Leverage existing             • Estimate improper             • Provide improper
       • Identify data-sharing           payment risks                      resources to create             payments                        payment information
         opportunities                 • Support nonfederal                 controls quickly              • Analyze the root cause          to oversight entities
       • Assign clear roles and          entities in assessing            • Prioritize prepayment           of improper payments          • Obtain and use
         responsibilities for managing   and managing improper              controls and avoid            • Monitor nonfederal              information from
         improper payments               payment risks                      overreliance on “pay            entities’ implementation        nonfederal entities and
       • Implement open                • Define risk tolerance              and chase” controls             of emergency assistance         state and local auditors
         recommendations related       • Periodically assess whether      • Ensure controls align           programs
         to improper payments            programs are susceptible           with statutory                • Develop corrective actions
       • Apply lessons learned           to significant improper            requirements
         from past emergencies           payments, including fraud


Source: GAO (analysis and icons). | GAO-23-105876
 A Framework for Managing Improper Payments
 in Emergency Assistance Programs
 July 2023, Highlights of GAO-23-105876, a report to congressional committees


How can applying the principles of GAO’s framework
help address increased risk during emergencies?
Agencies are better able to manage improper payment risk during emergencies if they have taken steps to manage
this risk effectively under normal conditions. When emergencies occur, agencies may need to develop new programs or
significantly expand existing ones, which can involve increased risk. This increased risk may require additional emphasis
on specific elements of the framework, such as those described below. Delaying or omitting the implementation of these
elements may lead to increased risk of improper payments.



     In emergencies, the risk of improper                                            Examples of how the framework can
          payments may be higher                                                        address this increased risk


                                                                                            Developing internal control plans that
                       Emergencies unfold rapidly, and                                      can be immediately implemented or
                       assistance must be distributed quickly                               adapted for a future emergency can
                                                                                            help ensure that agencies are ready to
                                                                                            respond to emergencies (Principle 1)


                                                                                            Estimating improper payments
                       Estimating improper payments after the
                                                                                            expeditiously, including during the
                       first year of assistance may be too late,
                                                                                            initial year of implementation, can help
                       as most funds are already disbursed
                                                                                            programs to address issues sooner
                                                                                            (Principle 2)


                       Emergency programs may allow                                         Prioritizing and implementing prepayment
                       applicants to certify their own eligibility                          controls, such as using existing data
                       for assistance, which can save time but                              sources to verify applicants’ identity and
                       increases the risk of improper                                       eligibility, can help to stop improper
                       payments, particularly due to fraud                                  payments before they are issued
                                                                                            (Principle 3)


                       The need for federal and nonfederal                                  Monitoring the controls used by
                       entities to coordinate means federal                                 nonfederal entities is a step to meeting
                       agencies may have additional                                         oversight responsibilities and can help
                       oversight responsibilities                                           ensure the effective use of federal
                                                                                            funds (Principle 4)

                                                                                            Providing timely, high-quality guidance
                       Emergency legislation can introduce                                  to nonfederal entities, including
                       new requirements and risks for both                                  guidance on program implementation,
                       new and existing programs                                            eligibility requirements, and appropriate
                                                                                            use of funds, can help them interpret
                                                                                            statutory requirements (Principle 5)


Source: GAO (analysis and icons); Lunaraa/stock.adobe.com (icons). | GAO-23-105876


View GAO-23-105876. For more information on fraud risk, contact Johana Ayers at (202) 512-6722 or ayersj@gao.gov.
For more information on improper payment risk, contact Beryl Davis at (202) 512-2623 or davisbh@gao.gov.
Table of Contents
Foreword .............................................................................................................................................................1

Introduction .........................................................................................................................................................3

Framework for Managing Improper Payments in Emergency Assistance Programs ..................................8

1. Commit to Managing Improper Payments ..................................................................................................10

           Develop Internal Control Plans ................................................................................................................................10

           Identify Data-Sharing Opportunities .........................................................................................................................11

           Assign Roles and Responsibilities ...........................................................................................................................13

           Implement Open Recommendations .......................................................................................................................13

           Apply Lessons Learned............................................................................................................................................14

2. Identify and Assess Improper Payment Risks, Including Fraud ..............................................................15

           Leverage Prior Risk Assessments ...........................................................................................................................15

           Identify and Assess New Risks ................................................................................................................................15

           Support Nonfederal Entities .....................................................................................................................................17

           Define Risk Tolerance ..............................................................................................................................................17

           Assess Whether Programs Are Susceptible to Significant Improper Payments......................................................18

3. Design and Implement Effective Control Activities ...................................................................................20

           Establish Control Activities .......................................................................................................................................20

           Leverage Existing Resources ..................................................................................................................................21

           Prioritize Prepayment Controls ................................................................................................................................22

           Align Controls with Statute .......................................................................................................................................23

4. Monitor the Effectiveness of Controls in Managing Improper Payments ...............................................24

           Establish Monitoring Activities..................................................................................................................................24

           Estimate Improper Payments ...................................................................................................................................24

           Analyze the Root Cause ..........................................................................................................................................25

           Monitor Nonfederal Entities ......................................................................................................................................25

           Develop Corrective Actions ......................................................................................................................................26




A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                                                                          Page i
5. Provide and Obtain Information to Manage Improper Payments .............................................................28

          Provide Information to Nonfederal Entities ..............................................................................................................28

          Provide Information to Oversight Entities.................................................................................................................29

          Obtain and Use Information from Nonfederal Entities .............................................................................................30

Appendix I: Congressional Addressees .........................................................................................................31

Appendix II: Additional Sources to Use in Managing Improper Payments .................................................32

Appendix III: Endnotes .....................................................................................................................................34

Appendix IV: GAO Contact and Staff Acknowledgments .............................................................................42

Figures

          Figure 1: Framework for Managing Improper Payments in Emergency Assistance Programs……………………….8

          Figure 2: Principles for Managing Improper Payments and Their Corresponding Internal Control Components…..9

Tables

          Table 1: Examples of Risk Factors That Increase a Program’s Susceptibility to Improper Payments …………….19

          Table 2: Example of Improper Payment Root Cause Analysis………………………………………………………....26

          Table 3: Additional Sources to Use in Managing Improper Payments ………………………………………………..33


Abbreviations
CMS           Centers for Medicare & Medicaid Services
DHS           Department of Homeland Security
DOL           Department of Labor
EIDL          Economic Injury Disaster Loan
FEMA          Federal Emergency Management Agency
HHS           Department of Health and Human Services
HRSA          Health Resources and Services Administration
IRS           Internal Revenue Service
NIST          National Institute of Standards and Technology
OMB           Office of Management and Budget
PIIA          Payment Integrity Information Act of 2019
PPP           Paycheck Protection Program
SBA           Small Business Administration
SSA           Social Security Administration


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A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                                                                Page ii
Foreword


Foreword



                                       I am pleased to present GAO’s Framework for Managing Improper
                                       Payments in Emergency Assistance Programs.

                                       Federal emergency assistance in response to public health crises, natural
                                       disasters, and other catastrophic events can present significant challenges
                                       to agencies that must make timely payments to eligible individuals,
                                       businesses, and other entities. These emergency events and the
                                       corresponding creation of new federal programs or rapid expansion of
                                       existing programs— often with an emphasis on getting money out quickly
                                       to those in need—can strain agencies’ capabilities in managing programs
                                       and ensuring that funds are spent appropriately. Further, the COVID-19
                                       pandemic saw an increase in the frequency and volume of identity-related
                                       fraud, particularly in the areas of unemployment insurance and assistance
                                       to small businesses, as well as sophisticated fraud schemes. These
                                       developments will likely continue to challenge future federal emergency
                                       assistance efforts.

                                       GAO’s oversight of emergency assistance programs has identified
                                       substantial shortcomings in agencies’ application of fundamental internal
                                       controls and fraud risk management practices. These shortcomings can
                                       result in significant improper payments—payments that should not have
                                       been made or were made in the incorrect amount as a result of
                                       mismanagement, errors, abuse, or fraud.

                                       To address these issues, GAO developed this framework to provide
                                       Congress and federal agencies with an overall approach to managing
                                       improper payments in emergency assistance programs. This framework
                                       can also be useful for managing improper payments in non–emergency
                                       assistance programs or during normal program operations.

                                       This framework should be used by federal agencies in conjunction with
                                       existing requirements related to managing improper payments, including
                                       those stemming from fraud. Federal agencies are required to follow the
                                       internal control standards outlined in Standards for Internal Control in the
                                       Federal Government, which provides the foundation of this framework.
                                       This framework’s principles align with a number of internal control steps
                                       that managers should take. Agencies should also apply the leading
                                       practices in GAO’s Framework for Managing Fraud Risks in Federal



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Foreword

                                       Programs in their efforts to combat fraud in a strategic, risk-based
                                       manner.

                                       We developed this framework through a deliberative process and solicited
                                       a wide range of views to help ensure its applicability to the federal
                                       government. This process included interactions with the Council of the
                                       Inspectors General on Integrity and Efficiency; the Chief Financial Officers
                                       Council; the National Association of State Comptrollers, Auditors and
                                       Treasurers; the American Institute for Certified Public Accountants; the
                                       Association of Government Accountants; and the Association of Local
                                       Government Auditors. The views of all parties were thoroughly considered
                                       in finalizing this document. We extend special thanks to those who
                                       provided input on and suggested improvements to this framework.




                                       Gene L. Dodaro
                                       Comptroller General of the United States




A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                   Page 2
Introduction


Introduction



Emergencies require federal agencies to plan proactively
and manage improper payments strategically.
                                       Natural disasters—such as those caused by hurricanes, tornadoes, and
                                       wildfires—have been occurring more frequently and are projected to
                                       increase in frequency and intensity due to climate change. 1 The federal
                                       government faces fiscal exposure from these events as well as from
                                       pandemics, cyberattacks, and terrorism. Such events have highlighted the
                                       challenges federal agencies face in responding to emergencies. These
                                       challenges include implementing new emergency assistance programs
                                       quickly and significantly increasing the volume of funding disbursed
                                       through existing programs. At the same time, new and expanded
                                       programs share the challenge of ensuring that payments are made
                                       properly to eligible recipients.

                                       Improper payments are any payments that should not have been made or
                                       that were made in an incorrect amount—that is, overpayments and
                                       underpayments—under statutory, contractual, administrative, or other
                                       legally applicable requirements. 2 They may include any payment for an
                                       ineligible good or service, any duplicative payment, or any payment made
                                       to an ineligible recipient. An ineligible recipient may receive an improper
                                       payment due to several factors, including fraudulent activity. While all
                                       payments resulting from fraudulent activity—those that involve an
                                       individual or entity obtaining something of value through willful
                                       misrepresentation—are considered improper, not all improper payments
                                       are the result of fraud. For example, improper payments can also be
                                       unintended and can result from lack of agency oversight,
                                       mismanagement, errors, and abuse.

                                       Improper payments are a long-standing, widespread, and significant
                                       problem in the federal government. Since fiscal year 2003, improper
                                       payment estimates across federal executive agencies (referred to in this
                                       report as “federal agencies”) have cumulatively totaled about $2.4 trillion. 3
                                       Federal agencies reported about $281 billion in estimated improper
                                       payments for fiscal year 2021—an increase of $75 billion from the prior
                                       fiscal year and about double the amount reported for fiscal year 2017—
                                       and about $247 billion for fiscal year 2022. 4 About 20 percent of the
                                       federal programs that reported improper payment rates in 2022 were


A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                  Page 3
Introduction

                                       found to have an estimated improper payment rate over 10 percent. 5 In
                                       the prior fiscal year, about 30 percent of the federal programs that
                                       reported improper payment rates were found to have an estimated
                                       improper payment rate over 10 percent. 6 However, we have found that
                                       the federal government is unable to determine the full extent to which
                                       improper payments occur and reasonably ensure that appropriate actions
                                       are taken to reduce them. 7

                                       In recent years, however, some agencies have reduced improper
                                       payments in their programs, including by applying existing requirements
                                       and guidance for managing improper payments. For example, we found
                                       that 19 of the 35 programs that reported estimated improper payment
                                       rates between fiscal years 2017 and 2022 saw their rates decrease. 8 The
                                       decrease in estimated improper payments across these programs in the
                                       5-year period totaled about $15 billion. In addition, our analysis found
                                       that at least 46 programs stopped reporting during this same period
                                       because the agencies determined they were no longer considered
                                       susceptible to significant improper payments. When agencies follow
                                       relevant requirements and guidance, they can successfully reduce
                                       improper payments.

