GAO-23-106285: Improper Payments: Fiscal Year 2022 Estimates and Opportunities for Improvement
Summary
GAO report GAO-23-106285, "Improper Payments: Fiscal Year 2022 Estimates and Opportunities for Improvement," a report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives, dated March 2023. It states that for fiscal year 2022, 18 agencies reported an estimated $247 billion in improper payments across 82 programs, with about $194 billion from Medicaid ($81 billion), Medicare ($47 billion), the Paycheck Protection Program ($29 billion), Unemployment Insurance ($19 billion) and the Earned Income Tax Credit ($18 billion). The total excludes estimates for programs such as Pandemic Unemployment Assistance and the Supplemental Nutrition Assistance Program. Agencies reported an estimated $200 billion of the total as overpayments, and cumulative estimates since fiscal year 2003 total almost $2.4 trillion.
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United States Government Accountability Office
Report to the Subcommittee on
Legislative Branch, Committee on
Appropriations, House of
Representatives
IMPROPER
March 2023
PAYMENTS
Fiscal Year 2022
Estimates and
Opportunities for
Improvement
GAO-23-106285
March 2023
IMPROPER PAYMENTS
Fiscal Year 2022 Estimates and Opportunities for
Improvement
Highlights of GAO-23-106285, a report to the
Subcommittee on Legislative Branch,
Committee on Appropriations, House of
Representatives
Why GAO Did This Study What GAO Found
Improper payments—payments that For fiscal year 2022, 18 agencies reported an estimated $247 billion in improper
should not have been made or that payments across 82 programs. Approximately 78 percent of this total (about
were made in incorrect amounts— $194 billion) was reported by five program areas: (1) Medicaid ($81 billion), (2)
continue to be an area of fiscal Medicare ($47 billion), (3) the Paycheck Protection Program ($29 billion), (4)
concern in the federal government. Unemployment Insurance ($19 billion), and (5) Earned Income Tax Credit ($18
Since fiscal year 2003, cumulative billion). However, the $247 billion total does not include estimates for certain risk-
executive agency improper payment susceptible programs, such as the Department of Labor’s Pandemic
estimates have totaled almost $2.4 Unemployment Assistance program and the Department of Agriculture’s
trillion.
Supplemental Nutrition Assistance Program.
House Report 117-389, which
accompanied the Legislative Branch Programs with the Largest Percentage of Total Reported Government-Wide Estimates of
Improper Payments for Fiscal Year 2022
Appropriations Act, 2023, included a
provision for GAO to provide quarterly
reports on its ongoing oversight of
improper payments.
Among other things, this report
summarizes federal agencies’ reported
improper payment estimates for fiscal
year 2022, as well as reported root
causes, corrective actions, and
reasons for substantial year-over-year
changes, and GAO’s open priority
recommendations and matters for
congressional consideration related to
reducing improper payments.
GAO summarized (1) improper
payment estimates and high-priority
program scorecards on
PaymentAccuracy.gov, as well as Agencies reported that an estimated $200 billion (over 80 percent) of the $247
agency financial reports, and (2) open billion total was the result of overpayments. Agencies also identified several
GAO priority recommendations and mitigating strategies to address the root causes of improper payments, such as
matters for Congress. providing training, changing processes, and proposing statutory changes.
Twelve agencies reported estimated improper payments each fiscal year for 35
programs since fiscal year 2017 using a consistent methodology. Over this
period, agencies’ estimated improper payment rates have 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, or variability from the estimation process (e.g., margin of error).
GAO has made numerous recommendations to agencies and provided
suggestions to Congress to help reduce improper payments. While some steps
have been taken in response, more action is needed. Eight agencies that
reported improper payment estimates for fiscal year 2022 had open
(unaddressed) GAO priority recommendations related to improper payments. As
View GAO-23-106285. For more information,
contact M. Hannah Padilla at (202) 512-5683
of February 2023, 37 of the 53 such recommendations remained open. In
or padillah@gao.gov. addition, there are 20 open GAO matters for congressional consideration to
improve federal financial management.
United States Government Accountability Office
Contents
Letter 1
Background 4
Agencies’ Improper Payment Estimates Totaled $247 Billion for
Fiscal Year 2022, and Reported Causes, Mitigation Strategies,
and Recovery Activities Varied 7
IGs Reported Fewer Than Half of CFO Act Agencies as Compliant
with PIIA and Related OMB Criteria for Fiscal Year 2021 20
Recent Matters for Congressional Consideration and Priority
Recommendations Have Identified Opportunities to Reduce
Improper Payments 27
Agency Comments 29
Appendix I Excerpt from an Example of an Agency’s High-Priority Program
Scorecard 31
Appendix II Reported Estimated Improper Payments and Rates by Agency and
Program for Fiscal Year 2022 32
Appendix III High-Priority Programs’ Estimated Overpayments Reported for
Fiscal Years 2022 and 2021 36
Appendix IV CFO Act Agencies’ Reported Estimated Monetary-Loss Improper
Payments and Related Recovery Activities for Fiscal Year 2022 38
Appendix V Matters for Congressional Consideration to Improve Improper
Payment Reporting 40
Appendix VI Matters for Congressional Consideration to Improve Federal
Financial Management and Reduce Improper Payments 42
Page i GAO-23-106285 Improper Payments
Appendix VII Open Priority Recommendations for Agencies That Reported
Improper Payment Estimates for Fiscal Year 2022 44
Appendix VIII GAO Contact and Staff Acknowledgments 48
Tables
Table 1: Programs Reporting Annual Estimated Improper
Payment Rates Greater Than 10 Percent for Fiscal Year
2022 11
Table 2: Decreases in Improper Payment Rates for 19 Programs
since Fiscal Year 2017 12
Table 3: Detailed Root Cause Information for Programs with the
Largest Improper Payment Estimates for Fiscal Year 2022 16
Table 4: Agency Reported Root Cause Categories for Estimated
Overpayments, Fiscal Year 2022 17
Table 5: High-Priority Program Mitigation Strategies for Monetary-
Loss Improper Payments Reported for Fiscal Year 2021 18
Table 6: Reported Estimated Improper Payments and Rates by
Agency and Program for Fiscal Year 2022 32
Table 7: High-Priority Programs’ Estimated Overpayments, Fiscal
Years 2022 and 2021 36
Table 8: Recovery Activities for Chief Financial Officers Act
Agencies That Reported Estimated Monetary-Loss
Improper Payments for Fiscal Year 2022 38
Table 9: Open Matters for Congressional Consideration Related to
COVID-19 and Improper Payments 40
Table 10: Open Improper Payment Priority Recommendations to
Agencies That Reported Improper Payment Estimates for
Fiscal Year 2022 44
Figures
Figure 1: Programs with the Largest Percentage of Total Reported
Government-Wide Estimates of Improper Payments for
Fiscal Year 2022 9
Figure 2: Breakdown of Agencies’ Fiscal Year 2022 Reported
Estimated Improper Payments by Type 9
Page ii GAO-23-106285 Improper Payments
Figure 3: CFO Act Agencies’ Compliance with PIIA or IPERA
Criteria for Fiscal Years 2016 through 2021, as Reported
by Their IGs 20
Figure 4: Chief Financial Officers Act of 1990 Agencies’
Compliance with Payment Integrity Information Act of
2019 and Related Office of Management and Budget
Criteria for Fiscal Year 2021, as Reported by Their IGs 23
Figure 5: Office of Management and Budget (OMB) Annual
Improper Payment Estimates Data Call Timeline 25
Figure 6: Excerpt from an Example of an Agency’s High-Priority
Program Scorecard 31
Abbreviations
AFR agency financial report
CCC Commodity Credit Corporation
CFO chief financial officer
CFO Act Chief Financial Officers Act of 1990
CMS Centers for Medicare & Medicaid Services
CNCS Corporation for National and Community Service
CPI Center for Program Integrity
DNP Do Not Pay
DOD Department of Defense
EITC Earned Income Tax Credit
EPA Environmental Protection Agency
FAR Federal Acquisition Regulation
FCC Federal Communications Commission
FEMA Federal Emergency Management Agency
Page iii GAO-23-106285 Improper Payments
FNS Food and Nutrition Service
FSA Farm Service Agency
HHS Department of Health and Human Services
HUD Department of Housing and Urban Development
IG inspector general
IPERA Improper Payments Elimination and Recovery Act of 2010
IRS Internal Revenue Service
NASA National Aeronautics and Space Administration
OIG Office of Inspector General
OMB Office of Management and Budget
OPM Office of Personnel Management
PAR performance and accountability report
PIIA Payment Integrity Information Act of 2019
PLTSS Purchased Long Term Services and Support
PPP Paycheck Protection Program
SBA Small Business Administration
SSA Social Security Administration
UI Unemployment Insurance
USAID U.S. Agency for International Development
USCG United States Coast Guard
USDA Department of Agriculture
USF Universal Service Fund
VA Department of Veterans Affairs
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Page iv GAO-23-106285 Improper Payments
Letter
441 G St. N.W.
Washington, DC 20548
March 29, 2023
The Honorable Mark E. Amodei
Chairman
The Honorable Adriano Espaillat
Ranking Member
Subcommittee on Legislative Branch
Committee on Appropriations
House of Representatives
Reducing improper payments is critical to safeguarding federal funds.
Improper payments—payments that should not have been made or were
made in the incorrect amount—have consistently been a government-
wide issue. 1 Since fiscal year 2003, when federal executive agencies
were required by law to begin reporting estimated improper payments for
certain programs and activities, cumulative estimates have totaled about
$2.4 trillion, including $247 billion for fiscal year 2022. 2
We have identified improper payments as a material deficiency or
material weakness in internal control in our audit reports on the U.S.
government’s consolidated financial statements since fiscal year 1997. 3
Specifically, we note that the federal government is unable to determine
the full extent to which improper payments occur or to reasonably assure
that appropriate actions are taken to reduce them.
1An improper payment is defined by law as any payment that should not have been made
or that was made in an incorrect amount (including overpayments and underpayments)
under statutory, contractual, administrative, or other legally applicable requirements. It
includes any payment to an ineligible recipient, any payment for an ineligible good or
service, any duplicate payment, any payment for a good or service not received (except
for such payments where authorized by law), and any payment that does not account for
credit for applicable discounts. 31 U.S.C. § 3351(4).
2Prior-year improper payment estimates have not been adjusted for inflation.
3Our most recent report was issued in February 2023. GAO, Financial Audit: FY 2022 and
FY 2021 Consolidated Financial Statements of the U.S. Government, GAO-23-105837
(Washington, D.C.: Feb. 16, 2023). A material weakness is a deficiency, or combination of
deficiencies, in internal control over financial reporting, such that there is a reasonable
possibility that a material misstatement of the entity’s financial statements will not be
prevented, or detected and corrected, on a timely basis. A deficiency in internal control
exists when the design or operation of a control does not allow management or
employees, in the normal course of performing their assigned functions, to prevent, or
detect and correct, misstatements on a timely basis.
Page 1 GAO-23-106285 Improper Payments
The Payment Integrity Information Act of 2019 (PIIA) 4 requires federal
agencies’ inspectors general (IG) to annually determine and report on
whether the agencies under their jurisdiction have complied with specified
criteria—including reporting improper payment estimates for certain
programs. 5 IGs’ annual PIIA compliance reports help ensure that
agencies’ improper payment estimates are accurate, reliable, and
complete and that Congress has information on agencies’ efforts to
address improper payments. We previously reported on agencies’
compliance under the Improper Payments Elimination and Recovery Act
of 2010 (IPERA) for fiscal years 2011 through 2017, as reported by the
agencies’ IGs. 6
House Report 117-389, accompanying the Legislative Branch
Appropriations Act, 2023, includes a provision for GAO to report quarterly,
through fiscal year 2025, on our ongoing oversight of improper payments
and recommendations for legislative or technical opportunities to improve
payment integrity. This report summarizes (1) federal agencies’ reported
improper payment estimates for fiscal year 2022, root causes, corrective
actions, and reasons for substantial year-over-year changes; (2) agency
IGs’ determinations on the extent to which Chief Financial Officers Act of
1990 (CFO Act) agencies complied with PIIA and the Office of
Management and Budget’s (OMB) criteria for fiscal year 2021; 7 and (3)
4Pub. L. No. 116-117, 134 Stat. 113 (2020) (codified at 31 U.S.C. §§ 3351-58).