                                       When the federal government provides emergency assistance, the risk of
                                       improper payments may be higher because the need to provide such
                                       assistance quickly can detract from the planning and implementation of
                                       effective controls. Our work has shown that federal agencies should better
                                       plan for and take a more strategic approach to managing improper
                                       payments in emergency assistance programs. For example:

                                       • Unemployment insurance. Prior to the COVID-19 pandemic, the
                                         Department of Labor (DOL) regularly reported billions of dollars in
                                         annual estimated improper payments in the unemployment insurance
                                         system, a federal-state partnership. 9 Under the CARES Act, enacted in
                                         March 2020 to address the public health and economic threats posed
                                         by COVID-19, states implemented three new federally funded programs
                                         that expanded unemployment insurance eligibility and benefits. 10 By
                                         January 31, 2021, DOL had obligated $723 billion to unemployment
                                         insurance as part of COVID-19 relief funding. 11 The risk of improper
                                         payments, including those due to fraud, increased because of the
                                         unprecedented demand and the urgency with which states
                                         implemented the new programs. During the pandemic, states received
                                         more than 42 million unemployment insurance claims from March 21 to
                                         May 30, 2020, compared with 5.1 million in all of fiscal year 2019. In
                                         February 2023, the DOL Inspector General reported that of the $888



A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876               Page 4
Introduction

                                          billion in state and federal unemployment insurance expenditures
                                          disbursed during the pandemic, at least $191 billion may have been
                                          improper payments. 12

                                          We found that states faced challenges processing a historically high
                                          number of claims and ensuring the timely payment of benefits to
                                          eligible individuals. We have made several recommendations to help
                                          DOL strategically manage fraud risks in unemployment insurance
                                          programs, including creating a dedicated fraud management entity and
                                          examining the suitability of existing fraud controls. 13

                                       • Assistance to small businesses. In response to the COVID-19
                                         pandemic, the Small Business Administration (SBA) provided over $1.1
                                         trillion in loans and advances to small business owners suffering from
                                         the economic effects of the pandemic. 14 While this assistance helped
                                         many small businesses, we found that SBA’s initial limited internal
                                         controls and lack of finalized oversight plans created significant risk of
                                         billions of dollars in improper payments.

                                          Specifically, SBA reported $29 billion in estimated improper payments
                                          for fiscal year 2022 for the Paycheck Protection Program (PPP), a new
                                          nationwide program established to provide guaranteed loans to small
                                          businesses adversely affected by COVID-19 that are fully forgivable if
                                          certain conditions are met. It also reported $6.9 billion in improper
                                          payments for fiscal year 2022 for the COVID-19 Economic Injury
                                          Disaster Loan (EIDL) program, which was an expansion of an existing
                                          program to assist small businesses and nonprofits experiencing
                                          economic injury due to COVID-19. 15 In 2020 and 2021, we made several
                                          recommendations aimed at helping SBA to better manage the risks of
                                          improper payments in its programs, including developing and
                                          implementing plans to respond to program integrity risks and address
                                          potential fraud. 16

                                       • Natural disaster response. In 2017, hurricanes and wildfires created
                                         unprecedented demand for federal disaster response and recovery
                                         resources. In response, Congress passed and the President signed three
                                         supplemental appropriations acts, which included an oversight
                                         framework related to internal controls to limit improper payment of
                                         these funds. The third of the supplemental appropriation acts also
                                         required the Office of Management and Budget (OMB) to issue criteria
                                         for federal agencies to use in designing internal control plans for
                                         spending disaster relief funding. In 2019 we reported on weaknesses

A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                  Page 5
Introduction

                                          related to managing improper payments in disaster assistance
                                          programs. For example, certain agencies did not submit timely or
                                          complete internal control plans because OMB did not employ an
                                          effective outreach strategy. 17 We recommended that OMB develop a
                                          strategy for ensuring that agencies communicate timely and sufficient
                                          internal control plans for disaster relief funds. 18

                                       Others in the inspector general community have also found significant
                                       improper payments in emergency assistance programs. For example:

                                       • Lost Wages Assistance program. On August 8, 2020, the President
                                         issued a memorandum directing the Federal Emergency Management
                                         Agency (FEMA) to provide up to $44 billion in lost wages assistance
                                         from the Department of Homeland Security’s (DHS) Disaster Relief Fund
                                         to individuals unemployed or partially unemployed because of the
                                         COVID-19 pandemic. 19 FEMA did not make lost wages payments
                                         directly to claimants. Instead, FEMA provided funding to the state
                                         workforce agencies of participating states and territories, which
                                         delivered the assistance in conjunction with the state workforce
                                         agencies’ existing unemployment systems. 20 Each state workforce
                                         agency was required to collect claimants’ self-certification that they
                                         were unemployed due to the pandemic.

                                          DHS’s Office of Inspector General found that FEMA did not implement
                                          controls that might have prevented 21 state workforce agencies from
                                          distributing more than $3.7 billion in improper payments through the
                                          Lost Wages Assistance program. 21 This occurred because FEMA
                                          launched the program in 11 days without developing and implementing
                                          clear guidance or verifying and monitoring the state workforce
                                          agencies’ controls to help ensure they prevented or mitigated improper
                                          payments. The Inspector General made several recommendations to
                                          FEMA, including that the agency develop and implement a standard risk
                                          assessment process before initiating new federal grant programs, and
                                          that it develop a process for assessing program controls and risks for
                                          when FEMA is mandated to rely on non-FEMA eligibility determinations.

                                       The CARES Act includes a provision for GAO to report on its ongoing
                                       monitoring and oversight efforts related to the COVID-19 pandemic. 22 We
                                       developed this framework as part of our work in response to this
                                       provision. To develop this framework, we reviewed the Payment Integrity
                                       Information Act of 2019 (PIIA), payment integrity guidance published by
                                       OMB, GAO’s Standards for Internal Control in the Federal Government, and
                                       GAO’s Framework for Managing Fraud Risks in Federal Programs. 23 We


A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876               Page 6
Introduction

                                       also reviewed relevant literature, including prior GAO reports related to
                                       improper payments, emergency assistance programs, and fraud risk
                                       management.

                                       In addition, we consulted with GAO specialists on internal control, fraud
                                       risk management, and improper payments. We interviewed officials from
                                       OMB and the Department of the Treasury and officials from interagency
                                       organizations, including the Council of the Inspectors General on Integrity
                                       and Efficiency’s Pandemic Response Accountability Committee and the
                                       Chief Financial Officers Council. We also solicited input from four
                                       organizations that represent federal, state, and local audit associations,
                                       which we identified through our background research and discussions
                                       with GAO experts on improper payments. 24 We asked officials from OMB,
                                       Treasury, and these organizations to review a draft of the framework and
                                       provide input, which we incorporated as appropriate.

                                       We conducted our work from February 2022 to July 2023 in accordance
                                       with all sections of GAO’s Quality Assurance Framework that are relevant
                                       to this framework. The Quality Assurance Framework requires that we plan
                                       and perform our work to obtain sufficient and appropriate evidence to
                                       meet our stated objective and to discuss any limitations in our work. We
                                       believe that the information and data obtained, and the analysis
                                       conducted, provide a reasonable basis for any conclusions in this product.




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Framework for Managing Improper Payments in Emergency Assistance Programs


Framework for Managing Improper Payments
in Emergency Assistance Programs

This framework provides five principles and corresponding practices that can help federal program managers
mitigate improper payments, particularly in emergency assistance programs (see fig. 1). The framework is also
intended as a resource for Congress to use when designing new programs or appropriating additional funding
in response to emergencies. The framework incorporates payment integrity requirements from PIIA and
relevant OMB guidance on payment integrity improvement. It also includes information derived from leading
practices for managing fraud risks in GAO’s Framework for Managing Fraud Risks in Federal Programs. Appendix
II provides additional information on the different sources that informed the development of this framework
and that can be used in managing improper payments.

Figure 1: Framework for Managing Improper Payments in Emergency Assistance Programs




A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876           Page 8
Framework for Managing Improper Payments in Emergency Assistance Programs

Standards for Internal Control in the Federal Government provides the foundation of this framework, and the
framework’s principles align with the components of internal control (see fig. 2). 25

Figure 2: Principles for Managing Improper Payments and Their Corresponding Internal Control Components




A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876            Page 9
1. Commit to Managing Improper Payments
                                       Because emergencies can unfold quickly or unexpectedly, agencies should
                                       commit to managing improper payments before an emergency occurs.
                                       Agencies can implement practices that demonstrate this commitment,
                                       including developing emergency internal control plans in advance to
                                       quickly adapt to an emergency situation, identifying data-sharing
                                       opportunities, assigning clear roles and responsibilities, implementing
                                       open recommendations related to improper payments, and applying
                                       lessons learned from past emergencies.

                                       Develop Internal Control Plans

                                       Because emergencies are inevitable, federal program managers should
                                       commit to managing improper payments early by developing internal
                                       control plans that can be immediately implemented or quickly tailored to
                                       fit the circumstances of a future emergency. 26 Managers should develop
                                       plans in advance that have potential eligibility criteria and controls
                                       designed for likely future emergencies, such as natural disasters. Some
                                       audit and government management organizations we spoke with
                                       emphasized this approach. These plans, developed in advance of an
                                       emergency, could also contain components such as identifying
                                       emergency-related risks and controls to address these risks.

                                       Preexisting internal control plans should include prepayment controls,
                                       such as use of the Do Not Pay working system. This system is operated by
                                       Treasury and provides a variety of data-matching and data-analytics
                                       services for all federal executive and many state agencies to support their
                                       efforts to prevent improper payments. Using the system can help
                                       agencies to determine payment eligibility quickly prior to payment
                                       issuance. 27 Agencies should also plan for expedited postpayment controls,
                                       such as postpayment reviews and recovery audits, which are more critical
                                       when the quick disbursement of funds makes prepayment controls
                                       difficult to apply fully.

                                       Effective, robust internal control plans can help agencies adapt to
                                       changing risks and new priorities. For example, to respond to an
                                       emergency, Congress may direct agencies to create new programs that
                                       are required to issue a large number of payments quickly, as it did with
                                       PPP. Given the immediate need for small business loans during the
                                       COVID-19 pandemic, SBA worked to set up PPP so that lenders could
                                       begin distributing funds as soon as possible. Specifically, SBA
                                       implemented PPP on April 3, 2020, 1 week after the enactment of the
                                       CARES Act. By April 16, 2020, just 14 days after SBA implemented the


A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                Page 10
Commit to Managing Improper Payments

                                       program, lenders had approved more than 1.6 million loans totaling
                                       nearly $342.3 billion. 28

                                       Because the need to provide funds quickly increased the risk of fraud, SBA
                                       would have benefitted from having plans in place prior to the emergency.
                                       Such plans could have helped ensure that program managers considered
                                       improper payment risks associated with emergency funding (such as the
                                       volume of transactions and speed at which they were processed) and
                                       implemented basic internal controls to help mitigate those risks prior to
                                       disbursing the emergency assistance. For example, antifraud controls
                                       within the internal control plan could have included using prepayment
                                       data analytics, such as the Do Not Pay working system mentioned above,
                                       as well as processes to screen payments for potential ineligibility or fraud.
                                       In addition, internal control plans increase transparency and may give
                                       Congress some assurance that agencies will be able to establish or adapt
                                       effective and efficient controls over new or expanded federal funding.

                                       Preexisting internal control plans allow federal program managers to
                                       adapt controls quickly when a program’s statutory requirements change
                                       in an emergency. For example, Congress may significantly expand an
                                       existing program, as it did with the federal unemployment insurance
                                       system during the pandemic. In 2020, DOL’s Pandemic Unemployment
                                       Assistance program expanded unemployment benefits to independent
                                       contractors, self-employed individuals, and others not traditionally eligible
                                       for these benefits. Applicants were required to self-certify that they were
                                       eligible for pandemic-related assistance before payments were sent. Also
                                       in 2020, the DOL Office of Inspector General reported self-certification as
                                       a top fraud vulnerability for state workforce agencies administering
                                       pandemic-related unemployment benefits. 29 Congress addressed this
                                       issue in the 2021 Consolidated Appropriations Act by creating new
                                       documentation requirements for Pandemic Unemployment Assistance
                                       claimants; however, the program had already become an attractive target
                                       for increasingly sophisticated fraud schemes. 30 Preexisting internal control
                                       plans might have helped managers quickly implement appropriate
                                       controls before payments were disbursed—such as leveraging existing
                                       data-matching services to validate individuals’ employment status. In
                                       emergencies, such plans may also help agencies to expedite more timely
                                       postpayment checks.

                                       Identify Data-Sharing Opportunities

                                       Sharing data allows programs to compare information from different
                                       sources to help ensure that payments are appropriate before they are
                                       made. Using different data sources to confirm identity and eligibility


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Commit to Managing Improper Payments

                                       information can be a key step in reducing improper payments in
                                       emergency assistance programs.

                                       Agencies should proactively identify data they may need to verify
                                       applicant identity and eligibility and resolve any barriers to accessing data
                                       before an emergency occurs, including entering into data-sharing
                                       agreements. Data-sharing agreements allow agencies access to necessary
                                       external data, which can be used to improve a program’s existing controls
                                       or develop new verification controls to help overcome incomplete or
                                       missing applicant information. 31 For example, agencies can enter into
                                       Computer Matching Agreements, which permit federal agencies to
                                       conduct data matches with one another to establish or verify personal
                                       information. 32

                                       Identifying data-sharing opportunities in advance can help agencies
                                       identify barriers to accessing data, such as statutory restrictions, and
                                       proactively work to resolve them before an emergency occurs. While the
                                       obligation to control and protect data can limit agencies’ ability and
                                       willingness to share information across the federal government, program
                                       managers may be able to identify authorities under which data sharing is
                                       permissible for the purpose of enhancing identity-verification controls.
                                       For example, the Privacy Act of 1974, as amended, defines a number of
                                       conditions under which federal agencies may share information with other
                                       government agencies without the affected individual’s consent. 33 To help
                                       ensure the integrity of direct payments to individuals, we have
                                       recommended that Congress consider amending the Social Security Act
                                       to explicitly allow the Social Security Administration (SSA) to share its full
                                       death data with Treasury for data matching to prevent payments to
                                       ineligible individuals. 34

                                       Having data-sharing agreements in place before an emergency occurs can
                                       help ensure timely access to verification information, and these
                                       agreements can be used in the prevention and detection of improper
                                       payments. For example, in January 2023, the Pandemic Response
                                       Accountability Committee identified $5.4 billion in potential identity fraud
                                       associated with 69,323 questionable and unverified Social Security
                                       numbers across disbursed COVID-19 EIDL and PPP loan program
                                       applications. The committee found that if SBA had been able to verify the
                                       accuracy of the Social Security numbers on borrower applications, it could
                                       have reduced the possibility of identity theft and ensured that benefits
                                       were paid only to eligible recipients. However, the process of
                                       implementing a new Social Security number verification agreement and
                                       addressing the legal questions regarding information sharing can be
                                       lengthy, and the time required to establish these types of agreements can


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Commit to Managing Improper Payments

                                       create delays and challenges, particularly in an emergency. The Pandemic
                                       Response Accountability Committee found that having such agreements
                                       in place before an emergency occurs would ensure timely access to
                                       verification information and protect taxpayer funds from improper
                                       payments. 35

                                       Assign Roles and Responsibilities

                                       Federal program managers should ensure that sufficient resources are
                                       applied to oversee improper payment and fraud risk management
                                       activities, and that authority and responsibility for internal control are
                                       clearly assigned and periodically reviewed.

                                       For example, the Centers for Medicare & Medicaid Services (CMS) created
                                       the Center for Program Integrity, a centralized entity responsible for
                                       Medicare and Medicaid program integrity issues. 36 After receiving
                                       additional funding, CMS allocated additional staff to the center and was
                                       able to establish working groups and interagency collaboration aimed at
                                       reducing improper payments. By assigning responsibility for payment
                                       integrity to this center, CMS was able to centralize the development and
                                       implementation of automated prepayment controls used to deny
                                       Medicare claims that should not be paid. As CMS has undertaken these
                                       efforts and others to address improper payments, it has seen a reduction
                                       in improper payments. Between fiscal years 2018 and 2020, Medicare’s
                                       fee-for- service and Medicare Advantage saw a reduction in their
                                       improper payment rates of more than 1 percentage point, which is
                                       significant given that Medicare’s improper payments accounted for over
                                       one-quarter of the total amount of improper payments made
                                       government-wide in fiscal year 2019. 37

                                       Clearly assigning roles and responsibilities for managing improper
                                       payments should also include establishing a dedicated antifraud entity to
                                       strategically manage fraud risks. 38 Having such an entity can help ensure
                                       that improper payment risks related to fraudulent activity are identified
                                       and assessed as the emergency unfolds and that appropriate controls are
                                       implemented when agencies distribute emergency funding. Such entities
                                       should have clearly defined and documented responsibilities and
                                       authority for managing fraud risks.

                                       Implement Open Recommendations

                                       Agencies can also prepare for future emergencies by promptly
                                       implementing recommendations made during normal operations by their
                                       inspectors general or GAO. For example, in 2018, GAO recommended that


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                                       the Internal Revenue Service (IRS) take steps to improve its efforts to
                                       authenticate taxpayers. 39 IRS had not fully implemented these
                                       recommendations at the onset of the COVID-19 pandemic, and
                                       subsequently IRS officials raised concerns that fraudsters could be taking
                                       economic impact payments intended for eligible recipients by improperly
                                       accessing IRS’s online payment portal and routing payments to their own
                                       bank accounts. By taking actions to address the open recommendations
                                       prior to the COVID-19 pandemic, IRS might have had better controls and
                                       safeguards in place during the emergency to manage improper payment
                                       risks and help ensure that eligible individuals in need of economic impact
                                       payments received them. 40

                                       In addition to implementing open recommendations made during normal
                                       operations, agencies can improve the integrity of their emergency
                                       assistance programs by implementing recommendations made during
                                       emergency operations. For example, we and inspectors general have
                                       made hundreds of recommendations in the course of performing COVID-
                                       19 oversight, many of which remained unimplemented at the end of the
                                       national emergency in May 2023.

                                       Apply Lessons Learned

                                       Agencies can also apply lessons learned about improper payments during
                                       emergencies to inform future practices. For example, during the COVID-
                                       19 pandemic, we and several inspectors general made recommendations
                                       to help agencies reduce improper payments, including those stemming
                                       from fraudulent activity in unemployment insurance and the EIDL
                                       program. These recommendations could benefit agencies in future
                                       emergencies. 41

                                       For example, in a future emergency, if agencies allow applicants to self-
                                       certify that they are eligible for assistance, agencies should consider
                                       establishing additional fraud controls, such as validating self-certifications
                                       with tax returns, employer certifications, or other alternate documentation
                                       before disbursing payments. The Pandemic Response Accountability
                                       Committee found that this lesson applies broadly to federal agencies that
                                       rely on self-certification to determine eligibility. 42 Agencies could apply
                                       this lesson by having a plan in place for validating self-certified eligibility
                                       information before the next emergency occurs. Applying lessons learned
                                       from past emergencies will help agencies build a foundation to quickly
                                       respond to and mitigate payment integrity risks in future emergencies.




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2. Identify and Assess Improper Payment Risks,
Including Fraud
                                       Agencies should identify and address improper payment risks both as
                                       part of their normal operations before an emergency occurs and once
                                       emergency conditions develop. This process includes leveraging prior risk
                                       assessments, identifying and assessing new risks, supporting nonfederal
                                       entities that administer federal programs in managing payment integrity
                                       risks, defining programs’ risk tolerance, and periodically assessing whether
                                       programs are susceptible to significant improper payments.

                                       In emergency assistance programs, understanding the general magnitude,
                                       likelihood, and nature of improper payment risks before spending begins
                                       is critical. Conducting regular risk assessments can help program
                                       managers identify and respond to risks facing the entity, including fraud.
                                       While some programs may conduct statutorily required risk assessments,
                                       such as the improper payment risk assessment discussed below, programs
                                       that do not meet the statutory threshold for improper payment risk
                                       assessments should still strategically assess and manage their risks of
                                       improper payments. 43 This approach provides both safeguards for normal
                                       operations and a starting point for assessing new emergency assistance
                                       programs and expanded programs, which may have significantly altered
                                       risks and may need modified or new controls.

                                       Leverage Prior Risk Assessments

                                       Federal program managers can take steps to understand risks in new
                                       emergency assistance programs by leveraging risk assessments of prior
                                       programs or similar emergency assistance programs. For example, DOL
                                       implements temporary unemployment insurance programs following
                                       natural disasters. These temporary programs have regulations similar to
                                       those of the unemployment assistance program DOL implemented during
                                       the COVID-19 pandemic, and these programs have previously been
                                       audited for improper payments by DOL’s Office of Inspector General. In
                                       emergency situations, using the risk assessments of previous or similar
                                       emergency assistance programs could better position program managers
                                       to quickly identify and assess improper payment risks and design
                                       appropriate internal controls to mitigate them.

                                       Identify and Assess New Risks

                                       Federal program managers should also identify and assess any new
                                       improper payment risks or changes in the likelihood of existing risks
                                       stemming from the emergency. For example, one office we spoke to with


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Identify and Assess Improper Payment Risks, Including Fraud

                                       payment oversight responsibilities was required to shift to a remote
                                       (telework) posture at the onset of the COVID-19 pandemic. However, not
                                       all personnel had the appropriate technology to oversee and manage the
                                       distribution of payments from a remote posture, which increased the risk
                                       of improper payments. 44

                                       Legislation to address emergencies can also introduce new risks. For
                                       example, a state auditor noted that when CARES Act legislation expanded
                                       unemployment insurance payments to independent contractors, staff did
                                       not have the means to conduct traditional employment verification for
                                       them. Some independent contractors who realized the state had no way
                                       to verify their unemployment may have been able to fraudulently claim
                                       they were unemployed, contributing to improper payments.

                                       The likelihood or severity of existing risks can also change. For example,
                                       an organization we spoke to noted that the risk of fraudulent activity may
                                       be higher when programs contract with and provide payments to
                                       unfamiliar businesses and do not have an established method to
                                       determine contractors’ legitimacy. Specifically, a state auditor’s office told
                                       us its staff routinely work with certain types of contractors after natural
                                       disasters, such as debris removal contractors, and based on prior
                                       experience are able to identify fraudulent companies more easily. During
                                       the COVID-19 pandemic, however, they had to work with ventilator
                                       contractors for the first time, and the lack of experience meant they had
                                       no basis on which to evaluate whether certain contractors were
                                       fraudulent. Fraudulent companies seeking contracts was a known existing
                                       risk that this auditor considered, but the circumstances of the pandemic
                                       increased the likelihood of this type of fraud.

                                       In emergencies, when program administrators need to confirm recipient
                                       identity and eligibility expeditiously, the extent to which agencies rely on
                                       applicants self-certifying their eligibility can increase. However, as
                                       discussed previously, we and others have repeatedly found that self-
                                       certification can increase the risk of fraud, which may ultimately reduce
                                       the total amount of funds available to eligible individuals and
                                       businesses. 45 For example, to apply for an EIDL loan from SBA, businesses
                                       certified that they were established on or before January 31, 2020, by
                                       entering their establishment date on their application form. SBA did not
                                       verify this information with another data source or ask for additional
                                       supporting documentation before disbursing funds. When SBA’s Office of
                                       Inspector General later used employer identification number data to audit
                                       the program, it found that the agency had approved over 22,700
                                       potentially ineligible applications. As a result of not identifying and



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Identify and Assess Improper Payment Risks, Including Fraud

                                       assessing this risk, SBA distributed $918 million in loan funds that were
                                       potentially improper payments. 46

                                       Support Nonfederal Entities

                                       In emergency assistance programs, addressing improper payment risks is
                                       often a responsibility shared between federal and nonfederal entities,
                                       such as tribal, state, territorial, and local governments, and federal
                                       program managers should assist their counterparts with assessing and
                                       managing risk.