531 U.S.C. § 3353.
6GAO, Improper Payments: CFO Act Agencies Need to Improve Efforts to Address
Compliance Issues, GAO-16-554 (Washington, D.C.: June 30, 2016); Improper Payments:
Additional Guidance Could Provide More Consistent Compliance Determinations and
Reporting by Inspectors General, GAO-17-484 (Washington, D.C.: May 31, 2017); and
Improper Payments: Additional Guidance Needed to Improve Oversight of Agencies with
Noncompliant Programs, GAO-19-14 (Washington, D.C.: Dec. 7, 2018). IPERA (Pub. L.
No. 111-204, 124 Stat. 2224) established a requirement for agency IGs to report annually
on their respective agencies’ compliance with criteria listed in section 3 of IPERA. In
March 2020, Congress and the President enacted PIIA, which repealed IPERA and the
other improper payments reporting–related statutes and enacted substantially similar
provisions, including those related to IGs’ reporting on agency compliance with criteria and
the compliance criteria themselves.
7The CFO Act, Pub. L. No. 101-576, 104 Stat. 2838 (Nov. 15, 1990) (codified as amended
in scattered sections of 31 U.S.C.), among other things, established chief financial officers
to oversee financial management activities at 23 major executive departments and
agencies. The list now includes 24 entities, which are often referred to collectively as CFO
Act agencies, and is codified as amended at 31 U.S.C. § 901(b).
Page 2 GAO-23-106285 Improper Payments
our open priority recommendations and matters for congressional
consideration related to reducing improper payments.
To address our first objective, we compiled improper payment estimates
from OMB’s PaymentAccuracy.gov website. 8 We also reviewed payment
integrity information that agencies reported in their agency financial
reports (AFR) or performance and accountability reports (PAR). We
summarized and compared the improper payment estimates to identify
any substantial changes between fiscal year 2022 and prior years. We
reviewed the agencies’ AFRs or PARs to determine what agencies
identified as the causes for these changes. To summarize corrective
actions, we reviewed recent program scorecards published on
PaymentAccuracy.gov for those programs OMB considers high priority. 9
To address our second objective, we reviewed the fiscal year 2021 PIIA
compliance reports that each agency’s IG issues. 10 We focused on the 24
CFO Act agencies because the improper payment estimates for those
agencies accounted for over 99 percent of the federal government’s
reported estimated improper payments for fiscal year 2021.
To address our third objective, we reviewed our open (unaddressed)
priority recommendations made to agencies that reported improper
payment estimates in fiscal year 2022 and our recent matters for
congressional consideration.
8PaymentAccuracy.gov is an official U.S. government website managed by OMB. It
contains, among other things, information about current and historical rates (i.e., agency-
reported amounts as a percentage of outlays) amounts of improper payments, root causes
of monetary loss and improper payments, monetary-loss recovery efforts, and high-priority
program scorecards.
9PIIA requires OMB to annually designate a list of high-priority programs for greater levels
of review and oversight. 31 U.S.C. § 3352(b). OMB has assigned such a designation to
programs with estimates of improper payments resulting in monetary losses that exceed
$100 million annually. OMB’s guidance states that a monetary loss is an amount that
should not have been paid and in theory should or could be recovered and that a
monetary-loss type of improper payment is an overpayment.
10IGs are required to issue compliance reports under PIIA. 31 U.S.C. § 3353. Per OMB
Memorandum M-21-19, the compliance reports are due within 180 days following the
publishing of agencies’ annual financial statements and accompanying materials, which
typically occurs in mid-November. The most recent IG compliance reports available were
issued in 2022 for agencies’ fiscal year 2021 compliance with PIIA criteria.
Page 3 GAO-23-106285 Improper Payments
We conducted this performance audit from October 2022 to March 2023
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Congress passed PIIA to improve efforts to identify and reduce
Background government-wide improper payments. PIIA repealed the laws that
previously governed executive agency reporting on improper payments,
but it enacted substantially similar requirements in their place. 11
PIIA requires executive branch agencies, among other things, to (1)
review all programs and activities and identify those that may be
susceptible to significant improper payments (commonly referred to as
conducting a risk assessment), (2) publish improper payment estimates
for those programs and activities that the agency identified as being
susceptible to significant improper payments, (3) implement corrective
actions to reduce improper payments and set reduction targets, and (4)
report on the results of addressing the foregoing requirements. 12
OMB plays a key role in developing guidance for executive branch
agencies on estimating and reporting on improper payments. OMB
Circular A-123 Appendix C, Requirements for Payment Integrity
Improvement (OMB M-21-19), carries out OMB’s responsibility to issue
guidance under PIIA 13 and includes guidance for IGs on how to determine
agency compliance. 14 It also includes guidance for executive agencies on
the corrective actions that PIIA requires them to take if they are found
noncompliant. PIIA also requires the IG at each executive branch agency
to issue an annual report. 15
11PIIA previously repealed the Improper Payments Information Act of 2002, Improper
Payments Elimination and Recovery Act of 2010, and Improper Payments Elimination and
Recovery Improvement Act of 2012. See Pub. L. No. 116-117, § 3(a)(1)-(3), 134 Stat. 113,
133.
1231 U.S.C. § 3352.
1331 U.S.C. § 3352(g).
14OMB M-21-19, issued on Mar. 5, 2021, became effective starting in fiscal year 2021.
1531 U.S.C. § 3353(a).
Page 4 GAO-23-106285 Improper Payments
PIIA includes six criteria for compliance, which OMB M-21-19 expands to
10 by breaking some criteria into subcomponents and, in some cases,
adding new elements. Specifically, OMB instructs IGs to report on
whether agencies
1a. publish payment integrity information with their annual financial
statements,
1b. post their annual financial statement and accompanying materials on
their websites,
2a. conduct improper payment risk assessments for each program with
annual outlays greater than $10 million at least once in the last 3
fiscal years,
2b. adequately conclude whether each program is likely to make
improper payments and unknown payments 16 above or below the
statutory threshold (either $100 million or both 1.5 percent of
program outlays and $10 million),
3. publish improper payment and unknown payment estimates for
programs susceptible to significant improper payments and unknown
payments in the accompanying materials to the annual financial
statement,
4. publish corrective action plans for each program for which an
estimate above the statutory threshold was published in the
accompanying materials to the annual financial statement,
5a. publish an improper payment and unknown payment reduction
target for each program for which an estimate above the statutory
threshold was published in the accompanying materials to the
annual financial statement,
5b. demonstrate improvements to payment integrity or reach a tolerable
improper payment and unknown payment rate,
16When performing improper payment risk assessments and estimates under PIIA,
executive agencies are required to treat as improper any payments whose propriety
cannot be determined due to lacking or insufficient documentation. 31 U.S.C. §
3352(a)(3)(A), (c)(2). OMB M-21-19 refers to such payments as unknown payments and
instructs agencies to report the portion of their improper payment estimates attributable to
unknown payments separately, although all applicable statutory thresholds still apply to
the total estimate.
Page 5 GAO-23-106285 Improper Payments
5c. develop plans to meet their improper payment and unknown
payment reduction targets, 17 and
6. report improper payment and unknown payment estimates of less
than 10 percent for each program for which they published estimates
in the accompanying materials to their annual financial statements.
The criteria described above do not apply to all programs or agencies.
For example, if an agency determines that none of its programs or
activities are susceptible to improper payments as a result of its risk
assessment, criteria three through six would not be applicable. If an IG
concludes that any of the IG’s agency’s programs or activities fail to meet
any of the compliance criteria, the agency is considered noncompliant
under PIIA for that fiscal year and is required to take additional actions for
each year it is noncompliant.
OMB M-21-19 also provides guidance to agencies on their responsibilities
for preventing and reducing improper payments. The guidance directs
agencies that have developed improper payment estimates to categorize
them by root cause and to estimate the percentage of the total that each
category represents. According to the guidance, this level of specificity
helps lead to more effective corrective actions and more focused
prevention strategies.
Under PIIA, agencies with high-priority programs are subject to additional
reporting requirements. 18 OMB guidance states that high-priority
programs must provide OMB with select information on a quarterly basis
until they report annual monetary-loss improper payment estimates that
are less than $100 million. 19 The information includes actions these
programs have planned and taken to mitigate root causes of monetary-
loss improper payments. Agencies publish this information for high-
priority programs quarterly on PaymentAccuracy.gov in a payment
17OMB M-21-19’s criteria 5a, 5b, and 5c relate to 31 U.S.C. § 3351(2)(E), which states
that compliance means that the executive agency “publishes improper payment reductions
targets prepared under [31 U.S.C. § 3352(d)] that the executive agency may have in the
accompanying materials to the annual financial statement for each program or activity
assessed to be at risk, and has demonstrated improvements and developed a plan to
meet the reduction targets.”
1831 U.S.C. § 3352(b).
19The information provided to OMB includes actions the agency program has taken or to
intends to take to prevent improper payments and actions to recover monetary-loss
improper payments.
Page 6 GAO-23-106285 Improper Payments
integrity scorecard, also known as a program scorecard. Appendix I
presents an example of a program scorecard.
Agencies’ Improper
Payment Estimates
Totaled $247 Billion
for Fiscal Year 2022,
and Reported
Causes, Mitigation
Strategies, and
Recovery Activities
Varied
Agencies’ Improper Improper payment estimates that agencies reported to OMB totaled
Payment Estimates nearly $247 billion government-wide for fiscal year 2022. 20 Our analysis of
Totaled $247 Billion for agency data shows that 18 agencies reported improper payment
estimates across 82 programs. In addition, only 16 of the CFO Act
Fiscal Year 2022 agencies reported improper payment estimates for fiscal year 2022. 21 See
20This total of fiscal year 2022 improper payment estimates does not include numerous
agency programs that agencies determined are susceptible to significant improper
payments. As a result, the fiscal year 2022 government-wide estimated improper payment
amount is potentially incomplete and not representative of the full amount of improper
payments. See app. II for details on the agency programs.
21The Department of Energy, Department of the Interior, Department of Justice,
Department of State, Environmental Protection Agency, General Services Administration,
National Science Foundation, and U.S. Nuclear Regulatory Commission did not report
improper payment estimates for fiscal year 2022. As noted, PIIA only requires an estimate
when a risk assessment determines that a program may be susceptible to significant
improper payments. 31 U.S.C. § 3352(c)(1).
Page 7 GAO-23-106285 Improper Payments
appendix II for the reported improper payment amounts by agency and
program in fiscal year 2022. 22
As shown in figure 1, most of the $247 billion total (about $194 billion, or
78 percent) of estimated improper payments that agencies reported for
fiscal year 2022 is concentrated in five program areas:
1. the Department of Health and Human Services’ (HHS) Medicaid ($81
billion);
2. HHS’s Medicare, comprising three programs ($47 billion); 23
3. the Small Business Administration’s (SBA) Paycheck Protection
Program (PPP) ($29 billion);
4. the Department of Labor’s Unemployment Insurance (UI) ($19 billion);
and
5. the Department of the Treasury’s Earned Income Tax Credit ($18
billion).
22The improper payment rates and totals in this report are subject to uncertainty, meaning
the actual amounts may differ from the reported estimates. More information on the
margins of errors associated with these estimates can be found in the annual improper
payment data sets available on PaymentAccuracy.gov. Prior to March 2021, OMB
guidance for statistically valid estimates included explicit margins of error and levels of
confidence. OMB revised its guidance in March 2021 to state that estimates will be
considered statistically valid if they produce point estimates and confidence intervals
around those estimates. However, as of March 2021, OMB does not prescribe specific
margins of error or confidence intervals. Instead, OMB specifies that agencies must work
with their statisticians to determine the appropriate confidence interval given program
characteristics, available resources, and whether the estimates are reliable.
23Medicare is composed of the Medicare Fee-For-Service, Medicare Advantage (Part C),
and Medicare Prescription Drug (Part D) programs.
Page 8 GAO-23-106285 Improper Payments
Figure 1: Programs with the Largest Percentage of Total Reported Government-
Wide Estimates of Improper Payments for Fiscal Year 2022
Figure 2 presents the improper payment estimates by type, based on
information from PaymentAccuracy.gov and agency AFRs and PARs.