                                       For example, nonfederal program administrators may assume
                                       responsibility for determining program eligibility, ensuring accurate
                                       benefit payments, and preventing fraudulent and other improper
                                       payments. Federal program managers can assist them in mitigating
                                       improper payment risk by providing fraud-related guidance, general
                                       support, and technical assistance. Furthermore, an audit and an oversight
                                       organization told us that federal program managers should ensure their
                                       state and local counterparts have their own risk assessment strategies,
                                       which can include activities such as assessing their vendors’ internal
                                       controls. In circumstances where program eligibility decisions are
                                       determined outside of the federal agency, taking steps to assist a
                                       counterpart may help to mitigate risk.

                                       Define Risk Tolerance

                                       When managing an emergency assistance program, federal program
                                       managers may choose to adjust their risk tolerance, or willingness to take
                                       on risk, with respect to improper payments. Because the nature of
                                       emergency assistance can increase vulnerability to improper payments,
                                       program managers should weigh their objective to provide assistance
                                       quickly against the increased risk of improper payments.

                                       For example, when responding to natural disasters, an emergency
                                       assistance program may contract with businesses for emergency services,
                                       such as debris removal. The managers may generally define their risk
                                       tolerance as “very low” because improper payments could undermine the
                                       program and waste resources. Therefore, they may require a full
                                       verification check as a control to ensure they identify businesses that may
                                       be using falsified tax identification numbers or fraudulent business
                                       websites. This control would have a high level of certainty of identifying
                                       fraud before issuing a payment. However, depending on the
                                       circumstances of the emergency, managers may accept a higher risk
                                       tolerance, and they might decide to waive the full verification control and


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Identify and Assess Improper Payment Risks, Including Fraud

                                       opt for a control activity that is more limited (such as auditing a sample of
                                       businesses to verify their identities). Such a limited control provides less
                                       assurance that improper payments are being detected but is less time
                                       consuming and may help get assistance out faster.

                                       Program management should define a program’s risk tolerance according
                                       to OMB guidance and federal internal control standards. Management
                                       should then develop an internal control system that balances these risks
                                       with controls so as to identify, achieve, and maintain a tolerable level of
                                       improper payments. 47

                                       Assess Whether Programs Are Susceptible to
                                       Significant Improper Payments

                                       Conducting improper payment risk assessments should be a routine part
                                       of risk management for federal programs, but emergency assistance
                                       programs may involve additional considerations because the risk of
                                       improper payments is higher. Federal program managers are required by
                                       law to periodically assess whether programs with annual outlays of over
                                       $10 million may be susceptible to significant improper payments, which
                                       would trigger requirements for improper payment estimates and
                                       corrective action plans. 48 While these improper payment risk assessments
                                       typically occur on a 3-year cycle, whenever a program experiences a
                                       significant change in legislation or funding—such as during a natural
                                       disaster or emergency—or any event that increases payment integrity risk,
                                       program managers should conduct an off-cycle risk assessment. 49

                                       For newly established programs, OMB guidance states that improper
                                       payment risk assessments should be completed after the first 12 months
                                       of the program. 50 However, for emergency assistance programs, especially
                                       large programs where there are concerns about the possibility of
                                       widespread improper payments, we have emphasized the importance of
                                       program management estimating improper payments expeditiously. 51
                                       This can include during the initial year of implementation. Given the rapid
                                       timeline of emergency assistance, time lags in assessing risk may result in
                                       improper payment issues, including those resulting from fraudulent
                                       activities, not being identified or addressed until after most or even all
                                       funds are disbursed.

                                       When conducting an improper payment risk assessment, program
                                       managers should consider risk factors that may contribute to a program’s
                                       susceptibility to significant improper payments, including but not limited
                                       to those listed in table 1.




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Identify and Assess Improper Payment Risks, Including Fraud

Table 1: Examples of Risk Factors That Increase a Program’s Susceptibility to Improper Payments
• Whether the program or activity is new to the agency

• The complexity of the program or activity

• The volume of payments made through the program or activity

• Whether payments or payment eligibility decisions are made outside of the executive agency, such as by a state or local government
  or another third party or intermediary

• Recent major changes in program funding, authorities, practices, or procedures

• The level and experience of and quality of training for personnel responsible for making program eligibility determinations or
  certifying that payments are accurate

• Significant deficiencies in the audit report of the executive agency or other relevant management findings that might hinder accurate
  payment certification

• Similarities to other programs or activities that have reported improper payment estimates or been deemed susceptible to
  significant improper payments

• The accuracy and reliability of improper payment estimates previously reported for the program or activity, or other indicator of
  potential susceptibility to improper payments identified by the inspector general of the executive agency or GAO; other audits
  performed by or on behalf of the federal, state, or local government; in disclosures by the executive agency; or through any other
  means

• Whether the program or activity lacks information or data systems to confirm eligibility or provide for other payment integrity needs

Source: GAO and 31 U.S.C. § 3352(a)(3)(B). | GAO-23-105876




                                                             If the improper payment risk assessment determines that the program
                                                             may be susceptible to significant improper payments, this determination
                                                             triggers additional statutory requirements, such as estimating and publicly
                                                             reporting on improper payments (see framework principles 4 and 5). 52 If a
                                                             program has not been determined to be susceptible to significant
                                                             improper payments, the agency should still regularly assess improper
                                                             payment risks and develop appropriate responses. These responses may
                                                             include assessing fraud risks and implementing new or modified control
                                                             activities that are consistent with federal internal control standards. 53




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3. Design and Implement Effective Control Activities
                                       Designing and implementing effective control activities from the
                                       beginning of an emergency assistance program is critical to strong
                                       oversight and helps ensure that agencies achieve program objectives and
                                       respond to identified risks of improper payments in a timely manner.
                                       Practices that support effective control activities include establishing
                                       control activities at the beginning of the program, leveraging existing
                                       resources to create controls, prioritizing prepayment controls, and
                                       ensuring that controls align with statutory requirements. Having an
                                       internal control plan in place before an emergency occurs, as discussed in
                                       principle 1, can help expedite the establishment of control activities from
                                       the beginning of the program.

                                       Establish Control Activities

                                       Incorporating effective control activities from the beginning of the
                                       program is critical to mitigating the risks of improper payments,
                                       particularly when distributing emergency assistance quickly. For example,
                                       an audit organization told us that before the COVID-19 pandemic, most
                                       states required employers to certify that unemployment insurance
                                       applicants were no longer employed with them before the states
                                       disbursed payments. However, the large volume of unemployed
                                       individuals and urgent need for relief, and an initial requirement in the
                                       Pandemic Unemployment Assistance program that allowed applicants to
                                       self-certify their eligibility without providing any documentation, led
                                       states to forgo employer certification. 54 Instead, states made advance
                                       payments to individuals followed by postpayment verification audits,
                                       which increased opportunities for improper payments, including those
                                       resulting from fraudulent activity. This decision reflects a program’s risk
                                       tolerance. One state official noted that relaxing this unemployment
                                       verification control cost the state hundreds of millions of dollars in
                                       improper payments.

                                       Program managers could have implemented a different verification
                                       control in place of employer certification. For example, sending
                                       unemployment claims to the National Association of State Workforce
                                       Agencies’ Integrity Data Hub for matching across datasets to determine if
                                       the claims had suspicious attributes. 55 Tools such as data matching can
                                       provide some assurance against improper payments, while potentially
                                       allowing for more timely payments.

                                       Similarly, SBA’s COVID-19 EIDL program initially had fewer safeguards
                                       than its traditional EIDL program. Under normal operations, SBA would


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Design and Implement Effective Control Activities

                                       use applicants’ federal tax returns to verify parts of their EIDL applications,
                                       but the CARES Act prohibited SBA from obtaining these returns from
                                       applicants. We and the SBA Office of Inspector General found that such
                                       internal control practices may have led to fraud and the provision of EIDL
                                       funding to ineligible entities. In December 2020, Congress passed
                                       legislation that removed the restriction on obtaining tax returns, but
                                       having access to tax returns from the beginning of the program could
                                       have helped mitigate improper payments to ineligible applicants. 56

                                       Leverage Existing Resources

                                       In emergency assistance programs, managers can leverage existing
                                       resources to design and implement control activities that allow them to
                                       disburse assistance rapidly while mitigating identified risks of improper
                                       payments, including those resulting from fraudulent activity. For example,
                                       CMS’s Accelerated and Advanced Payments Program, expanded under
                                       the CARES Act to relieve the financial strain on health care providers
                                       caused by the pandemic, was able to distribute more than $100 billion in
                                       payments to 46,000 eligible providers by leveraging existing resources.
                                       Specifically, the program used CMS databases, including bankruptcy
                                       databases, and publicly available bankruptcy filing records to determine
                                       whether providers were eligible. In an October 2022 report, the
                                       Department of Health and Human Services (HHS) Office of Inspector
                                       General found that CMS generally made these payments in compliance
                                       with CARES Act and federal requirements. 57

                                       Agencies can also leverage controls used in similar programs. For
                                       example, the DOL Office of Inspector General suggested that the
                                       Pandemic Unemployment Assistance program adopt the same controls as
                                       those used in previous temporary disaster unemployment assistance
                                       programs, which required applicants to substantiate self-certified data on
                                       employment and wages with documentation such as pay stubs, business
                                       records, and tax returns. 58

                                       Some audit, oversight, and government management organizations
                                       similarly told us that if an agency decides to relax certain controls
                                       temporarily to provide assistance quickly, it should still leverage existing
                                       resources to implement some basic controls that mitigate improper
                                       payments. For example, the Pandemic Response Accountability
                                       Committee said program managers can use internal data they already
                                       have, such as mailing addresses from other programs they administer, to
                                       implement prepayment controls that help verify identity without requiring
                                       much additional time.



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Design and Implement Effective Control Activities


                                       Prioritize Prepayment Controls

                                       Prepayment controls can help prevent improper payments by identifying
                                       potential fraud and control deficiencies early, and they generally offer the
                                       most cost-efficient use of resources. 59

                                       For example, in August 2020, DOL’s Employment and Training
                                       Administration, which oversees the unemployment insurance system,
                                       issued guidance to state workforce agencies on implementing
                                       prepayment controls for detecting fraudulent claims, including using the
                                       National Association of State Workforce Agencies’ Integrity Data Hub to
                                       screen claims. 60 While the association estimated that use of the Integrity
                                       Data Hub during the COVID-19 pandemic helped to prevent more than
                                       $178 million in improper payments, its use is optional, and only 32 of 54
                                       state workforce agencies had used or partially used it by December 2020.
                                       In February 2021, the DOL Office of Inspector General identified more
                                       than $5.4 billion in potentially fraudulent unemployment insurance
                                       payments made from March 2020 to October 2020, including benefits
                                       paid to individuals using Social Security numbers of deceased persons
                                       and federal inmates. 61 The DOL Inspector General recommended that the
                                       Employment and Training Administration work with Congress to establish
                                       legislation requiring state workforce agencies to cross-match data before
                                       issuing payments in four high-risk areas, including Social Security
                                       numbers of deceased individuals and federal prisoners.

                                       While program managers should prioritize prepayment controls,
                                       postpayment controls, such as recovery audits, are also important.
                                       However, the “pay and chase model,” where efforts are made to identify
                                       and recover improper payments after they are made, can be difficult and
                                       expensive. 62

                                       As managers implement emergency assistance programs, any reduction in
                                       prepayment controls to provide services and issue payments faster should
                                       be mitigated by strengthening postpayment controls, such as sampling
                                       payments to determine whether they were disbursed properly. For
                                       example, within 8 months of disbursing the first Provider Relief Fund
                                       payments, HHS developed a postpayment quality control review process
                                       to help verify that providers had received correct payments and to recover
                                       any overpayments. HHS stated that because full provider eligibility data
                                       that may not have been available at the time of payment had become
                                       available, program managers would review applicant and payment data to
                                       identify improper payments, reassess provider eligibility, and recover
                                       payments that exceeded a threshold of $10,000. 63 Postpayment controls
                                       can also be used to inform future preventive activities—for example, by


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Design and Implement Effective Control Activities

                                       using the results of audits to enhance applicant screenings and fraud
                                       indicators. 64

                                       Align Controls with Statute

                                       Federal managers of emergency assistance programs should ensure that
                                       controls align with statutory oversight requirements. Emergency
                                       assistance funds will likely have different statutory requirements for
                                       eligibility, allowable spending, and reporting, including in existing
                                       programs that are expanded in an emergency. One agency official told us
                                       that bringing together staff from a variety of offices, such as general
                                       counsel, legislative affairs, operations, and information technology, can
                                       aid in developing and implementing effective and realistic controls that
                                       are consistent with statutory requirements.