Figure 2: Breakdown of Agencies’ Fiscal Year 2022 Reported Estimated Improper
Payments by Type
Page 9 GAO-23-106285 Improper Payments
As seen in figure 2, the total $247 billion in government-wide estimated
improper payments for fiscal year 2022 breaks down into
• overpayments (monetary loss), totaling about $200 billion;
• underpayments, totaling about $5.3 billion;
• unknown payments, totaling about $32.7 billion; and
• technically improper payments, totaling about $9 billion. 24
The number of programs meeting the definition of high-priority program,
as specified in OMB guidance, increased in fiscal year 2022 compared to
fiscal year 2021. Per OMB, high-priority programs are those programs for
which agencies report estimated monetary loss from improper payments
in excess of $100 million. Based on fiscal year 2022 reporting, 29
programs at 11 agencies meet the definition of a high-priority program,
compared to 23 programs at 11 agencies for fiscal year 2021. Appendix
III contains a comparison of the agencies’ high-priority programs that
reported overpayments for fiscal years 2022 and 2021.
As shown in table 1, for fiscal year 2022, agencies reported estimated
improper payment rates of 10 percent or greater for 17 programs. 25
24OMB’s PaymentAccuracy.gov data call for fiscal year 2022 included guidance for
agencies to use when reporting the types of their estimated improper payments. This
guidance was in addition to that provided in OMB M-21-19 on reporting estimates for
programs or activities that are identified as susceptible to improper payments. According
to OMB M-21-19, “overpayments” are those in excess of the amount due, and are
payments that, in theory, should or could be recovered. “Underpayments” are those in
which recipients did not receive the funds to which they were entitled. “Unknown
payments” are those that a program cannot determine were either proper or improper.
“Technically improper payments” are those in which recipients received funds they were
entitled to, but the payment process failed to follow all applicable statutes or regulations.
25The improper payment rate reflects the estimated improper payments as a percentage
of total annual outlays.
Page 10 GAO-23-106285 Improper Payments
Table 1: Programs Reporting Annual Estimated Improper Payment Rates Greater Than 10 Percent for Fiscal Year 2022
Estimated improper payment
Agency Program rate (percent)a
Department of Veterans Affairs (VA) Purchased Long Term Services and Supports 47.5
Department of the Treasury American Opportunity Tax Credit 36.1
Department of Education Title I Grants to Local Educational Agencies 35.7
Treasury Earned Income Tax Credit 31.6
Department of Agriculture (USDA) Emergency Conservation Program - Disasters 29.2
Treasury Refundable Premium Assistance Tax Credit 27.4
Department of Health and Human Services Children’s Health Insurance Program 26.7
(HHS)
Education Special Education Grants to States 26.7
Corporation for National and Community Senior Companion Program 26.2
Service (CNCS)
CNCS Foster Grandparent Program 23.7
Department of Labor Unemployment Insurance 22.2
USDA Commodity Credit Corporation Trade Mitigation 19.3
Program
CNCS Retired and Senior Volunteer Program 17.2
Treasury Additional Child Tax Credit 15.8
HHS Medicaid 15.6
Education Education Stabilization Fund 12.1
VA Pension 11.7
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106285
a
The estimated improper payment rate is the estimated amount of improper payments divided by the
amount in program outlays for a given program in a given fiscal year.
For fiscal year 2022, agencies reported improper payment estimates of
$1 billion or more for 18 programs. Estimates for the following four
programs exceeded $1 billion for the first time:
• SBA’s PPP ($29 billion),
• SBA’s COVID Economic Injury Disaster Loans ($6.9 billion),
• the Department of Education’s Education Stabilization Fund ($6
billion), and
• Education’s Special Education Grants to States ($3.1 billion).
Page 11 GAO-23-106285 Improper Payments
Agencies Have Reported Twelve agencies reported estimated improper payments each fiscal year
Decreases in Estimated for 35 programs since fiscal year 2017 using a consistent methodology.
Over this period, agencies’ estimated improper payment rates have
Improper Payment Rates
decreased in 19 of these programs, according to fiscal year 2022
for 19 Programs since reporting (see table 2). 26 These changes may be attributable to a number
Fiscal Year 2017 of different factors, including agency corrective actions, changes in
policies, or variability (e.g., margin of error) in the process for estimating
the payment rates.
Table 2: Decreases in Improper Payment Rates for 19 Programs since Fiscal Year 2017
Decrease in
Fiscal year Fiscal year rate (net
2017 rate 2022 rate percentage
Agency Program (percentage)a (percentage) points)
Corporation for National and AmeriCorps 10.8 8.4 -2.4
Community Service
Department of Agriculture Special Supplemental Nutrition Program for 5.0 1.8 -3.2
Women, Infants, and Children Total Program
Department of Defense (DOD) DOD Travel Pay 5.0 4.4 -0.6
Department of Health and Human Child Care 4.1 4.0 -0.2
Services Medicare Fee-for-Service 9.5 7.5 -2.1
Medicare Prescription Drug (Part D) 1.7 1.5 -0.1
Department of Veterans Affairs Beneficiary Travel 25.1 7.9 -17.2
(VA) Communications, Utilities, and Other Rent 24.4 2.7 -21.7
Medical Care Contracts and Agreements 16.6 7.5 -9.1
Supplies and Materials 18.8 4.0 -14.7
Purchased Long Term Services and Support 100.0 47.5 -52.5
VA Community Care 93.4 7.8 -85.6
Federal Communications Universal Service Fund (USF)—Lifeline 21.9 6.1 -15.8
Commission USF—Schools and Libraries 4.3 3.7 -0.6
Small Business Administration 7(a) Guaranty Approvals 1.3 1.0 -0.3
7(a) Guaranty Purchases 4.3 4.2 -0.1
Disaster Loan Disbursements 13.7 3.1 -10.6
Social Security Administration Old-Age, Survivors, and Disability Insurance 0.3 0.2 -0.1
Supplemental Security Income 8.9 8.7 -0.1
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106285
26In addition, agencies stopped reporting estimates for at least 46 programs from fiscal
years 2017 through 2022 because the programs fell below the statutory threshold for
improper payment reporting and were therefore no longer considered susceptible to
significant improper payments.
Page 12 GAO-23-106285 Improper Payments
Notes: The table is based on fiscal year 2022 reporting for programs with estimates reported in each
fiscal year and using consistent estimation methodologies in each fiscal year since fiscal year 2017.
The table includes both statistical and nonstatistical estimates of improper payment totals. An
unknown number of differences listed in the table may be attributable to the uncertainty of the
estimation processes rather than changes in underlying agency conditions. Lower improper payment
rates may be due to a variety of other causes, including agency corrective actions and changes in
policies. Decreases may not equal the differences between the listed fiscal year 2017 and fiscal year
2022 rates due to rounding.
a
The estimated improper payment rate is the estimated amount of improper payments divided by the
amount in program outlays for a given program in a given fiscal year.
Of the 19 programs that reported decreases in improper payment rates
over the period, six were Department of Veterans Affairs (VA) programs
and three were HHS programs.
Decreases in certain VA programs’ estimated improper payment
rates. The largest decreases in estimated improper payment rates overall
were reported by VA for the VA Community Care program (85.6
percentage points) and the Purchased Long Term Services and Support
(PLTSS) program (52.5 percentage points). According to its fiscal year
2022 AFR, VA has reduced its estimates of improper payments, including
unknown payments, by about $11.2 billion since fiscal year 2018. VA
attributes this reduction to its use of mitigation strategies and corrective
actions that addressed the largest contributors of errors and
noncompliance with laws and regulations.
According to its fiscal year 2017 AFR, VA attributed the high fiscal year
2017 estimated improper payment rates in the VA Community Care and
PLTSS programs to noncompliance with Federal Acquisition Regulation
(FAR) requirements. Specifically, because VA made payments in these
programs that were noncompliant with FAR requirements, the resulting
payments were improper.
Statutory changes made in fiscal year 2018 contributed to reductions in
the VA Community Care and PLTSS improper payment rates. The VA
MISSION Act of 2018 allowed VA to enter into contracts to purchase care
without complying with all FAR requirements. In its report on VA’s fiscal
year 2019 compliance under IPERA, VA’s Office of Inspector General
(OIG) noted that VA planned to correct VA Community Care and PLTSS
improper payments by purchasing community care using new
agreements, as allowed by the VA MISSION Act. According to its OIG,
VA reported that this process would take time, and VA estimated that it
might not be able to fully report on the results of its ongoing and planned
corrective actions until fiscal year 2022.
Page 13 GAO-23-106285 Improper Payments
While only the VA Community Care program remains as high priority as
of fiscal year 2022, VA has substantially reduced improper payments in
both of these programs since 2017. Specifically, it has significantly
decreased these programs’ estimated improper payment rates.
Decreases in certain HHS programs’ estimated improper payment
rates. Two of the three HHS programs that reported decreases in
improper payment rates from fiscal year 2017 to fiscal year 2022 were
Medicare programs. For example, from fiscal years 2017 through 2022,
HHS reported a total decrease in Medicare Fee-for-Service estimated
improper payments of $4.8 billion, the largest amount for any of the 19
programs reporting decreases in improper payment rates over that
period.
Since 1990, we have included Medicare on our High Risk List, in part
because of its susceptibility to improper payments, which reached an
estimated $46.8 billion in fiscal year 2022. 27 The Centers for Medicare &
Medicaid Services (CMS) administers Medicare. In our most recent High
Risk List update, we assessed that CMS has both the leadership
commitment and capacity to address challenges that contribute to
Medicare’s high-risk status. HHS states it manages fraud risk within other
scopes of responsibility as well—such as annual internal control reviews
and audits; reviews of allegations involving misuse of grant or contractor
funds, conflicts of interest, misconduct, or misuse; continuous monitoring
of grant recipients through, for example, audit resolution, special
conditions/drawdown restrictions, site visits, and performance reports;
review of potential recipients; and other activities.
Within CMS, the Center for Program Integrity (CPI) serves as a
centralized entity for Medicare and Medicaid program integrity issues.
CMS has increased CPI’s resources over time, growing CPI’s staff from
117 full-time equivalent positions in fiscal year 2011 to about 492 in fiscal
year 2021. In addition, CMS has established working groups and
interagency collaborations to extend CPI’s capacity.
27The High Risk List highlights federal programs and operations that we have determined
are in need of transformation. It also names federal programs and operations that are
vulnerable to waste, fraud, abuse, and mismanagement. We issue a high-risk series
report every 2 years at the start of each new Congress.
Page 14 GAO-23-106285 Improper Payments
Agencies Primarily Agencies attributed about $225.5 billion (approximately 91.3 percent) of
Attributed Improper the improper payment estimates reported for fiscal year 2022 to the
following four root cause categories specified in OMB guidance: 28
Payments to Four Root
Cause Categories • Failure to access data/information needed. About $145.1 billion
(approximately 58.8 percent).
• Inability to access the data/information. About $35.9 billion
(approximately 14.5 percent).
• Data/information needed does not exist. About $24.2 billion
(approximately 9.8 percent).
• Unknown payment caused by insufficient or lack of
documentation from applicants to determine eligibility. About
$20.3 billion (approximately 8.2 percent).
Some agencies reported additional information in their AFRs or PARs
regarding the specific causes and challenges that contributed to improper
payments. This reporting included causes that were more specific to the
agencies and their processes than were the overarching OMB root cause
categories. 29 Table 3 summarizes the specific causes and challenges
reported by agencies in their AFRs or PARs for programs with the largest
improper payment estimates for fiscal year 2022.
28OMB M-21-19 defines a root cause as “something that would directly lead to an
improper payment, and if corrected, would prevent the improper payment.” While OMB M-
21-19 provides root cause categories for program administrators to use as a starting point
when identifying the root cause of a program’s improper payments, it notes that further
work may be needed to identify the “true root cause.” OMB’s PaymentAccuracy.gov
improper payment estimates are broken into eight root cause categories: (1) unknown
payment caused by insufficient or lack of documentation for eligibility by applicants, (2)
data/information needed does not exist, (3) failure to access data/information needed, (4)
failure to follow statute or regulation, (5) inability to access the data/information, (6) cause
of unknown payment is not specified, (7) unknown payment caused by insufficient or lack
of documentation from the states, and (8) unknown payment caused by insufficient or lack
of documentation submitted by vendors or providers. For the purposes of this report, we
did not conduct further analysis on the root cause categories that agencies reported.