                                       Managers of emergency assistance programs in which payment eligibility
                                       decisions are made outside the agency, such as programs that distribute
                                       assistance through state and local governments or nonprofits, should also
                                       ensure that nonfederal program administrators have received sufficient
                                       guidance in creating control activities that align with statutory
                                       requirements. One audit organization told us that federal program
                                       managers should share information about improper payment control
                                       activities with nonfederal entities that may not have the resources to
                                       rapidly design effective controls in an emergency.




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4. Monitor the Effectiveness of Controls in Managing
Improper Payments
                                       As part of managing and overseeing federal emergency assistance, federal
                                       program managers should regularly assess the effectiveness of controls in
                                       managing improper payments. Managers can do this by establishing
                                       monitoring activities, estimating improper payments, analyzing their root
                                       causes, monitoring nonfederal entities’ implementation of emergency
                                       assistance programs, and developing appropriate corrective actions. 65

                                       Establish Monitoring Activities

                                       Program management should assess the internal control system through
                                       ongoing monitoring, which is built into the system and performed
                                       continually, and through separate evaluations, which are used periodically
                                       for a more in-depth analysis of the effectiveness of controls and ongoing
                                       monitoring efforts. 66 A risk-based approach to monitoring can allow
                                       managers to respond quickly to external factors that can influence the
                                       control environment. For example, changes in statutory requirements,
                                       new fraud schemes, or economic instability that accompany a natural
                                       disaster or national emergency can affect the extent to which controls are
                                       effective in addressing improper payment risks. Managers may need to
                                       modify specific control activities accordingly, based on monitoring results.

                                       Estimate Improper Payments

                                       Federal program managers should estimate a program’s annual improper
                                       payments. Estimating a program’s annual improper payments is an
                                       example of a separate evaluation that helps program managers—and the
                                       federal government—understand the scope of the problem and measure
                                       the effectiveness of internal controls in addressing improper payment
                                       risks. 67 Monitoring improper payments on a more frequent and recurring
                                       basis, such as by reviewing a sample of payments monthly or quarterly,
                                       can facilitate taking needed corrective actions on a more timely basis.

                                       Estimating improper payments is especially important for emergency
                                       assistance programs, where the risk of improper payments is higher.
                                       Agencies should ensure that the estimate’s methodology incorporates
                                       emergency-related risks, such as whether the program is new or received
                                       increased funding, whether there are time constraints for spending, and
                                       whether changes were made to existing program eligibility rules.




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Monitor the Effectiveness of Controls in Managing Improper Payments


                                                           Analyze the Root Cause

                                                           After estimating the improper payments, federal program managers
                                                           should analyze the root cause of the improper payments to help prevent
                                                           them from recurring. Understanding the root cause will help agencies
                                                           develop effective corresponding corrective actions. Identifying the root
                                                           cause is an iterative process that can include assessing possible causes
                                                           and prioritizing among them. According to OMB guidance, this process
                                                           involves asking “why did this occur?” multiple times until the deeper cause
                                                           is identified. 68 Table 2 is an example of a root cause analysis from OMB
                                                           guidance.

Table 2: Example of Improper Payment Root Cause Analysis
Improper payment                   Why did this occur?             Potential cause            Analysis           Root cause         Possible corrective
                                                                   category                                                         actions
A payment is improperly The agency has access Failure to access                               Why was the        Lack of training   Training on how to
issued to a deceased    to the data it needs to data/information                              data/information   or automation      review information
individual.             verify if an individual is                                            not accessed?      for checking       Automate the eligibility
                        deceased but did not                                                                     whether the        process to enable data
                        check that information                                                                   applicant is       access
                        prior to payment.                                                                        deceased

Source: GAO analysis of Office of Management and Budget Memorandum M-21-19 | GAO-23-105876.



                                                           Monitor Nonfederal Entities

                                                           Federal agencies have oversight responsibilities for the funds they award
                                                           to nonfederal entities. In emergency assistance programs, nonfederal
                                                           entities, such as tribal, state, territorial, and local governments, may be
                                                           responsible for implementing policies and procedures and making
                                                           payments, while federal program managers oversee and monitor these
                                                           nonfederal entities. Federal agencies may rely on nonfederal entities that
                                                           are providing the federal assistance to design and implement controls for
                                                           mitigating improper payments.

                                                           Where federal program managers oversee nonfederal entities, this
                                                           oversight can include evaluating the adequacy of the nonfederal entity’s
                                                           policies and procedures and other controls. For example, federal program
                                                           managers may conduct postpayment testing to validate payments and to
                                                           evaluate the nonfederal entity’s compliance with its control activities.
                                                           Without appropriate monitoring and evaluation of nonfederal entities,
                                                           federal agencies cannot have reasonable assurance that their nonfederal
                                                           counterparts are meeting program requirements or effectively managing
                                                           risks.




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Monitor the Effectiveness of Controls in Managing Improper Payments

                                       In programs where eligibility determinations are made by nonfederal
                                       entities, nonfederal program administrators may temporarily adjust some
                                       controls to ensure payments are not delayed. However, such adjustments
                                       usually require federal program managers to perform additional
                                       monitoring, as they can increase the risk of improper payments.

                                       For example, the Emergency Rental Assistance program made funding
                                       available to tribal, state, territorial, and local governments to provide
                                       rental assistance during the COVID-19 pandemic. Treasury allowed state
                                       and local program administrators to determine applicant eligibility
                                       through written attestations provided by the applicant (self-certification) if
                                       the applicant could not provide supporting documentation such as a pay
                                       stub to demonstrate income eligibility or a signed lease to demonstrate a
                                       rental obligation. Local auditors noted that the decision to rely on self-
                                       certification expedited application processing but also increased fraud
                                       risks. In February 2022, we recommended that Treasury develop and
                                       implement procedures to monitor and evaluate grantees’ controls,
                                       including providing information on the minimum internal controls
                                       expected for nonfederal entities that rely on self-attestation and other
                                       administrative flexibilities that could increase risks of improper
                                       payments. 69

                                       In addition, certain nonfederal entities are required to undergo a single
                                       audit if their expenditures of federal awards in a fiscal year exceed a
                                       certain threshold. 70 A single audit includes an audit of the recipient’s
                                       expenditure of federal funding and of its financial statements. It can
                                       identify deficiencies in the award recipient’s compliance with the
                                       provisions of laws, regulations, contracts, or grant agreements and in its
                                       financial management and internal controls. Correcting such deficiencies
                                       can help reasonably assure the effective use of federal funds and reduce
                                       improper payments.

                                       Develop Corrective Actions

                                       Effective monitoring can inform the development and implementation of
                                       corrective actions that address identified weaknesses in controls. If
                                       management performs monitoring activities, such as auditing a sample of
                                       disbursed emergency assistance payments, and finds an unacceptable
                                       level of improper payments and develops information on a root cause,
                                       these findings could inform future prepayment controls. 71

                                       For example, at the beginning of the pandemic, SBA relied on applicants
                                       to self-certify that they were eligible for PPP loans, including that they
                                       were not delinquent on any federal loans. When SBA’s Office of Inspector


A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                  Page 26
Monitor the Effectiveness of Controls in Managing Improper Payments

                                       General later reviewed these payments and corroborated the self-certified
                                       information against other data sources, it found that 57,500 PPP loans
                                       worth $3.6 billion had been issued to potentially ineligible recipients. As a
                                       result, for the third round of PPP distributions, SBA implemented the
                                       corrective action of using the Do Not Pay system to screen new PPP loan
                                       applications. 72

                                       Developing and implementing corrective action plans has been shown to
                                       reduce improper payments. Such plans involve determining the root
                                       causes of improper payments and developing solutions to address them,
                                       and each estimate of an executive agency program’s improper payments
                                       must be accompanied by a report on these plans. Between fiscal years
                                       2018 and 2021, several programs, including Medicare, reported that
                                       corrective action plans had contributed to a reduction in improper
                                       payments. In a study of eight federal programs, we found that the only
                                       one agency correctly adhered to statutory requirements and OMB
                                       guidance for corrective action plans—the Department of Veterans
                                       Affairs—and the estimated improper payment rate in its Prosthetic and
                                       Sensory Aids Service declined by 37.6 percent. 73




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5. Provide and Obtain Information to Manage
Improper Payments
                                       Providing information to and obtaining it from appropriate entities is
                                       necessary for emergency assistance programs to effectively manage
                                       improper payments. Practices that support this principle include providing
                                       clear, timely improper payment information to nonfederal entities and
                                       entities that perform oversight over emergency assistance programs.
                                       Federal managers of emergency assistance programs should also obtain
                                       and use information from nonfederal entities and from state and local
                                       auditors that oversee these entities.

                                       Provide Information to Nonfederal Entities

                                       To manage improper payments, federal managers of emergency
                                       assistance programs should provide timely and quality information to
                                       nonfederal entities, including guidance on program implementation,
                                       eligibility requirements, and appropriate use of funds. 74 We have
                                       previously reported that uncoordinated communication from federal
                                       agencies to state and local jurisdictions, and to providers and the general
                                       public, has caused confusion, frustration, and, in some cases, individuals’
                                       failure to seek or receive emergency assistance. 75

                                       For example, the CARES Act created the Coronavirus Relief Fund to
                                       provide $150 billion in financial assistance to tribal, state, territorial, and
                                       local governments to cover expenses incurred due to the COVID-19
                                       pandemic. The act contained stipulations on the use of funds and
                                       required Treasury to issue payments from the fund within 30 days of
                                       enactment. When Treasury disbursed the funds, it did not provide
                                       recipients with timely information on terms and conditions, including that
                                       the funds could only be used to cover costs incurred between March 21,
                                       2020, and December 30, 2020, among other requirements. 76 A state
                                       auditor we spoke to noted that state agencies that lacked experience as
                                       recipients of federal emergency assistance funds faced challenges with
                                       interpreting what costs were covered by the Coronavirus Relief Fund
                                       payments and required additional guidance on how to interpret the
                                       CARES Act statutory requirements.

                                       In response, Treasury issued three versions of guidance and eight versions
                                       of frequently asked questions; however, these updates caused confusion
                                       about the use of the payments. 77 Further, the Treasury Office of Inspector
                                       General found that, in some cases, the lack of comprehensive, timely
                                       guidance caused ineligible uses of Coronavirus Relief Fund payments.



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Provide and Obtain Information to Manage Improper Payments

                                       More timely information, such as guidance on eligible costs and
                                       definitions of key terms, might have helped recipients properly use funds.

                                       Provide Information to Oversight Entities

                                       Emergency assistance programs should also provide relevant, reliable, and
                                       timely information to external entities with oversight and monitoring
                                       responsibilities. These entities include Congress, federal inspectors
                                       general, and GAO. Programs should provide information to these entities
                                       to ensure that proper oversight of federal dollars is conducted during
                                       emergency circumstances.

                                       Congress needs relevant, reliable, and timely improper payment
                                       information to perform its oversight responsibilities, which can include
                                       using improper payment information for future policy-making decisions.
                                       In addition, Congress may use this information to request evaluation of
                                       these programs by GAO or federal inspectors general. GAO and federal
                                       inspectors general need and use this information to perform their
                                       missions. Specifically, these entities use this information to examine the
                                       use of public funds and evaluate emergency assistance programs and
                                       policies in order to help Congress make informed oversight, policy, and
                                       funding decisions.

                                       To ensure transparency and accountability of public funds, PIIA requires
                                       federal agencies to identify and review all programs and activities above a
                                       certain size that may be susceptible to significant improper payments.
                                       Federal agencies are also required to publish payment integrity
                                       information—including information on improper payments—in the
                                       materials accompanying their annual financial statements. In addition,
                                       PIIA requires federal inspectors general to publicly report on their
                                       determination of federal agencies’ compliance with six statutory criteria as
                                       part of their PIIA compliance reporting. 78 If an agency’s inspector general
                                       determines that the agency is not in compliance with the six criteria listed
                                       in PIIA, that agency must submit a plan to Congress describing the actions
                                       that it will take to come into compliance.

                                       For fiscal year 2021, agencies reported estimated improper payment rates
                                       of 10 percent or greater for 26 risk-susceptible programs and activities,
                                       which accounted for about 87 percent of the government-wide total of
                                       reported estimated improper payments. 79 For fiscal year 2022, agencies
                                       reported estimated improper payment rates of 10 percent or greater for
                                       17 risk-susceptible programs and activities, which accounted for about 59
                                       percent of the government-wide total of reported estimated improper
                                       payments. 80


A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                Page 29
Provide and Obtain Information to Manage Improper Payments


                                       Obtain and Use Information from Nonfederal Entities

                                       To manage improper payments, federal program managers of emergency
                                       assistance programs that are administered by nonfederal entities should
                                       obtain and use quality information from these entities. 81 Nonfederal
                                       entities may include those that are public in nature, such as state and local
                                       governments and public higher education institutions. They may also
                                       include private for-profit financial organizations, such as banks and
                                       depository institutions. Finally, nonfederal entities may include nonprofit
                                       organizations, such as community centers and food banks. Congress may
                                       design emergency assistance programs that require federal agencies to
                                       facilitate relief funding through these organizations.

                                       Emergency assistance programs that are administered by nonfederal
                                       government entities may benefit from oversight by state and local
                                       auditors. State and local auditors play a critical role in ensuring the
                                       accountability of nonfederal entities that receive federal emergency
                                       assistance. Federal program managers should ensure they obtain state
                                       and local auditor findings and recommendations and incorporate them
                                       into their risk assessment and monitoring activities. For example, local
                                       auditors identified deficiencies related to improper payments and controls
                                       for determining eligibility in a program administering Emergency Rental
                                       Assistance funds. 82 Specifically, the auditors noted that while the decision
                                       to rely on self-certification made it easier for those without formal
                                       documentation to qualify for awards, it also increased fraud risks. 83
                                       Federal program managers should incorporate such information from
                                       state and local auditors into their programs to reduce fraud risks and
                                       improper payments.




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Appendix I: Congressional Addressees



 The Honorable Patty Murray                                        The Honorable Cathy McMorris Rodgers
 Chair                                                             Chair
 The Honorable Susan Collins                                       The Honorable Frank Pallone, Jr.
 Vice Chair                                                        Ranking Member
 Committee on Appropriations                                       Committee on Energy and Commerce
 United States Senate                                              House of Representatives

 The Honorable Ron Wyden                                           The Honorable Mark E. Green, M.D.
 Chairman                                                          Chairman
 The Honorable Mike Crapo                                          The Honorable Bennie G. Thompson
 Ranking Member                                                    Ranking Member
 Committee on Finance                                              Committee on Homeland Security
 United States Senate                                              House of Representatives

 The Honorable Bernard Sanders                                     The Honorable James Comer
 Chair                                                             Chairman
 The Honorable Bill Cassidy                                        The Honorable Jamie Raskin
 Ranking Member                                                    Ranking Member
 Committee on Health, Education, Labor and Pensions                Committee on Oversight and Accountability
 United States Senate                                              House of Representatives

 The Honorable Gary C. Peters                                      The Honorable Jason Smith
 Chairman                                                          Chairman
 The Honorable Rand Paul, M.D.                                     The Honorable Richard Neal
 Ranking Member                                                    Ranking Member
 Committee on Homeland Security and Governmental Affairs           Committee on Ways and Means
 United States Senate                                              House of Representative

 The Honorable Kay Granger
 Chairwoman
 The Honorable Rosa L. DeLauro
 Ranking Member
 Committee on Appropriations
 House of Representatives




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Appendix II: Additional Sources to Use in
Managing Improper Payments

Table 3: Additional Sources to Use in Managing Improper Payments

Source                    Purpose                                      When/how to use in managing improper payments
Standards for Internal    The Federal Managers’ Financial              The Green Book provides managers criteria for designing,
Control in the Federal    Integrity Act of 1982, as amended,           implementing, and operating an effective internal control
Government (known as      requires the Comptroller General to          system, which is key to preventing and reducing improper
the Green Book)           issue standards for internal control in      payments. The Green Book defines the standards through
                          the federal government. Standards for        five components:
                          Internal Control in the Federal
                                                                         • Control environment
                          Government provides the overall
                          framework for establishing and                 • Risk assessment
                          maintaining an effective internal control      • Control activities
                          system.                                        • Information and communication
                                                                   • Monitoring
                          The Green Book may also be adopted by
                                                                The Green Book includes a discussion of how the five
                          state, local, and quasi-governmental
                                                                internal control components relate to an entity’s objectives;
                          entities, as well as nonprofit
                                                                how to evaluate the internal control system’s design,
                          organizations, as a framework for an
                                                                implementation, and operation; and the requirements for
                          internal control system.
                                                                each of the five components, including documentation
                                                                requirements.
                                                                       Managers determine, based on applicable laws and
                                                                       regulations, how to appropriately adapt the standards
                                                                       presented in the Green Book as a framework for the entity.

A Framework for         GAO’s Framework for Managing Fraud             The framework identifies and conceptualizes leading
Managing Fraud Risks in Risks in Federal Programs identifies           practices to aid program managers in managing fraud,
Federal Programs        leading practices for managing fraud           including fraud that results in improper payments. These
                        risks—an important subset of improper          practices relate to the following concepts:
                        payment risks—and organizes them into
                                                                         • Commit to combating fraud by creating an
                        a conceptual framework. The framework
                                                                           organizational culture and structure conducive to fraud
                        encompasses control activities to
                                                                           risk management
                        prevent, detect, and respond to fraud,
                        with an emphasis on prevention, as well          • Plan regular fraud risk assessments
                        as structures and environmental factors          • Design and implement a strategy with specific control
                        that influence or help managers achieve            activities to mitigate assessed fraud risks
                        their objective to mitigate fraud risks.         • Evaluate outcomes using a risk-based approach and
                                                                           adapt activities to improve fraud risk management
                          Effective fraud risk management helps
                          to ensure that federal programs’ services
                          fulfill their intended purposes, funds are
                          spent effectively, and assets are
                          safeguarded. The purpose of proactively
                          managing fraud risks is to facilitate, not
                          hinder, a program’s mission and
                          strategic goals.




A Framework for Managing Improper Payments in Emergency Assistance Programs | GAO-23-105876                                   Page 32
Payment Integrity              PIIA was intended to improve efforts to        This act establishes requirements for executive agencies to
Information Act of 2019        identify and reduce government-wide            help them manage improper payments, including the
(PIIA)                         improper payments.                             following:
                                                                                 • Estimating improper payments and reporting on
                                                                                   actions to reduce improper payments, including
                                                                                   identifying susceptible programs
                                                                                 • Establishing compliance requirements for inspectors
                                                                                   general of executive agencies
                                                                                 • Establishing the Do Not Pay initiative
                                                                                 • Improving recovery of improper payments, including
                                                                                   through setting targets for recovery
                                                                                 • Establishing and maintaining procedures for using data
                                                                                   to prevent and reduce improper payments
                                                                                 • Establishing financial and administrative controls
                                                                                   related to fraud and improper payments
                                                                              PIIA also continues the requirement that the Office of
                                                                              Management and Budget (OMB) establish guidelines for
                                                                              agencies that incorporate leading practices from A
                                                                              Framework for Managing Fraud Risks in Federal Programs—
                                                                              specifically, guidelines for agencies to establish financial and
                                                                              administrative controls to identify and assess fraud risks and
                                                                              design and implement control activities in order to prevent,
                                                                              detect, and respond to fraud.

Office of Management           OMB M-21-19 provides requirements          This guidance explains requirements related to improper
and Budget                     for assessing and reporting on executive payments, including providing instruction on the following:
Memorandum M-21-19,            agency internal controls.                    • Distinguishing among types of improper payments
Appendix C to OMB              The goal of this revised version of OMB      • Identifying susceptible programs using an improper
Circular A-123,                Circular A-123's Appendix C is to                payment risk assessment, including the structure and
Requirements for               transform the payment integrity                  frequency of the risk assessment
Payment Integrity              compliance framework and create a
Improvement                                                                 • Reporting improper payment estimates for susceptible
                               more comprehensive and meaningful
                                                                                programs, including suggested sampling and
                               set of requirements to allow agencies to
                                                                                estimation methodologies, frequency of reporting, and
                               spend less time complying with low-
                                                                                how to report
                               value activities and more time
                               researching the underlying causes of         • Identifying root causes of improper payments
                               improper payments, balancing payment         • Preventing improper payments, including identifying
                               integrity risks and controls, and building       improper payment risks, making corrective action
                               the capacity to help prevent future              plans, and using databases such as those available via
                               improper payments.                               the Do Not Pay working system
                                                                                 • Identifying and setting risk tolerance and improper
                                                                                   payment rate
                                                                                 • Identifying and recovering overpayments
                                                                                 • Inspector general requirements for determining agency
                                                                                   programs’ compliance with PIIA criteria, including
                                                                                   reporting requirements
Source: GAO-14-704G, GAO-15-593SP, 31 U.S.C. § 3351-3357, OMB M-21-19. | GAO-23-105876




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Appendix III: Endnotes


1GAO, Disaster Recovery: Actions Needed to Improve the Federal Approach, GAO-23-104956 (Washington, D.C.: Nov. 15, 2022) and

Disaster Resilience Framework: Principles for Analyzing Federal Efforts to Facilitate and Promote Resilience to Natural Disasters,
GAO-20-100SP (Washington, D.C.: Oct. 23, 2019).

231 U.S.C. § 3351(4). When an executive agency’s review is unable to discern whether a payment was proper as a result of insufficient

or lack of documentation, this payment must also be included in the improper payment estimate. 31 U.S.C. § 3352(c)(2).

3In 2003, federal executive agencies were required by law to begin reporting estimated improper payments for certain programs and

activities. An executive agency is a department, an agency, or an instrumentality in the executive branch of the U.S. government. 31
U.S.C. § 102. Prior year improper payment estimates have not been adjusted for inflation.

4The improper payment estimate reported for fiscal year 2021 does not reflect all government-wide improper payments. Notably,

several agencies with large programs that have been identified as susceptible to significant improper payments have not reported
estimates, and some reported estimates are not comprehensive. Further, with the exception of two Department of Labor (DOL)
unemployment insurance programs, the estimate does not include estimates related to the expenditures to fund response and recovery
efforts for the COVID-19 pandemic. For example, for fiscal year 2021, the Small Business Administration did not report improper
payment estimates for its Paycheck Protection Program (PPP), although it estimated $29 billion in improper payments for fiscal year
2022. Most of the fiscal year 2021 estimate was concentrated in the following areas: the Department of Health and Human Services’
(HHS) Medicaid ($99 billion); DOL’s unemployment insurance ($78 billion); and HHS’s Medicare, which comprises three programs:
Fee-For-Service, Part C, and Part D ($50 billion).

5GAO, Financial Audit: FY 2021 and FY 2022 Consolidated Financial Statements of the U.S. Government, GAO-23-105837

(Washington, D.C.: Feb. 16, 2023). Of 82 programs with reported estimates, 17 reported a rate over 10 percent. However, programs
that were identified by their agency as not susceptible to significant improper payments would not be included in this 82-program
population.

6GAO, Financial Audit: FY 2021 and FY 2020 Consolidated Financial Statements of the U.S. Government, GAO-22-105122

(Washington, D.C.: Feb. 17, 2022). Of 86 programs with reported estimates, 26 reported a rate over 10 percent. However, programs
that were identified by their agency as not susceptible to significant improper payments would not be included in this 86-program
population.

7
 GAO has an extensive body of work on improper payments that spans a number of years. Significantly, in March 2022 we
recommended 10 matters for congressional consideration to strengthen internal controls and financial and fraud risk management
practices across the government. We consider these actions to be important steps to more effectively manage improper payments. See
GAO, 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).