29OMB’s PaymentAccuracy.gov data call instructions for fiscal year 2022 require agencies
to report additional information about specific causes and challenges for publication on
PaymentAccuracy.gov.
Page 15 GAO-23-106285 Improper Payments
Table 3: Detailed Root Cause Information for Programs with the Largest Improper Payment Estimates for Fiscal Year 2022
Agency Program Reported root causes of improper payments
Department of Medicaid • Insufficient documentation. State did not verify eligibility data, such as income,
Health and Human or did not provide documentation to validate that verification process was
Services completed; state did not submit medical records, or submitted records that
lacked required documentation.
• State noncompliance. State did not comply with federal eligibility
redetermination requirements or state did not appropriately screen enrolled
providers.
Medicare Fee-for-Service • Insufficient documentation. Missing required documentation, such as support
for level of care billing codes, orders for outpatient hospitals, and certification or
recertification of documents.
• Medically unnecessary errors. Hospice and home health claims did not meet
coverage criteria for medical necessity.
Small Business Paycheck Protection • Eligibility. Loan amounts disbursed to borrowers in excess of what they were
Administration Program eligible or receive, loans that lacked supporting documentation, or loans to
ineligible business types.
Department of Unemployment Insurance • Eligibility. Claimants continued to claim benefits after returning to work;
Labor employers failed to provide timely and adequate information on reasons for
employee departure; claimants failed to show that they met state requirements to
demonstrate they were actively seeking work.
• Fraud. Organized fraud, at the national and international level, targeted state
unemployment insurance systems (e.g., fraud during the COVID-19 pandemic).
Department of the Earned Income Tax Credit • Eligibility. Eligibility requirements for refundable tax credits are overly complex.
Treasury (EITC)a • Insufficient documentation. Internal Revenue Service lacked sufficient,
relevant, and timely third-party data to adequately verify taxpayer-provided
information.
• Tax preparation. Unenrolled tax-return preparers produced higher error rates
than enrolled preparers did on EITC returns.b
Source: GAO analysis of agencies’ fiscal year 2022 AFRs and PARs. | GAO-23-106285
Note: As reported by agencies in their fiscal year 2022 agency financial reports (AFR) or performance
and accountability reports (PAR).
a
Treasury reported eligibility and insufficient documentation as causes of refundable tax-credit
improper payments in general. Refundable tax credits include EITC, the American Opportunity Tax
Credit, the Advanced Child Tax Credit, and the net Premium Tax Credit. Treasury reported that the
root cause of refundable tax-credit improper payments is not internal control deficiencies but rather
the complexities of verifying eligibility and unavailability of third-party data.
b
Treasury reported that EITC returns have higher error rates because unenrolled tax-return preparers,
who prepare a large number of EITC returns, are not subject to the same level of training and
certifications as other tax professionals.
Estimated overpayments reported for fiscal year 2022 high-priority
programs totaled about $198.9 billion, or about 99 percent of the total
fiscal year 2022 overpayments. Agencies attributed about $15.5 billion
(approximately 8 percent) to root cause categories within the agencies’
control and $184.4 billion (approximately 92 percent) to root cause
Page 16 GAO-23-106285 Improper Payments
categories outside of agency control. 30 Table 4 shows the specific
overpayment estimates and associated root cause categories reported by
agencies for fiscal year 2022.
Table 4: Agency Reported Root Cause Categories for Estimated Overpayments, Fiscal Year 2022
Dollars in billions
Within agency control Outside of agency control
Root cause category Amount (dollars) Percent Amount (dollars) Percent
Failure to access data/information needed 11.6 75.0 129.8 70.4
Inability to access data/information 3.9 25.0 30.8 16.7
Data/Information does not exist 0.0a 0.0a 23.8 12.9
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106285
a
Numbers shown in table as 0.0 due to rounding. Agencies reported that about $500,000, or less than
0.1 percent, of estimated overpayments were attributable to the “Data/Information does not exist” root
cause category.
Agencies Reported Varied Based on our review of agencies’ fiscal year 2022 fourth quarter high-
Mitigation Strategies for priority program scorecards, strategies for mitigating monetary-loss
improper payments varied. 31 The most commonly reported mitigation
Monetary-Loss Improper
strategies related to training and proposed statutory changes. Table 5
Payments in High-Priority provides a comparison of the mitigation strategies for monetary loss
Programs reported most often by agencies for high-priority programs.
30OMB data call instructions define causes “within agency control” as those an agency is
able to control to avoid improper payments, while causes “outside agency control” are
those that might lead to improper payments but that the agency cannot control, such as
the program not being administered at the federal level.
31Agencies did not report high-priority program scorecards for the first quarter of fiscal
year 2023. For this report, we reviewed the most current available scorecards, issued for
the fourth quarter of fiscal year 2022, for those programs deemed high priority based on
agencies’ reported fiscal year 2021 improper payment estimates. Information on agency-
identified mitigation strategies for fiscal year 2022 estimated monetary-loss improper
payments can be found on OMB’s Annual Improper Payments Dashboard on
PaymentAccuracy.gov.
Page 17 GAO-23-106285 Improper Payments
Table 5: High-Priority Program Mitigation Strategies for Monetary-Loss Improper Payments Reported for Fiscal Year 2021
Reported use to mitigate overpayments
Mitigation Within agency Outside agency
strategy Description control control Total
Audit Process for assuring an organization’s objectives of 3 1 4
operational effectiveness; efficiency; reliable financial
reporting; and compliance with laws, regulations, and
policies.
Automation Automatically controlled operation, process, or system. 2 3 5
Change process Altering or updating a process or policy to prevent or 3 2 5
correct error.
Cross enterprise Sharing of documents, processes, and opportunities 1 2 3
sharing with intra-agency partners and stakeholder. Potentially
managed through federated repositories and a registry
to increase access to information used to mitigate
improper payments.
Predictive analysis Data analytics technique used to prevent improper 1 0 1
payments. Analyzes known improper payments to
identify common attributes that may be linked to
improper payments.
Statutory change Proposed changes to statute that would modify 0 6 6
conditions that lead to improper payments.
Training Teaching particular skills or methods; reminding 3 9 12
people of proper processing methods.
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106285
Note: Data in the table are based on agencies’ high-priority program scorecards posted to
PaymentAccuracy.gov for fiscal year 2022, fourth quarter. These scorecards list mitigation strategies
for agencies’ reported fiscal year 2021 monetary-loss estimates. In addition to the seven mitigation
strategies listed in this table, agencies also had the option to select “behavioral/psychological
influence” as a strategy. Per OMB guidance, behavioral/psychological influence is defined as the use
of behavioral science, such as psychology, to understand how individuals absorb, process and react
to information and to use this understanding to design practical policies and interventions. In fiscal
year 2021, no agencies reported use of this mitigation strategy.
Some of the largest agency programs reported the following improper-
payment mitigation strategies in their fiscal year 2022, fourth quarter
program scorecards: 32
• HHS Medicaid. Provide training and resources by working with states
to develop corrective action plans; provide state Medicaid provider
enrollment tools, technical assistance, and training; conduct site visits
32For purposes of this report, we did not conduct further analysis or make any
determinations as to whether each agency implemented the mitigation strategies they
reported.
Page 18 GAO-23-106285 Improper Payments
for provider screening and enrollment; conduct beneficiary eligibility
audits and reviews.
• HHS Medicare Advantage (Part C). Provide training to reduce
administrative or process errors made by other parties through
contract-level Risk Adjustment Data Validation audits; improve policy
based on statutory requirements; expand education to Medicare
Advantage Organizations.
• HHS Medicare Fee-for-Service. Provide training to reduce
administrative or process errors through systems edits, provider and
supplier screening, participation in the Healthcare Fraud Prevention
Partnership, integrated medical review approaches, improved policy,
and expanded provider education.
• HHS Medicare Prescription Drug (Part D). Provide training to
reduce administrative or process errors made by other parties through
outreach efforts; improve policy based on statutory requirements;
expand education to Part D sponsors.
• Labor UI. Provide training to give states access to resources; offer
states enhanced technical assistance to prevent or detect improper
payments and fraud and to reduce the number of improper payments
caused by issues that normal procedures did not detect.
Agencies Reported on In fiscal year 2022, agencies reported on overpayment recovery methods
Their Overpayment they currently use. Based on our review of the PaymentAccuracy.gov
data, 14 of the 24 CFO Act agencies reported monetary loss, and they
Recovery Methods
use a variety of methods to recover overpayments.
For example, OMB’s PaymentAccuracy.gov data show that most CFO Act
agencies with reported monetary-loss improper payments used either
mailed or electronic notices to recover overpayments. 33 CFO Act
agencies that did not use mailed or electronic notification most commonly
used Treasury’s reclamation process to recover overpayments.
Treasury’s Bureau of the Fiscal Service uses recovery procedures to
obtain refunds (reclamations) from financial institutions. Nine of the 14
CFO Act agencies that reported monetary-loss improper payments used
the Treasury reclamation process.
33A mailed or electronic notification advises the recipient of the amount of money owed to
the agency.
Page 19 GAO-23-106285 Improper Payments
Appendix IV contains a list of the CFO Act agencies that reported
monetary-loss improper payments in fiscal year 2022, as well as their
associated recovery activities.
In fiscal year 2021, fewer than half of the 24 CFO Act Agencies were
IGs Reported Fewer compliant with PIIA and related OMB criteria, as reported by their IGs.
Than Half of CFO Act Specifically, only 10 agencies were overall compliant with PIIA and OMB
criteria in fiscal year 2021, a decrease from 12 agencies in fiscal year
Agencies as 2020, and the lowest number of CFO Act agencies reported as compliant
Compliant with PIIA since fiscal year 2017. Figure 3 provides a 6-year comparison of
agencies’ compliance with criteria—which includes IPERA criteria for
and Related OMB fiscal years prior to 2020 and PIIA criteria for fiscal year 2020 onward—as
Criteria for Fiscal reported by agencies’ respective IGs.
Year 2021
Figure 3: CFO Act Agencies’ Compliance with PIIA or IPERA Criteria for Fiscal
Years 2016 through 2021, as Reported by Their IGs
Page 20 GAO-23-106285 Improper Payments
This decline in compliance with PIIA and related OMB criteria from fiscal
year 2020 to fiscal year 2021 is mainly attributable to four agencies that
were reported by their IGs as compliant in fiscal year 2020 but
noncompliant in fiscal year 2021. 34 These agencies are Labor, the
Environmental Protection Agency (EPA), the National Aeronautics and
Space Administration (NASA), and the Office of Personnel Management
(OPM). While there was no common cause for Labor, EPA, NASA, and
OPM status changes from compliant to noncompliant, their IGs reported
compliance issues with these agencies’ risk assessments and improper
payment estimates for fiscal year 2021. For example:
• Labor did not appropriately estimate improper payments associated
with UI due to issues with its estimation methodology.
• EPA did not make adequate conclusions from its risk assessments
because it used outdated operating procedures and lacked standard
operating procedures to evaluate payments.
• NASA did not publish improper payment estimates for a program that
was previously identified as susceptible to significant improper
payments because it only reported programs that were risk assessed
in response to OMB’s fiscal year 2021 data call.
• OPM did not complete all required risk assessments.
IGs also reported issues related to the effects of the federal response to
COVID-19 that, in some cases, caused agencies to be noncompliant with
PIIA and related OMB criteria for fiscal year 2021. For example:
• Labor used an improper payment rate derived from the state UI
program to calculate the improper payments for the combined outlays
of the UI program. However, this methodology did not take into
account that a portion of the outlays was associated with its Pandemic
Unemployment Assistance claims rather than state UI claims. The
impact of this could not be determined because the pandemic
assistance improper payment estimate was not required to be
reported for fiscal year 2021.
• HHS’s ability to visit sites and access external information was
hampered by the impact of COVID-19; as a result, HHS did not report
improper payment and unknown payment estimates for its Foster
Care program. Similarly, the Department of Housing and Urban
34Fiscal year 2021 was the first year IGs evaluated agency compliance under PIIA and
OMB M-21-19.
Page 21 GAO-23-106285 Improper Payments
Development (HUD) could not access files maintained outside of the
agency.
• SBA and Treasury did not adjust their PIIA compliance activities to
accommodate for changes caused by COVID-19 and the CARES Act.