8Over this period, agencies’ estimated improper payment rates decreased in 19 of these programs, according to fiscal year 2022

reporting. These changes may be attributable to a number of factors, including agency corrective actions, changes in policies, and
variability (e.g., margin of error) in the process for estimating the payment rates. To identify the number of programs reporting improper
payment estimates, we analyzed paymentaccuracy.gov data from fiscal years 2017 through 2022. Programs had to have a comparable
improper payment estimation methodology from year to year. To determine if a program reported a change in estimation methodology,
we assessed any programs that had a change in either (1) the estimated improper payment amount greater than $100 million and the
estimated improper payment rate greater than 5 percent or (2) the estimated improper payment amount greater than $1 billion.
Paymentaccuracy.gov is a U.S. government website managed by the Office of Management and Budget (OMB) that includes
information about current and historical rates and amounts of estimated improper payments.

9Unemployment insurance programs provide temporary financial assistance to eligible workers who become unemployed through no

fault of their own.

10GAO, COVID-19: Opportunities to Improve Federal Response and Recovery Efforts, GAO-20-625 (Washington, D.C.: June 25, 2020).

A fourth unemployment insurance program was created by the Consolidated Appropriations Act, 2021 and extended by the American
Rescue Plan Act of 2021. See GAO, Unemployment Insurance: Transformation Needed to Address Program Design, Infrastructure,
and Integrity Risks, GAO-22-105162 (Washington, D.C.: June 7, 2022).




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11GAO-22-105715.


12Department of Labor, Office of Inspector General, Testimony Before the U.S. House of Representatives Committee on Ways and

Means, No. 1919-23-003-03-315 (Washington D.C. Feb. 8, 2023). With the exception of the Pandemic Unemployment Assistance
Program, for which claims could be backdated to January 27, 2020, the DOL Inspector General defined the unemployment period as
March 27, 2020, through September 6, 2021. The DOL Inspector General also noted that according to the Employment Training
Administration, it could not provide final total costs of the programs because states were still processing claims that were for weeks of
unemployment prior to expiration of the programs.

13GAO, COVID-19: Additional Actions Needed to Improve Accountability and Program Effectiveness of Federal Response, GAO-22-

105051 (Washington, D.C.: Oct. 27, 2021). DOL and the DOL Inspector General have also reported on the need for improving
management of the unemployment insurance system and program integrity, among other things.

14GAO, 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). SBA made or guaranteed these emergency loans and grants through its PPP and
Economic Injury Disaster Loans. As of March 27, 2022, lenders had made about 11.4 million PPP loans, totaling about $789 billion.

15This information is based on GAO analysis of improper payment estimate data from fiscal year 2022 as reported on

paymentaccuracy.gov. All references to the EIDL program in this report refer to the program administered in response to the COVID-19
pandemic unless otherwise noted.

16GAO-20-625 and GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its Second Year, GAO-21-387

(Washington, D.C.: Mar. 31, 2021).

17GAO, 2017 Disaster Relief Oversight: Strategy Needed to Ensure Agencies’ Internal Control Plans Provide Sufficient Information,

GAO-19-479 (Washington D.C.: June 28, 2019).

18OMB disagreed with our recommendation. OMB staff stated that OMB did not believe the sufficiency or timeliness of control plans

presented material issues that warranted OMB action. OMB staff also stated that agency management and not OMB has responsibility
for ensuring compliance with applicable laws and regulations. While agencies were responsible for submitting their internal
control plans, federal law places the responsibility of establishing the criteria for the internal control plans with OMB. Therefore, we
believe that our recommendation remains warranted.

19The White House, Memorandum on Authorizing the Other Needs Assistance Program for Major Disaster Declarations Related to

Coronavirus Disease 2019 (Aug. 8, 2020). This program was authorized under the Other Needs Assistance category of FEMA’s
Individual and Households program. According to 42 U.S.C. § 5174(a)(1), after a disaster, the President, in consultation with the state
governor, may provide financial assistance to cover necessary expenses and serious needs in cases where the individual or household
is not able to meet such expenses or needs through other means.

20Department of Homeland Security, Office of Inspector General, FEMA Did Not Implement Controls to Prevent More Than $3.7 Billion

in Improper Payments from the Lost Wages Assistance Program, OIG-22-69 (Washington, D.C.: Sept. 16, 2022). FEMA approved Lost
Wages Assistance grant applications totaling more than $37.3 billion in grant obligations for 49 states, four territories, and the District of
Columbia. South Dakota was the only state that did not apply for or participate in the Lost Wages Assistance program. The U.S.
territories that participated in the program were the Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands. As of
April 2022, $36.5 billion had been expended by the state workforce agencies.

21Department of Homeland Security, Office of Inspector General, OIG-22-69. These 21 state workforce agencies distributed more than

80 percent of the $36.5 billion of lost wages assistance—approximately $30 billion in total—and later detected $3.3 billion in potentially
fraudulent payments. In addition, they identified $21.6 million in overpayments and $403 million in payments made without obtaining
claimants’ required self-certifications of eligibility.

22Pub. L. No. 116-136, § 19010, 134 Stat. 281, at 579-81 (2020). See app. I for the list of congressional addressees for this work.


23Pub. L. No. 116-117, 134 Stat. 113 (2020) (codified at 31 U.S.C. §§ 3351-3358); OMB Circular A-123, Appendix C, Requirements for

Payment Integrity Improvement (OMB M-21-19); GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept. 10, 2014); and GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 28, 2015).

24These entities are the National Association of State Comptrollers, Auditors and Treasurers; the American Institute for Certified Public

Accountants; the Association of Government Accountants; and the Association of Local Government Auditors.




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25The five components of internal control (Control Environment, Risk Assessment, Control Activities, Information and Communication,

and Monitoring) must be effectively designed, implemented, and operating together in an integrated manner for an internal control
system to be effective.

26In March 2022, we recommended that Congress consider requiring OMB to provide guidance for agencies to develop internal control

plans that would then be ready for use in, or adaptation for, future emergencies or crises and requiring agencies to report these plans to
OMB and Congress. See GAO-22-105715.

27OMB, in coordination with Treasury, developed the Do Not Pay initiative as a web-based, centralized data-matching service for

federal agencies to use in preventing and detecting improper payments. The Do Not Pay working system allows agencies to review
multiple databases before making payments. Although PIIA established the requirement that all executive agencies use Do Not Pay
prior to issuing payments, officials from Treasury’s Bureau of the Fiscal Service told us that not all agencies are in compliance. As of
May 2022, the Bureau of the Fiscal Service was working with 47 federal agencies and 286 federally funded programs. Bureau officials
stated that they conduct significant outreach to increase awareness of the initiative and to bring more agencies into compliance with
PIIA. In 2013, OMB also issued guidance to help agencies protect privacy while reducing improper payments with the Do Not Pay
system. Office of Management and Budget, Protecting Privacy While Reducing Improper Payments with the Do Not Pay Initiative, OMB
Memorandum M-13-20 (Washington, D.C.: Aug. 16, 2013).

28Small Business Administration, Office of Inspector General, Inspection of SBA’s Implementation of the Paycheck Protection Program,

21-07 (Washington D.C.: Jan. 14, 2021).

29Department of Labor, Office of Inspector General, COVID-19: States Struggled to Implement Cares Act Unemployment Insurance

Programs, 19-21-004-03-315 (Washington D.C.: May 28, 2021).

30Individuals who filed a new Pandemic Unemployment Assistance claim on or after January 31, 2021, were required to provide

documentation of employment or self-employment within 21 days of application, or following the state deadline if later (with exceptions
for good cause). Individuals who received Pandemic Unemployment Assistance on or after December 27, 2020, were required to
provide this documentation within 90 days, or within the state deadline if later (with exceptions for good cause). For Pandemic
Unemployment Assistance claims filed on or after January 26, 2021, states were required to use administrative procedures to verify the
identity of Pandemic Unemployment Assistance applicants and provide timely payment, to the extent reasonable and practicable. The
Continued Assistance Act included a new statutory requirement for weekly self-certification by claimants of a COVID-19-related
condition for weeks on or after January 26, 2021. For more information, see also GAO-22-105051.

31Joint Financial Improvement Program, Key Practices to Reduce Improper Payments through Identity Verification (Washington, D.C.:

July 2022).

325 U.S.C. § 552a(o); see also OMB Memorandum M-21-19 and Joint Financial Improvement Program, Key Practices. Federal

executive agencies generally may enter into Computer Matching Agreements with other agencies for ongoing data matching that
assists in the detection and prevention of improper payments. These agreements are limited to 18 months followed by a renewal period
and must contain certain information, such as a description of the records that will be matched.

335 U.S.C. § 552a(b). For example, data sharing between federal agencies may be allowed if it is for a purpose that is compatible with

the purpose for which the data were collected, referred to as routine use. 5 USC 552a(b)(3),(a)(7). While increased data sharing can
help identify and reduce improper payments, identity verification involves individuals’ personal information, such as mailing address,
date of birth, and Social Security number, which can create privacy risks. According to the National Institute of Standards and
Technology (NIST), organizations could potentially mitigate these risks by assessing the risk associated with online transactions and
selecting the appropriate assurance level for each. A low assurance level reduces the amount of personal information that organization
must collect, but increases the risk of improper payments. On the other hand, a high assurance level may increase the burden on
applicants, including those who are not misrepresenting their identities. NIST develops information-security standards and guidelines,
including the minimum requirements for federal information systems. Joint Financial Improvement Program, Key Practices.

34
  GAO-20-625. For the economic impact payments made during the pandemic, starting with the fourth batch of payments, the SSA
death records were used by Treasury’s Bureau of the Fiscal Service to identify deceased individuals. This occurred after Treasury and
IRS, in consultation with counsel, determined that such individuals were not entitled to receive the payment.

35Pandemic Response Accountability Committee, Fraud Alert: PRAC Identifies $5.4 Billion in Potentially Fraudulent Pandemic Loans

Obtained Using over 69,000 Questionable Social Security Numbers (Jan. 30, 2023).

36For more information, see GAO, High Risk Series: Dedicated Leadership Needed to Address Limited Progress in Most High-Risk

Areas, GAO-21-119SP (Washington, D.C.: Mar. 2, 2021). Due to Medicare’s size, complexity, and susceptibility to improper payments,
GAO first designated it as a high-risk program in 1990.

37GAO-21-119SP.



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38GAO-15-593SP.


39GAO, Identity Theft: IRS Needs to Strengthen Taxpayer Authentication Efforts, GAO-18-418 (Washington D.C.: June 22, 2018).


40GAO made 11 recommendations. Of those, IRS had addressed 10 by September 2022; it had partially addressed the remaining

recommendation as of January 2023.

41GAO-20-625; Small Business Administration, Office of Inspector General, Inspection of Small Business Administration’s Initial

Disaster Assistance Response to the Coronavirus Pandemic, 21-02 (Oct. 28, 2020); and Department of Labor, Office of Inspector
General, Alert Memorandum: The Pandemic Unemployment Assistance Program Needs Proactive Measures to Detect and Prevent
Improper Payments and Fraud, 19-20-002-03-315 (May 26, 2020).

42Pandemic Response Accountability Committee, Lessons Learned in Oversight of Pandemic Relief Funds Updated (Washington D.C.:

June 8, 2022).

43Federal program managers are responsible for identifying, assessing, and responding to risks (including the potential for fraud) while

a program seeks to achieve its objectives. According to Standards for Internal Control in the Federal Government, a risk assessment is
the identification and analysis of risks related to achieving the defined objectives, and the assessment forms the basis for designing risk
responses. When conducting a risk assessment, managers should consider internal risk factors, such as the complex nature of the
program, and external factors, such as potential natural disasters. To focus managers’ attention on the need to take a more strategic,
risk-based approach to managing fraud risks, managers are required to consider the potential for fraud and fraud risks as part of their
risk assessment activities. GAO’s Framework for Managing Fraud Risks in Federal Programs provides comprehensive guidance for
conducting these assessments and using the results as part of the development of a robust antifraud strategy. Additionally, some
programs may be statutorily required to do other types of risk assessments, such as an improper payment risk assessment. OMB
Memorandum M-21-19 provides additional guidance to agencies on conducting the improper payment risk assessment.

44A state auditor told us that the COVID-19 pandemic created unique personnel challenges that affected distribution of funds. For

example, staff had to work from home, and in certain situations they did not have the proper equipment to do so. The auditor noted that
only eight of the 54 staff within the office owned a laptop to be able to conduct work remotely.

45GAO-20-625 and Pandemic Response Accountability Committee, Lessons Learned.


46Pandemic Response Accountability Committee, Lessons Learned, and Small Business Administration, Office of Inspector General,

21-02.

47OMB Memorandum M-21-19 and GAO-14-704G. According to federal internal control standards, program managers should define

their risk tolerances and consider them in the context of the applicable laws, regulations, and standards as well as the agency’s
standards of conduct, oversight structure, organizational structure, and expectations of competence. An internal control system is a
continuous built-in component of operations, effected by people, that provides reasonable assurance, not absolute assurance, that an
entity’s objectives will be achieved.

48By statute, agencies must conduct improper payment risk assessments at least once every 3 years for all programs with annual

outlays of more than $10 million. PIIA defines “significant” improper payments as improper payments in the preceding fiscal year that
may have exceeded either (1) 1.5 percent of program outlays and $10 million or (2) $100 million (regardless of the improper payment
rate). 31 U.S.C. § 3352(a).

49OMB Memorandum M-21-19.


50After the first improper payment risk assessment is conducted, agencies can adjust the time frame so future assessments are aligned

or staggered with other agency programs on a 3-year improper payment risk assessment cycle. OMB Memorandum M-21-19.

51GAO-21-191.


5231 U.S.C. § 3352. OMB designates programs with estimated improper payments resulting in a monetary loss greater than or equal to

$100 million as high-priority programs, which are subject to requirements in addition to those for programs deemed susceptible to
improper payments. See OMB Memorandum M-21-19.

53GAO-14-704G. According to federal internal control standards, management should consider the potential for fraud when identifying,

analyzing, and responding to risks.

54
 The CARES Act created the Pandemic Unemployment Assistance program and initially allowed applicants to self-certify their eligibility
and did not require them to provide any documentation of self-employment or prior income. The Consolidated Appropriations Act of

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2021 included a requirement for individuals to submit documentation of employment or self-employment when applying for the
Pandemic Unemployment Assistance program. See GAO-22-105051.

55The National Association of State Workforce Agencies’ Integrity Data Hub provides states a secure and centralized platform to assist

in detecting and preventing fraud, identity theft, and improper payments in the unemployment insurance program. The platform brings
state workforce agencies together to compare and analyze claims data for enhanced detection and prevention of fraud and improper
payments. Specifically, states can submit unemployment insurance claims data to the data hub, which then cross-matches these data
with a variety of datasets to determine if a claim has suspicious attributes that may indicate fraud or identity theft before the agency
issues payment. As we previously reported, according to DOL Inspector General officials, some state IT systems may not have been
easily compatible with the Integrity Data Hub. See GAO-22-105162.

56GAO-21-387; Small Business Administration, Office of Inspector General, Follow-Up Inspection of SBA’s Internal Controls to Prevent

COVID-19 EIDLs to Ineligible Applicants, 22-22 (Washington D.C.: Sept. 29, 2022); and Pandemic Response Accountability
Committee, Lessons Learned.

57Of the 109 provider payment requests that the HHS Office of Inspector General included in its audit, 100 were correctly paid, six were

incorrectly approved but CMS identified the error before the payment was made, and in three of the cases, CMS identified the errors
immediately after the payments were made and recovered the improper payments. Department of Health and Human Services, Office
of Inspector General, Payments Made to Providers Under the COVID-19 Accelerated and Advance Payments Program Were Generally
in Compliance with the CARES Act and Other Federal Requirements (Washington, D.C.: October 2022).

58Department of Labor, Office of Inspector General, 19-20-002-03-315. In addition, the DOL Inspector General recommended that the

department seek additional guidance or clarification from Congress concerning whether a claimant is entitled to establish and continue
to receive Pandemic Unemployment Assistance payments without providing documentation. The department agreed to consult with
Congress and provide technical assistance if Congress wished to amend the self-certification provision within the Pandemic
Unemployment Assistance program to require submission of documentation to substantiate an individual’s previous employment. The
DOL Inspector General closed this recommendation on April 28, 2021, based on actions taken by Congress when it created
documentation requirements for Pandemic Unemployment Assistance claimants in the Continued Assistance to Unemployed Workers
Act of 2020.

59For more information, see GAO-15-593SP.


60The Integrity Data Hub allows state workforce agencies to perform various cross-matches of data, such as identifying claims filed

using deceased persons’ and federal inmates’ Social Security numbers. Department of Labor, Office of Inspector General, Alert
Memorandum: The Employment and Training Administration Needs to Ensure State Workforce Agencies Implement Effective
Unemployment Insurance Program Fraud Controls for High Risk Areas, 19-21-002-03-315 (Washington D.C.: Feb. 22, 2021).

61Department of Labor, Office of Inspector General, 19-21-002-03-315.


62Postpayment reviews and improper payment recovery audits are financial management practices that agencies can use to determine

whether payments were made appropriately to eligible recipients in correct amounts and used by recipients in accordance with law and
applicable agreements. “Pay and chase” refers to the practice of detecting improper payments after payments have been made and
attempting to recover funds.

63Department of Health and Human Services, Office of Inspector General, HHS’s and HRSA’s Controls Related to Selected Provider

Relief Fund Program Requirements Could Be Improved (Washington, D.C.: September 2022). In October 2021, we recommended that
the Health Resources and Services Administration (HRSA), within HHS, establish time frames for completing postpayment reviews and
finalize and implement procedures for postpayment recovery of any Provider Relief Fund improper payments. GAO-22-105051.

64GAO-15-593SP.


65According to federal internal control standards, program managers should (1) monitor the effectiveness of internal controls (including

internal controls to mitigate improper payments and fraud risk) and evaluate the results and (2) remediate identified internal control
deficiencies on a timely basis.

66GAO-14-704G.


67Under certain circumstances, executive agencies are statutorily required to produce an annual estimate of a program’s improper

payments, i.e., if the program has been determined through the improper payment risk assessment to be susceptible to significant
improper payments, or otherwise as required by law. 31 U.S.C. § 3352(c)(1) and OMB Memorandum M-21-19. While improper
payments could suggest that a program may be vulnerable to fraud, improper payment estimates are not valid indicators of the extent
of fraud in a particular program.

68OMB Memorandum M-21-19.


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69GAO, Emergency Rental Assistance: Additional Grantee Monitoring Needed to Manage Known Risks, GAO-22-105490 (Washington

D.C.: Feb. 10, 2022). Treasury did not agree or disagree with our recommendation. Treasury stated it planned to update its compliance
testing procedures to include information on control systems expected for grantees that rely on administrative flexibilities, which
generally aligned with our recommendation.

70Pub. L. No. 98-502, 98 Stat. 2327 (1984) (codified, as amended, at 31 U.S.C. §§ 7501-7506). States, local governments, and

nonprofit organizations that expend $750,000 or more in federal awards in a fiscal year are required to undergo a single audit or, in
limited circumstances, a program-specific audit.

71One step that can help support improved audits would be to have a more complete Compliance Supplement, which is issued annually

by OMB and provides guidance to auditors performing single audits of nonfederal entities that receive funding from federal assistance
programs. OMB requires federal awarding agencies to provide annual updates to agency program information before publishing the
supplement each year, including adding additional requirements as a result of changes in statutory or regulatory requirements, such as
those in the COVID-19 relief laws. The agency-specific information included in the supplement can support an auditor’s determination
of whether the recipient has complied with federal statutes, regulations, and award terms. Without the supplement, auditors would need
to research many statutes and regulations for each program under audit to identify compliance requirements that could have a direct
and material effect on that program. In April 2022, we recommended that the Departments of Education, Health and Human Services,
and the Treasury document their policies and procedures for providing information to OMB to better enable OMB to annually update the
Compliance Supplement. Establishing written policies and procedures could help expedite OMB’s final issuance of the supplement,
ensure that concerns can be resolved prior to issuance, and strengthen the quality of single audit guidance. As of January 2023, these
recommendations had not been implemented.

72Pandemic Response Accountability Committee, Lessons Learned; Small Business Administration, Office of Inspector General,

Paycheck Protection Program Loan Recipients on the Department of Treasury’s Do Not Pay List, 21-06 (Washington D.C. Jan. 11,
2021).

73GAO, Payment Integrity: Selected Agencies Should Improve Efforts to Evaluate Effectiveness of Corrective Actions to Reduce

Improper Payments, GAO-20-336 (Washington, D.C.: Apr. 1, 2020).

74According to federal internal control standards, management should externally communicate the necessary quality information to

achieve the entity’s objectives. GAO-14-704G.

75GAO, Influenza Pandemic: Lessons from the H1N1 Pandemic Should Be Incorporated into Future Planning, GAO-11-632

(Washington, D.C.: June 27, 2011).

76The CARES Act also stipulated that Coronavirus Relief Fund recipients only use the funds for costs that (1) were necessary

expenditures incurred due to the public health emergency with respect to COVID-19 and (2) were not accounted for in the budget most
recently approved as of March 27, 2020.

77Department of the Treasury, Office of Inspector General, American Rescue Plan—Application of Lessons Learned from the

Coronavirus Relief Fund, OIG-CA-21-020 (Washington D.C.: May 17, 2021).

78
  PIIA requires offices of inspector general to report on executive agency compliance with six statutory criteria: (1) publishing payment
integrity information with the annual financial statement and posting the annual financial statement and any accompanying materials as
required under OMB guidance on the agency website; (2) conducting improper payment risk assessments for any program or activity
with annual outlays greater than $10 million at least once every 3 years to identify each program or activity that may be susceptible to
significant improper payments; (3) if required, publishing improper payment estimates for each such identified susceptible program or
activity in the accompanying materials to the annual financial statement; (4) publishing a corrective action plan for each such identified
susceptible program or activity in the accompanying materials to the annual financial statement; (5) publishing an improper payment
reduction target for each such susceptible program and activity in the accompanying materials to the annual financial statement and
demonstrating improvements and developing a plan to meet the reduction target; and (6) reporting an improper payment estimated rate
of less than 10 percent for each program and activity for which an estimate was published in the accompanying materials to the annual
financial statement. OMB Memorandum M-21-19 expands these six criteria into 10 by breaking down some criteria into subcomponents
and, in some cases, adding new elements.

79GAO-22-105122.


80GAO-23-105837.


81According to federal internal control standards, management should use quality information to achieve the entity’s objectives. GAO-

14-704G.


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82GAO-22-105490. Section 501 of Division N of the Consolidated Appropriations Act, 2021 appropriated $25 billion for the delivery of

emergency rental assistance to eligible households suffering unemployment or other financial hardship due to the novel coronavirus
pandemic. Treasury allocated these funds to states, the District of Columbia, U.S. territories, Indian Tribes, tribally designated housing
entities, the Department of Hawaiian Homelands, and units of local government. Congress later appropriated an additional
$21,550,000,000 for emergency rental assistance under the American Rescue Plan Act of 2021.

83Office of the Inspector General, Montgomery County, Maryland, COVID-19 Rental Assistance Programs (Rockville, Md.: Oct. 8,

2021).




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Appendix IV: GAO Contact and Staff Acknowledgments



GAO Contacts
For more information on fraud risk, contact Johana Ayers at (202) 512-6722 or ayersj@gao.gov.
For more information on improper payment risk, contact Beryl Davis at (202) 512-2623 or davisbh@gao.gov.


Staff Acknowledgments
In addition to the contacts named above, Dan Garcia-Diaz (Managing Director), Alicia Puente Cackley
(Director), Andrew Pauline (Assistant Director), Brandon Jones (Analyst-in-Charge), and Sarah Garcia
(Analyst-in-Charge) made key contributions to this publication. Also contributing to this publication were
Stephanie Adams, Robert Dacey, Jason Kirwan, Jill Lacey, Diana Lee, Kun-Fang Lee, Maria McMullen, Marc
Molino, Jessica Sandler, Jennifer Schwartz, Rebecca Shea, and Matthew Valenta.




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GAO’s Mission
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