For example, SBA did not update risk assessments after the CARES
Act created new and modified existing SBA programs. Similarly,
Treasury did not adequately conclude that its U.S. Coronavirus
Economic Impact Payment program was susceptible to improper
payments.
With regard to the PIIA and related OMB compliance criteria, as shown in
figure 4, IGs reported all agencies as compliant with the criteria to publish
payment integrity information within the AFR or PAR and to post it on the
agencies’ websites. In addition, 19 agencies met the criterion to conduct
program-specific risk assessments, and 20 agencies adequately
concluded improper payment likelihood from their risk assessments.
Page 22 GAO-23-106285 Improper Payments
Figure 4: Chief Financial Officers Act of 1990 Agencies’ Compliance with Payment
Integrity Information Act of 2019 and Related Office of Management and Budget
Criteria for Fiscal Year 2021, as Reported by Their IGs
Based on the IGs’ fiscal year 2021 compliance reports, agencies were
most frequently noncompliant with the criterion to report estimated
improper payments at or below 10 percent for programs that published
estimates in the accompanying materials to the annual financial
statement. IGs reported that out of the 16 agencies for which this criterion
was applicable, nine agencies were noncompliant. The second most
frequently reported area of noncompliance related to the criterion that
applicable agencies publish their improper payment estimates; out of the
16 agencies for which this criterion was applicable, IGs for six agencies
reported noncompliance.
IGs reported that improper payment estimates for the CFO Act agency
programs that were noncompliant with PIIA and related OMB criteria for
fiscal year 2021 totaled about $247.5 billion. This represents
Page 23 GAO-23-106285 Improper Payments
approximately 88 percent of the $281 billion government-wide total of
improper payment estimates for fiscal year 2021.
In fiscal year 2021, OMB updated its process to collect improper payment
data from agencies. Prior to fiscal year 2021, agencies manually inputted
their data into a spreadsheet and uploaded it through OMB’s MAX
information system, at which point the information would be uploaded to
PaymentAccuracy.gov. 35 The new process uses a survey tool and
conditional logic to collect the required information on improper payments,
unknown payments, and improper payment recovery actions uploaded
through OMB MAX. 36 Figure 5 shows OMB’s timeline for its annual
improper payment estimates data call process.
35OMB MAX is a government-wide system used to share information and services among
government agencies.
36Conditional logic is a set of rules or conditions that cause a process to change based on
input. The OMB survey tool applies conditional logic to general questions that are
applicable to an agency’s programs in order to gather specific information to publish on
PaymentAccuracy.gov.
Page 24 GAO-23-106285 Improper Payments
Figure 5: Office of Management and Budget (OMB) Annual Improper Payment Estimates Data Call Timeline
Note: Per OMB, GSA is engaged to perform certain functions that are outside of OMB’s area of
expertise, such as database development.
However, IGs for just over a third of the CFO Act agencies (nine out of
24) reported that agencies submitted inaccurate data using OMB’s new
data collection process. 37 Based on our review of IG reports, these
agencies experienced issues such as entering data improperly, OMB
system errors, or OMB’s survey tool collecting information in a format that
differed from how the agency obtained it. 38 For example, IGs reported the
following:
37Per OMB, the number of agencies providing inaccurate data was larger prior to its new
data collection method. For example, OMB indicated that in fiscal year 2017, it identified
errors in data submissions from 18 of the 24 CFO Act agencies prior to publication.
38In 2022, GAO recommended that the Director of OMB require agencies to certify the
reliability of data submitted to PaymentAccuracy.gov. GAO, COVID-19: Current and
Future Federal Preparedness Requires Fixes to Improve Health Data and Address
Improper Payments, GAO-22-105397 (Washington, D.C.: Apr. 27, 2022).
Page 25 GAO-23-106285 Improper Payments
• Five agencies—Department of Agriculture (USDA), Department of
Transportation, NASA, Treasury, and the U.S. Agency for
International Development (USAID)—entered data to OMB’s system
improperly. The reasons for discrepancies varied. For example,
Treasury’s IG stated that OMB did not provide Treasury with sufficient
time to comprehend and implement OMB’s instructions, while
USAID’s IG stated that the inadequacy of USAID’s controls caused
the issue. USDA’s IG cited both a lack of guidance and lack of an
opportunity to review the improper payment information before it was
published.
• IGs for the Department of Defense (DOD), NASA, and OPM reported
that the OMB system did not accept agency-specific formatting or
prepopulated information. According to DOD’s IG, OMB’s system did
not allow DOD to report confirmed fraud amounts in the manner it
tracks them. NASA’s IG reported that OMB’s system collected
information by agency programs and did not allow it to report
information on the activity level, as the administration tracks it.
Additionally, according to OPM’s IG, the use of drop-down menus and
prepopulated information did not allow it to elaborate or contextualize
its improper payment data. 39
OMB requires agencies to develop sampling and estimation methodology
plans when producing improper payment estimates for programs
susceptible to significant improper payments. However, EPA, DOD,
Education, Labor, and HUD had inadequate plans, according to their
IGs. 40 These agencies had issues such as incomplete information,
insufficient documentation, and lack of guidance to support sampling and
estimation plan implementation. As a result, the PIIA compliance reports
for all five agencies included recommendations to improve their sampling
and estimation plans, such as by
• revising agency plans to include missing information,
• developing guidance and procedures to support plan implementation,
and
39Per OMB, it made changes to its fiscal year 2022 data call process to prevent similar
situations from occurring. For example, according to OMB, these changes included giving
agency programs the opportunity to elaborate on any item selected from the drop down
menu, issuing guidance at least 3 months earlier, and adjusting the level of data collection
to accommodate all agencies.
40In addition, according to their IGs, SBA and the Departments of the Interior and
Transportation lacked sufficient documentation to support their methodologies.
Page 26 GAO-23-106285 Improper Payments
• developing a new plan.
Our work on improper payments, financial management, and the federal
Recent Matters for government’s response to the pandemic has provided suggested actions
Congressional for Congress and federal agencies to increase transparency and
accountability of federal spending by strengthening federal financial and
Consideration and fraud risk management. While Congress and federal agencies have made
Priority efforts in recent years, more work remains to be done to improve
payment integrity. Implementing our suggestions and priority
Recommendations recommendations may help to reduce improper payments.
Have Identified
Opportunities to
Reduce Improper
Payments
Congress Has Taken Congress has taken some steps to implement our matters for
Some Action, but congressional actions for reducing improper payments. For example, to
enhance identity verification through data sharing, we have previously
Opportunities Remain to
suggested that Congress consider amending the Social Security Act to
Reduce Improper share the Social Security Administration’s (SSA) full death data with
Payments Treasury’s Do Not Pay (DNP) System. 41 In December 2020, Congress
passed—and the President signed into law—the Consolidated
Appropriations Act, 2021. The act requires SSA, to the extent feasible, to
share its full death data with Treasury’s DNP system for a 3-year period. 42
Sharing these data will allow agencies to enhance their efforts to identify
and prevent improper payments to deceased individuals.
However, other matters for congressional consideration related to
improper payments remain open. This includes suggestions we made
recently as a result of our oversight of the federal government’s response
to COVID-19. For example, we suggested that Congress amend PIIA to
designate all new federal programs making more than $100 million in
payments in any one fiscal year as “susceptible to significant improper
41GAO, Improper Payments: Strategy and Additional Actions Needed to Help Ensure
Agencies Use the Do Not Pay Working System as Intended, GAO-17-15 (Washington,
D.C.: Oct. 14, 2016), and COVID-19: Opportunities to Improve Federal Response and
Recovery Efforts, GAO-20-625 (Washington, D.C.: June 25, 2020).
42Consolidated Appropriations Act, 2021, Pub. L. No. 116-260. § 801, 134 Stat. 1182,
3201 (Dec. 27, 2020), amending 42 U.S.C. § 405(r). This provision will take effect 3 years
after enactment and will be effective for a 3-year period.
Page 27 GAO-23-106285 Improper Payments
payments” for their initial years of operation. If enacted, this measure
would lead to more timely reporting of improper payment estimates
because agencies will be required to expeditiously estimate their
improper payments, identify root causes, and develop corrective actions.
See appendix V for the 12 open matters for congressional consideration
related to improper payments as a result of our COVID-19 work. See
appendix VI for eight additional matters for congressional consideration to
improve federal financial management.
Open Priority We have made numerous priority recommendations to federal agencies
Recommendations to related to improper payments. 43 Of the 18 agencies that reported
Agencies to Reduce improper payment estimates in fiscal year 2022, eight had open priority
recommendations related to improper payments. As of February 2023, 37
Improper Payments out of 53 of those recommendations remained open. See appendix VII for
a list of the recommendations.
Some of our open recommendations are directed at agencies with high-
priority programs with more than $1 billion in overpayments or monetary
loss. 44 For example, we recommended the following:
• HHS’s CMS institute a process to routinely assess, and take steps to
ensure, as appropriate, that Medicare and Medicaid documentation
requirements are necessary and effective at demonstrating
compliance with coverage policies while appropriately addressing
program risks. HHS agreed with our recommendation.
• SBA develop a strategy that outlines specific actions to monitor and
manage fraud risks in the Paycheck Protection Program on a
continuous basis. SBA agreed with our recommendation.
Additionally, we made the following priority recommendations related to
improper payments to OMB:
• To better monitor agency use of the DNP working system once a
strategy has been developed, the Director of OMB should develop
and implement monitoring mechanisms—such as goals, benchmarks,
and performance measures—to evaluate agency use of the DNP
working system. OMB agreed with the concept of monitoring
43Priority recommendations warrant priority attention from heads of key departments or
agencies. Since 2015, we have sent letters to selected agencies to highlight the
importance of implementing such recommendations.
44As previously mentioned, high-priority programs are those reporting estimated annual
monetary-loss improper payments of $100 million or more.
Page 28 GAO-23-106285 Improper Payments
mechanisms and indicated that it will continue to work with agencies
to address this recommendation. In March 2022, OMB informed us
that due to policy priorities and limited resources, it is not able to
completely implement this recommendation. As of December 2022,
OMB did not indicate any change in its position.
• The Director of OMB should work in consultation with federal
agencies and the audit community (e.g., agency Offices of Inspector
General; National Association of State Auditors, Comptrollers, and
Treasurers; and American Institute of Certified Public Accountants), to
the extent practicable, to incorporate appropriate measures in OMB’s
process for preparing single audit guidance, including the annual
Single Audit Compliance Supplement, to better ensure that such
guidance is issued in a timely manner and is responsive to users’
input and needs. 45 OMB neither agreed nor disagreed with this
recommendation. OMB issued a Controller Alert in December 2021
that included a timeline for preparing the 2022 Compliance
Supplement, which was published on May 11, 2022.
By working collaboratively to address the open priority recommendations
and matters for congressional considerations, federal agencies and
Congress can make progress toward reducing improper proper payments
and improving payment integrity.
We provided a draft of this report to OMB for review and comment. OMB
Agency Comments provided technical comments, which we have incorporated as
appropriate.
We are sending copies of this report to the appropriate congressional
committees and the Office of Management and Budget. In addition, the
report is available at no charge on the GAO website at
https://www.gao.gov.
If you or your staff members have any questions about this report, please
contact me at (202) 512-5683 or padillah@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
45A single audit is an audit of certain award recipients’ financial reporting and expenditure
of federal awards and can identify deficiencies in the award recipient’s compliance with
laws, regulations, contracts, or grant agreements and in its financial management and
internal control systems. Correcting such deficiencies can help reasonably assure the
effective use of federal funds and reduce federal improper payments.
Page 29 GAO-23-106285 Improper Payments
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix VIII.
M. Hannah Padilla
Director, Financial Management and Assurance
Page 30 GAO-23-106285 Improper Payments
Appendix I: Excerpt from an Example of an
Appendix I: Excerpt from an Example of an
Agency’s High-Priority Program Scorecard
Agency’s High-Priority Program Scorecard
Figure 6: Excerpt from an Example of an Agency’s High-Priority Program Scorecard
Page 31 GAO-23-106285 Improper Payments
Appendix II: Reported Estimated Improper Appendix II: Reported Estimated Improper
Payments and Rates by Agency and Program
for Fiscal Year 2022
Payments and Rates by Agency and
Program for Fiscal Year 2022
Table 6 details the estimated improper payments and rates that federal
agencies reported to the Office of Management and Budget for fiscal year
2022. In total, 18 agencies reported estimates for 82 programs for fiscal
year 2022.
Table 6: Reported Estimated Improper Payments and Rates by Agency and Program for Fiscal Year 2022
Outlays by Estimated
programs reporting Estimated improper improper
estimates (millions payment amount payment ratea
Agency and program of dollars) (millions of dollars) (percent)
U.S. Agency for International Development 6,984.0 0.2
Administration and Oversight 50.7 0.0 0.0
Protection, Assistance and Solutions 5,205.4 0.0 0.0
Operating Expense 1,193.0 0.2 0.0
Administration and Oversight 534.9 0.1 0.0
Corporation for National and Community Service 430.0 60.8
AmeriCorps State and National 256.0 21.5 8.4
Foster Grandparent Program 91.6 21.8 23.7
Retired and Senior Volunteer Program 45.0 7.8 17.2
Senior Companion Program 37.3 9.8 26.2
Department of Agriculture (USDA) 86,150.2 1,905.8
Commodity Credit Corporation (CCC) Agriculture Risk Coverage 6,290.8 378.8 6.0
and Price Loss Coverage
CCC Trade Mitigation Program 39.2 7.6 19.3
Emergency Conservation Program - Disasters 61.1 17.8 29.2
Food and Nutrition Service (FNS) Child and Adult Care Food 4,351.0 3.1 0.1
Program
FNS National School Lunch Program 5,845.0 87.7 1.5
FNS Pandemic Electronic Benefit Transfer 30,540.0 65.7 0.2
FNS School Breakfast Program 2,521.0 53.2 2.1
FNS Special Supplemental Nutrition Program for Women, Infants, 2,648.0 47.8 1.8
and Children Total Program
Risk Management Agency Federal Crop Insurance Corporation 11,824.5 304.7 2.6
Farm Service Agency (FSA) Coronavirus Food Assistance 19,028.4 743.4 3.9
Program
FSA Livestock Forage Disaster Program 554.1 51.5 9.3
FSA Noninsured Crop Disaster Assistance Program 177.9 16.8 9.5
FSA Quality Loss Adjustment Program 285.9 16.1 5.6
Wildfires and Hurricanes Indemnity Program Plus 1,983.4 111.7 5.6
Page 32 GAO-23-106285 Improper Payments
Appendix II: Reported Estimated Improper
Payments and Rates by Agency and Program
for Fiscal Year 2022
Outlays by Estimated
programs reporting Estimated improper improper
estimates (millions payment amount payment ratea
Agency and program of dollars) (millions of dollars) (percent)
Department of Commerce 70.1 3.9
Economic Development Administration - Funds Received under 70.1 3.9 5.6
Bipartisan Budget Act of 2018
Department of Defense (DOD) 616,863.2 2,011.8
Civilian Pay 47,036.0 157.5 0.3
Commercial Pay 389,991.7 67.5 0.0
DOD Travel Pay 8,405.2 368.5 4.4
Military Pay – Marine Corps 9,121.2 0.0 0.0
Military Health Benefits 20,762.3 149.6 0.7
Military Pay - Air Force 25,826.0 30.9 0.1
Military Pay - Army 40,061.4 818.0 2.0
Military Pay - Navy 23,785.3 1.1 0.0
Military Retirement 51,874.2 418.8 0.8
Department of Education 186,095.3 15,718.7
Education Stabilization Fund 49,280.6 5,956.4 12.1
Federal Pell Grant Program 26,129.5 586.0 2.2
Special Education Grants to States 11,668.5 3,117.1 26.7
Title I Grants to Local Educational Agencies 15,202.1 5,430.6 35.7
William D. Ford Federal Direct Loan Program 83,814.7 628.6 0.7
Department of Health and Human Services (HHS) 1,475,895.7 132,646.3
Administration for Children and Families (ACF) Child Care and 8,699.1 344.7 4.0
Development Fund
ACF Head Start - Disaster Relief 69.6 0.2 0.2
Centers for Medicare & Medicaid Services (CMS) Advance 41,255.8 255.8 0.6
Premium Tax Credit
CMS Children’s Health Insurance Program 16,093.0 4,304.5 26.7
CMS Medicaid 515,813.5 80,573.0 15.6
CMS Medicare Advantage (Part C) 257,174.1 13,940.8 5.4
CMS Medicare Fee-for-Service 421,914.4 31,456.7 7.5
CMS Medicare Prescription Drug Benefit (Part D) 88,415.6 1,361.1 1.5
Health Resources and Services Administration - Provider Relief 126,460.5 409.5 0.3
Fund General and Targeted
Department of Homeland Security 5,691.1 257.3
Federal Emergency Management Agency (FEMA) - Disaster Case 66.2 1.1 1.7
Management - Disaster Supplemental Funds
Page 33 GAO-23-106285 Improper Payments
Appendix II: Reported Estimated Improper
Payments and Rates by Agency and Program
for Fiscal Year 2022
Outlays by Estimated
programs reporting Estimated improper improper
estimates (millions payment amount payment ratea
Agency and program of dollars) (millions of dollars) (percent)
FEMA - Disaster Case Management - Disaster Supplemental 32.0 2.2 7.0
Funds Hazard Mitigation Grant Program
FEMA - Payroll - Disaster Supplemental Funds 252.2 7.3 2.9
FEMA - Public Assistance - Disaster Supplemental Funds - 4,767.9 242.9 5.1
Validate as You Go
FEMA - Vendor Pay - Disaster Supplemental Funds 495.3 3.5 0.7
United States Coast Guard (USCG) - Aviation Logistics Command 25.1 0.0 0.0
- Disaster Supplemental Funds
USCG - Procurements, Construction, and Improvement - Disaster 52.4 0.3 0.6
Supplemental Funds
Department of Housing and Urban Development 1,538.5 2.9
Community Planning and Development - Public Laws 115-123, 1,538.5 2.9 0.2
115-56, and 115-72
Department of Labor 88,158.9 19,016.7
Employment and Training Administration - Federal State 85,235.6 18,925.0 22.2
Unemployment Insurance
Office of Workers’ Compensation - Federal Employees’ 2,923.3 91.7 3.1
Compensation Act
Department of Transportation 61,613.7 755.6
Federal Highway Administration Highway Planning and 48,440.1 549.0 1.1
Construction
Federal Transit Administration Transit Infrastructure Grants - 13,173.5 206.6 1.6
COVID Relief Funds
Department of the Treasury 98,097.1 25,967.3
Internal Revenue Service (IRS) - Additional Child Tax Credit 32,841.4 5,182.4 15.8
IRS - American Opportunity Tax Credit 5,625.9 2,029.8 36.1
IRS - Earned Income Tax Credit 57,522.8 18,177.2 31.6
IRS - Refundable Premium Assistance Tax Credit 2,107.0 577.9 27.4
Department of Veterans Affairs (VA) 31,716.5 3,499.7
Beneficiary Travel 1,253.7 99.1 7.9
Communications, Utilities, and Other Rent 1,819.9 49.1 2.7
Medical Care Contracts and Agreements 1,051.0 78.5 7.5
Pension 4,224.8 492.4 11.7
Purchased Long Term Services and Supports 2,709.1 1,285.5 47.5
Supplies and Materials 3,276.1 132.0 4.0
VA Community Care 17,382.0 1,363.1 7.8
Page 34 GAO-23-106285 Improper Payments
Appendix II: Reported Estimated Improper
Payments and Rates by Agency and Program
for Fiscal Year 2022
Outlays by Estimated
programs reporting Estimated improper improper
estimates (millions payment amount payment ratea
Agency and program of dollars) (millions of dollars) (percent)
Federal Communications Commission 2,764.1 117.8
Universal Service Fund - Lifeline 606.7 37.2 6.1
Universal Service Fund - Schools and Libraries 2,157.3 80.6 3.7
National Aeronautics and Space Administration 16.5 0.0
Disaster Relief Appropriation 16.5 0.0 0.0
Office of Personnel Management 87,898.9 337.9
Federal Retirement Services 87,898.9 337.9 0.4
Small Business Administration 888,419.3 37,273.9
7(a) Loan Guaranty Approvals 29,717.2 298.1 1.0
7(a) Loan Guaranty Purchases 706.9 29.8 4.2
504 Loan Guaranty Approvals 10,020.8 201.2 2.0
COVID-Economic Injury Disaster Loan (EIDL) 153,811.6 6,916.7 4.5
Disaster Assistance Loans 1,133.6 34.7 3.1
EIDL Emergency Assistance (Advance) 7,849.8 766.3 9.8
Paycheck Protection Program 685,179.4 29,027.0 4.2
Social Security Administration 1,183,790.1 7,397.0
Old-Age, Survivors, and Disability Insurance 1,127,519.0 2,491.0 0.2
Supplemental Security Income 56,271.1 4,906.0 8.7
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106285
Notes: Totals may not agree because of rounding. Agencies did not report fiscal year 2022 improper
payment estimates for numerous programs that were determined to be susceptible to significant
improper payments. Specifically, the following programs did not report improper payment estimates
for fiscal year 2022: (1) USDA FNS’s Supplemental Nutrition Assistance Program (outlays of $ 71.4
billion); (2) USDA FNS’s Summer Food Service Program (outlays of $10.9 billion); (3) HHS ACF’s
Foster Care (outlays of $2.3 billion); (4) HHS’s Temporary Assistance for Needy Families (outlays of
$15.9 billion); (5) HHS’s Health Resources and Services Administration’s Provider Relief Fund,
Uninsured (outlays not reported); (6) HHS’s Head Start (outlays of $10.8 billion); (7) Labor’s
Employment and Training Administration’s Unemployment Insurance, Federal Pandemic
Unemployment Assistance (outlays not reported); and (8) the Federal Communications Commission’s
Universal Service Fund, High Cost (outlays not reported). As a result, the fiscal year 2022
government-wide estimated improper payment amount is potentially incomplete and not
representative of the full amount of improper payments.
a
The estimated improper payment rate is the estimated amount of improper payments divided by the
amount in program outlays for a given program in a given fiscal year.
Page 35 GAO-23-106285 Improper Payments
Appendix III: High-Priority Programs’ Appendix III: High-Priority Programs’
Estimated Overpayments Reported for Fiscal
Years 2022 and 2021
Estimated Overpayments Reported for Fiscal
Years 2022 and 2021
Table 7 provides a comparison of the high-priority programs that reported
overpayments for fiscal years 2022 and 2021.
Table 7: High-Priority Programs’ Estimated Overpayments, Fiscal Years 2022 and 2021
Fiscal year 2022 Fiscal year 2021
overpayments overpayments
Agency Program (millions of dollars) (millions of dollars)
Department of Agriculture Food and Nutrition Service (FNS) National School Not reported 491.7
Lunch Program
FNS School Breakfast Program Not reported 167.9
Risk Management Agency Federal Crop Insurance 289.4 153.3
Corporation
Department of Defense (DOD) DOD Travel Pay 107.2 Not reported
Military Health Benefits - Healthcare 105.8 124.2
Military Retirement 369.5 Not reported
Department of Education Federal Pell Grant Program 240.6 274.0
William D. Ford Federal Direct Loan Program 103.2 Not reported
Department of Health and Centers for Medicare & Medicaid Services (CMS) 236.1 Not reported
Human Services Advance Premium Tax Credit
CMS Children’s Health Insurance Program 4,303.0 5,372.0
CMS Medicaid 80,203.7 98,357.4
CMS Medicare Advantage (Part C) 12,686.1 15,182.2
CMS Medicare Fee-for-Service 30,678.0 24,584.9
CMS Medicare Prescription Drug Benefit (Part D) 1,323.2 686.5
Health Resources and Services Administration - 409.5 Not reported
Provider Relief Fund General and Targeted
Department of Labor Employment & Training Administration - Federal 17,820.2 73,842.2
State Unemployment Insurance
Department of Transportation Federal Highway Administration Highway Planning Not reported 428.7
and Construction
Federal Transit Administration Transit 206.6 Not reported
Infrastructure Grants - COVID Relief Funds
Department of the Treasury Internal Revenue Service (IRS) - Additional Child 5,182.4 5,218.8
Tax Credit
IRS - American Opportunity Tax Credit 2,029.8 1,873.4
IRS - Earned Income Tax Credit 18,177.2 18,971.0
IRS - Refundable Premium Assistance Tax Credit 577.9 Not reported
Department of Veterans Pension 492.0 367.6
Affairs (VA) Purchased Long Term Services and Supports Not reported 105.9
VA Community Care 770.9 1,389.5
Page 36 GAO-23-106285 Improper Payments
Appendix III: High-Priority Programs’
Estimated Overpayments Reported for Fiscal
Years 2022 and 2021
Fiscal year 2022 Fiscal year 2021
overpayments overpayments
Agency Program (millions of dollars) (millions of dollars)
Federal Communication Universal Service Fund - Lifeline Not reported 117.4
Commission
Office of Personnel Federal Retirement Services 244.7 228.3
Management
Small Business Administration 7(a) Loan Guarantees Approvals 298.1 Not reported
504 Certified Development Loans Approvals 199.0 Not reported
COVID-19 Economic Injury Disaster Loan (EIDL) 2,600.0 Not reported
EIDL Emergency Assistance (Advance) 766.3 Not reported
Paycheck Protection Program 12,529.3 Not reported
Social Security Administration Old-Age, Survivors, and Disability Insurance 1,972.3 4,985.9
Supplemental Security Income 4,032.5 1,813.6
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106285
Page 37 GAO-23-106285 Improper Payments
Appendix IV: CFO Act Agencies’ Reported Appendix IV: CFO Act Agencies’ Reported
Estimated Monetary-Loss Improper Payments
Estimated Monetary-Loss Improper
and Related Recovery Activities for Fiscal Year
2022
Payments and Related Recovery Activities
for Fiscal Year 2022
Table 8 shows the recovery activities reported by the Chief Financial
Officers Act of 1990 (CFO Act) agencies with estimated monetary-loss
improper payments for fiscal year 2022.
Table 8: Recovery Activities for Chief Financial Officers Act Agencies That Reported Estimated Monetary-Loss Improper
Payments for Fiscal Year 2022
Estimated monetary-loss
amount (dollars in
CFO Act agencya millions) Recovery activities
U.S. Agency for International Development 0.2 • Legal/judgment collection
• Mailed/electronic notice
• Treasury’s reclamation process
Department of Agriculture 638.6 • Contract suspension
• Implementation of Department of the Treasury’s
Invoice Processing Platform (IPP) payment off-set
• In-person collection
• Legal/judgment collection
• Mailed/electronic notice
• Treasury’s reclamation process
Department of Commerce 3.7 • Contract suspension
• In-person collection
• Legal/judgment collection
• Mailed/electronic notice
Department of Defense 664.4 • Mailed/electronic notice
Department of Education 368.1 • IPP payment off-set
• Legal/judgment collection
• Mailed/electronic notice
• Treasury’s reclamation process
Department of Health and Human 129,930.7 • Legal/judgment collection
Services • Mailed/electronic notice
• Treasury’s reclamation process
Department of Homeland Security 52.9 • Mailed/electronic notice
• Treasury’s reclamation process
Department of Labor 17,897.2 • Treasury’s reclamation process
Department of Transportation 239.4 • Mailed/electronic notice
Department of the Treasury 25,967.3 • Contract suspension
• IPP payment off-set
• Legal/judgment collection
• Mailed/electronic notice
• Treasury’s reclamation process
Page 38 GAO-23-106285 Improper Payments
Appendix IV: CFO Act Agencies’ Reported
Estimated Monetary-Loss Improper Payments
and Related Recovery Activities for Fiscal Year
2022
Estimated monetary-loss
amount (dollars in
CFO Act agencya millions) Recovery activities
Department Veterans Affairs 1,397.0 • IPP payment off-set
• Mailed/electronic notice
• Treasury’s reclamation process
Office of Personnel Management 244.7 • Legal/judgment collection
• Mailed/electronic notice
• Treasury’s reclamation process
Small Business Administration 16,435.0 • Mailed/electronic notice
Social Security Administration 6,004.8 • In-person collection
• Legal/judgment collection
• Mailed/electronic notice
• Treasury’s reclamation process
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106285
Note: The highlighted agencies have programs with monetary loss of $100 million or more annually.
a
The Department of Energy, Department of the Interior, Department of Justice, Environmental
Protection Agency, General Services Administration, Department of Housing and Urban
Development, National Aeronautics and Space Administration, National Science Foundation, U.S.
Nuclear Regulatory Commission, and Department of State did not report estimated monetary-loss
improper payments for fiscal year 2022.
Page 39 GAO-23-106285 Improper Payments
Appendix V: Matters for Congressional Appendix V: Matters for Congressional
Consideration to Improve Improper Payment
Reporting
Consideration to Improve Improper Payment
Reporting
Table 9 lists the 12 matters for congressional consideration as a result of
our COVID-19 work.
Table 9: Open Matters for Congressional Consideration Related to COVID-19 and Improper Payments
Product number Product title Matter for consideration
GAO-21-191 COVID-19: Urgent Actions Needed to To hold agencies accountable and increase transparency, Congress
Better Ensure an Effective Federal should consider, in any future legislation appropriating COVID-19
Response relief funds, designating all executive agency programs and
activities making more than $100 million in payments from COVID-
19 relief funds as “susceptible to significant improper payments” for
purposes of 31 U.S.C § 3352.
GAO-22-105397 COVID-19: Current and Future Federal Congress should consider providing the Department of Health and
Preparedness Requires Fixes to Improve Human Services the authority to require states to report the data
Health Data and Address Improper necessary for the Secretary to estimate and report on improper
Payments payments for the Temporary Assistance for Needy Families program
in accordance with 31 U.S.C. § 3352.
GAO-22-105715 Emergency Relief Funds: Significant Congress should pass legislation requiring the Office of
Improvements Are Needed to Ensure Management and Budget (OMB) to provide guidance for agencies to
Transparency and Accountability for develop plans for internal control that would then immediately be
COVID-19 and Beyond ready for use in, or adaptation for, future emergencies or crises and
requiring agencies to report these internal control plans to OMB and
Congress.
GAO-22-105715 Emergency Relief Funds: Significant Congress should amend the Payment Integrity Information Act of
Improvements Are Needed to Ensure 2019 (PIIA) to designate all new federal programs making more than
Transparency and Accountability for $100 million in payments in any one fiscal year as “susceptible to
COVID-19 and Beyond significant improper payments” for their initial years of operation.
GAO-22-105715 Emergency Relief Funds: Significant Congress should amend PIIA to reinstate the requirement that
Improvements Are Needed to Ensure agencies report on their antifraud controls and fraud risk
Transparency and Accountability for management efforts in their annual financial reports.
COVID-19 and Beyond
GAO-22-105715 Emergency Relief Funds: Significant Congress should establish a permanent analytics center of
Improvements Are Needed to Ensure excellence to aid the oversight community in identifying improper
Transparency and Accountability for payments and fraud.
COVID-19 and Beyond
GAO-22-105715 Emergency Relief Funds: Significant Congress should clarify that (1) chief financial officers (CFO) at
Improvements Are Needed to Ensure Chief Financial Officers Act agencies have oversight responsibility
Transparency and Accountability for for internal controls over financial reporting and key financial
COVID-19 and Beyond management information that includes spending data and improper
payment information; and (2) executive agency internal control
assessment, reporting, and audit requirements for key financial
management information, discussed in an existing matter for
congressional consideration in our August 2020 report, include
internal controls over spending data and improper payment
information.
Page 40 GAO-23-106285 Improper Payments
Appendix V: Matters for Congressional
Consideration to Improve Improper Payment
Reporting
Product number Product title Matter for consideration
GAO-22-105715 Emergency Relief Funds: Significant Congress should require agency CFOs to (1) submit a statement in
Improvements Are Needed to Ensure agencies’ annual financial reports certifying the reliability of improper
Transparency and Accountability for payments risk assessments and the validity of improper payment
COVID-19 and Beyond estimates, and describing the actions of the CFO to monitor the
development and implementation of any corrective action plans; and
(2) approve any methodology that is not designed to produce a
statistically valid estimate.
GAO-22-105715 Emergency Relief Funds: Significant Congress should consider legislation to require improper payment
Improvements Are Needed to Ensure information required to be reported under PIIA to be included in
Transparency and Accountability for agencies’ annual financial reports.
COVID-19 and Beyond
GAO-22-105715 Emergency Relief Funds: Significant Congress should amend the DATA Act to extend the previous
Improvements Are Needed to Ensure requirement for agency inspectors general to review the
Transparency and Accountability for completeness, timeliness, quality, and accuracy of their respective
COVID-19 and Beyond agency data submissions on a periodic basis.
GAO-22-105715 Emergency Relief Funds: Significant Congress should amend the DATA Act to clarify the responsibilities
Improvements Are Needed to Ensure and authorities of OMB and Department of the Treasury for ensuring
Transparency and Accountability for the quality of data available on USAspending.gov.
COVID-19 and Beyond
GAO-22-105715 Emergency Relief Funds: Significant Congress should amend the Social Security Act to accelerate and
Improvements Are Needed to Ensure make permanent the requirement for the Social Security
Transparency and Accountability for Administration to share its full death data with the Department of the
COVID-19 and Beyond Treasury’s Do Not Pay working system.
Source: GAO. | GAO-23-106285
Page 41 GAO-23-106285 Improper Payments
Appendix VI: Matters for Congressional
Appendix VI: Matters for Congressional
Consideration to Improve Federal Financial
Consideration to Improve Federal Financial
Management and Reduce Improper Payments
Management and Reduce Improper
Payments
In August 2020, we made eight matters for congressional consideration to
improve federal financial management and reduce improper payments. 1
Specifically:
1. Congress should consider legislation to require each Chief Financial
Officer (CFO) at a Chief Financial Officers Act of 1990 (CFO Act)
agency to oversee and provide leadership for all of the responsibilities
necessary to effectively carry out federal financial management
activities, including the formulation and financial execution of the
budget, planning and performance, risk management, internal control,
financial systems, and accounting.
2. Congress should consider legislation to require deputy CFOs in CFO
Act agencies to have defined responsibilities consistent with the
breadth of those of the agency CFOs.
3. Congress should consider legislation to require the Director of the
Office of Management and Budget (OMB) to prepare and submit to
the appropriate committees of Congress a government-wide 4-year
financial management plan (with timing to match the Government
Performance and Results Act reporting requirements) and an annual
financial management status report.
a. The plan should include actions for improving financial
management systems, strengthening the federal financial
management workforce, and better linking performance and cost
information for decision-making.
b. The plan should be developed in consultation with the CFO
Council, the Chief Information Officers Council, the Chief Data
Officer Council, the Chief Acquisition Officers Council, Council of
the Inspectors General on Integrity and Efficiency, GAO, and other
appropriate financial management experts.
4. Congress should consider legislation to require each CFO at a CFO
Act agency, in consultation with financial management and other
appropriate experts, to prepare an agency plan to implement the 4-
year government-wide financial management plan prepared by OMB.
5. Congress should consider legislation to require the Director of OMB to
prepare comprehensive financial management performance-based
metrics and use these metrics to evaluate the financial management
performance of executive agencies. The metrics should be included in
1GAO, Federal Financial Management: Substantial Progress Made since Enactment of
the 1990 CFO Act; Refinements Would Yield Added Benefits, GAO-20-566 (Washington,
D.C.: Aug. 6, 2020).
Page 42 GAO-23-106285 Improper Payments
Appendix VI: Matters for Congressional
Consideration to Improve Federal Financial
Management and Reduce Improper Payments
the government-wide and agency-level financial management plans,
and agencies’ performance against the metrics should be reported in
the annual financial management status reports.
6. Congress should consider legislation to require the head of each
executive agency to identify, and if necessary develop, the key
financial management information, in addition to financial statements,
needed for effective financial management and decision-making.
7. Congress should consider legislation to require the head of each
executive agency to annually assess and separately report their
conclusion on the effectiveness of internal controls of the agency over
financial reporting and other key financial management information.
8. Congress should consider legislation to require auditors, as part of
each financial statement audit of an executive agency, to test and
report on internal control over financial reporting and other key
financial management information.
Page 43 GAO-23-106285 Improper Payments
Appendix VII: Open Priority Appendix VII: Open Priority Recommendations
for Agencies That Reported Improper Payment
Recommendations for Agencies That
Estimates for Fiscal Year 2022
Reported Improper Payment Estimates for
Fiscal Year 2022
Table 10 provides a list of the 37 open priority recommendations related
to payment integrity for agencies that reported improper payments for
fiscal year 2022.
Table 10: Open Improper Payment Priority Recommendations to Agencies That Reported Improper Payment Estimates for
Fiscal Year 2022
Report number Recommendations to Department of Agriculture
GAO-22-104259 The Administrator of the Farm Service Agency (FSA) should issue guidance directing the agency to assess
risk characteristics and take a more complete risk-based approach in selecting samples for future
compliance reviews of supplemental assistance programs. This approach could include focusing on farming
operations that received substantially large payments and new customers for which FSA does not have
other information to corroborate eligibility for program participation.
GAO-13-741 To further improve agency controls that help prevent payments to participants whose incomes exceed
eligibility limits, the Secretary of Agriculture should direct the Administrator of the Farm Service Agency to
implement a process to verify that accountants’ and attorneys’ statements accurately reflect participants’
incomes as reported on income tax returns and supporting documentation or other equivalent documents.
Report number Recommendations to Department of Defense (DOD)
GAO-18-553 The Secretary of Defense should ensure that the Director of the Defense Security Cooperation Agency
takes steps to work with the Defense Finance and Accounting Service—the Defense Security Cooperation
Agency’s financial service provider—and other DOD components, as appropriate, to improve the reliability
of the data that the Defense Security Cooperation Agency obtains on all DOD components’ use of Foreign
Military Sales administrative funds, including actual execution data, at an appropriate level of detail, such as
by object class.
GAO-18-553 The Secretary of Defense should ensure that the Director of the Defense Security Cooperation Agency
takes steps to work with the Defense Finance and Accounting Service—the Defense Security Cooperation
Agency’s financial service provider—and other DOD components, as appropriate, to improve the reliability
of the data that the Defense Security Cooperation Agency obtains on all DOD components’ use of contract
administration services funds, including actual execution data, at an appropriate level of detail, such as by
object class.
GAO-15-269 The Secretary of Defense should direct the Assistant Secretary of Defense for Health Affairs to implement a
more comprehensive TRICARE improper payment measurement methodology that includes medical record
reviews, as done in other parts of its existing post-payment claims review programs.
GAO-15-269 Once a more comprehensive improper payment methodology is implemented, the Secretary of Defense
should direct the Assistant Secretary of Defense for Health Affairs to develop more robust corrective action
plans that address underlying causes of improper payments, as determined by the medical record reviews.
GAO-13-227 The Secretary of Defense should direct the Under Secretary of Defense (Comptroller) to establish and
implement key quality assurance procedures, such as reconciliations, to ensure the completeness and
accuracy of the sampled populations.
Report number Recommendations to Department of Health and Human Services (HHS)
GAO-21-98 The Administrator of Centers for Medicare & Medicaid Services (CMS) should collect and document
complete and consistent provider-specific information about Medicaid payments to providers, including new
state-directed managed care payments, and states’ sources of funding for the nonfederal share of these
payments.
GAO-19-519 The Director of the Office of Head Start should perform a fraud risk assessment for the Head Start program,
to include assessing the likelihood and impact of fraud risks it faces.
Page 44 GAO-23-106285 Improper Payments
Appendix VII: Open Priority Recommendations
for Agencies That Reported Improper Payment
Estimates for Fiscal Year 2022
GAO-19-277 The Administrator of CMS should institute a process to routinely assess, and take steps to ensure, as
appropriate, that Medicare and Medicaid documentation requirements are necessary and effective at
demonstrating compliance with coverage policies while appropriately addressing program risks.
GAO-19-112 The Secretary of HHS should revise HHS’s procedures for conducting improper payment risk assessments
to help ensure that all programs and activities are assessed for susceptibility to significant improper
payments at least once every 3 years, as required by the Improper Payments Information Act of 2002, as
amended.
GAO-18-564 The Administrator of CMS should complete a comprehensive, national risk assessment and take steps, as
needed, to assure that resources to oversee expenditures reported by states are adequate and allocated
based on areas of highest risk.
GAO-16-76 As CMS continues to implement and refine the contract-level risk adjustment data validation (RADV) audit
process to improve the efficiency and effectiveness of reducing and recovering improper payments, the
Administrator should enhance the timeliness of CMS’s contract-level RADV process by taking actions such
as the following: (1) closely aligning the time frames in CMS’s contract-level RADV audits with those of the
national RADV audits the agency uses to estimate the Medicare Advantage (MA) improper payment rate;
(2) reducing the time between notifying MA organizations of contract audit selection and notifying them
about the beneficiaries and diagnoses that will be audited; (3) improving the reliability and performance of
the agency’s process for transferring medical records from MA organizations, including assessing the
feasibility of updating Electronic Submission of Medical Documentation for use in transferring medical
records in contract-level RADV audits; and (4) requiring that CMS contract-level RADV auditors complete
their medical record reviews within a specific number of days comparable to other medical record review
time frames in the Medicare program.
GAO-16-568 To ensure efficient use of federal resources, the Administrator of CMS should account for Medicaid
payments a hospital has received that offset uncompensated care (UC) costs when determining hospital
UC costs for the purposes of making Medicare UC payments to individual hospitals.
GAO-16-394 In order to better ensure proper Medicare payments and protect Medicare funds, CMS should seek
legislative authority to allow the recovery auditors to conduct prepayment claim reviews.
GAO-16-108 To promote consistency in the distribution of supplemental payments among states and with CMS policy,
the Administrator of CMS should issue written guidance clarifying its policy that payments should not be
made contingent on the availability of local funding.
GAO-14-571 To ensure that MA encounter data are of sufficient quality for their intended purposes, the Administrator of
CMS should complete all the steps necessary to validate the data, including performing statistical analyses,
reviewing medical records, and providing Medicare Advantage Organizations with summary reports on
CMS’s findings, before using the data to risk adjust payments or for other intended purposes.
GAO-13-287 To reduce the incentive for dialysis facilities to restrict their service provision to avoid reaching the low-
volume payment adjustment (LVPA) treatment threshold, the Administrator of CMS should consider
revisions such as changing the LVPA to a tiered adjustment.
GAO-12-966 In order to improve CMS’s ability to identify self-referred advanced imaging services and help CMS address
the increases in these services, the Administrator of CMS should insert a self-referral flag on its Medicare
Part B claims form and require providers to indicate whether the advanced imaging services for which a
provider bills Medicare are self-referred or not.
GAO-12-966 In order to improve CMS’s ability to identify self-referred advanced imaging services and help CMS address
the increases in these services, the Administrator of CMS should determine and implement a payment
reduction for self-referred advanced imaging services to recognize efficiencies when the same provider
refers and performs a service.
GAO-12-966 In order to improve CMS’s ability to identify self-referred advanced imaging services and help CMS address
the increases in these services, the Administrator of CMS should determine and implement an approach to
ensure the appropriateness of advanced imaging services referred by self-referring providers.
Page 45 GAO-23-106285 Improper Payments
Appendix VII: Open Priority Recommendations
for Agencies That Reported Improper Payment
Estimates for Fiscal Year 2022
GAO-12-51 To help ensure appropriate payments to MA plans, the Administrator of CMS should take steps to improve
the accuracy of the adjustment made for differences in diagnostic coding practices between MA and
Medicare Fee-for-Service. Such steps could include, for example, accounting for additional beneficiary
characteristics, including the most current data available, identifying and accounting for all years of coding
differences that could affect the payment year for which an adjustment is made, and incorporating the trend
of the impact of coding differences on risk scores.
Report number Recommendations to Department of Homeland Security
GAO-20-604 The Administrator of the Federal Emergency Management Agency should designate one entity as the lead
entity with responsibility for providing oversight of agency-wide efforts to manage fraud risks to Public
Assistance emergency work grants, including managing the fraud risk assessment process, consistent with
leading practices.
GAO-20-182 The Commissioner of Customs and Border Protection should ensure that the Office of Trade turns the claim
selection feature in the Automated Commercial Environment (ACE) back on and finalizes and implements
procedures to target claims for review that were accepted into ACE during the period in which the selection
feature was disabled.
Report number Recommendations to Department of Labor
GAO-22-105051 The Secretary of Labor should examine the suitability of existing fraud controls in the unemployment
insurance program and prioritize residual fraud risks.
GAO-18-486 The Assistant Secretary of Labor’s Employment and Training Administration should provide states with
information about its determination that the use of state formal warning policies is no longer permissible
under federal law.
GAO-18-486 The Assistant Secretary of Labor’s Employment and Training Administration should clarify information on
work search verification requirements in its revised Benefit Accuracy Measurement procedures. The revised
procedures should include an explanation of what Labor considers to be sufficient verification of claimants’
work search activities.
Report number Recommendations to Department of the Treasury
GAO-22-105291 The Secretary of the Treasury should design and implement processes, such as post-payment reviews or
recovery audits, to help ensure timely identification and recovery of overpayments made by grantees to
households, landlords, or utility providers in the Emergency Rental Assistance programs.
GAO-20-174 The Commissioner of Internal Revenue should designate a dedicated entity to provide oversight of agency-
wide efforts to detect, prevent, and resolve business identity theft (business IDT) refund fraud, consistent
with leading practices. This may involve designating one business unit as a lead entity, or leveraging
cooperative relationships between business units to establish a business IDT leadership team. This entity
should have defined responsibilities and authority for managing fraud risk.
GAO-18-544 The Commissioner of Internal Revenue should implement the most cost-effective method to digitize
information provided by taxpayers who file returns on paper.
GAO-18-544 Based on its evaluation of the Return Review Program (RRP), the Commissioner of Internal Revenue
should expand RRP to support identified activities.
GAO-18-418 In accordance with the plan developed for implementing changes to its online authentication programs, the
Commissioner of Internal Revenue should implement improvements to the Internal Revenue Service’s
systems to fully implement the National Institute of Standards and Technology’s new guidance.
Report number Recommendations to Small Business Administration (SBA)
GAO-21-589 The Associate Administrator of SBA’s Office of Disaster Assistance should develop a comprehensive
strategy for communicating with potential and actual program applicants in the event of a disaster. Such a
strategy should provide guidelines for the types of information and timing of information to be provided to
program participants throughout a disaster. The types of information to be addressed in the strategy could
include processing steps and time frames applicants might experience through different stages of the loan
process.
Page 46 GAO-23-106285 Improper Payments
Appendix VII: Open Priority Recommendations
for Agencies That Reported Improper Payment
Estimates for Fiscal Year 2022
GAO-21-387 The Administrator of SBA should develop a strategy that outlines specific actions to address assessed fraud
risks in the Economic Injury Disaster Loan program on a continuous basis.
GAO-21-387 The Administrator of the SBA should develop a strategy that outlines specific actions to monitor and
manage fraud risks in Paycheck Protection Program on a continuous basis.
Report Number Recommendations to Social Security Administration (SSA)
GAO-16-331 To ensure effective and appropriate recovery of disability insurance (DI) overpayments and administration
of penalties and sanctions, the Acting Commissioner of SSA should adjust the minimum withholding rate to
10 percent of monthly DI benefits to allow quicker recovery of debt.
GAO-15-531 To improve SSA’s ability to detect, prevent, and recover potential DI benefit overpayments due to the
concurrent receipt of Federal Employees’ Compensation Act (FECA) benefits, the Commissioner of SSA
should strengthen internal controls designed to prevent DI overpayments due to the concurrent receipt of
FECA benefits by implementing the alternative that provides the greatest net benefits.
Source: GAO. | GAO-23-106285
Page 47 GAO-23-106285 Improper Payments
Appendix VIII: GAO Contact and Staff
Appendix VIII: GAO Contact and Staff
Acknowledgments
Acknowledgments
M. Hannah Padilla, (202) 512-5683 or padillah@gao.gov
GAO Contact
In addition to the contact named above, Daniel Flavin (Assistant Director),
Staff Jenny Li (Auditor in Charge), Edgar Fletes, Seth Brewington, Patrick
Acknowledgments Frey, Jason Kelly, Matthew Valenta, and Teressa Gardner made key
contributions to this report.
Page 48 GAO-23-106285 Improper Payments
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