GAO-23-106585: Improper Payments: Programs Reporting Reductions Had Taken Corrective Actions That Shared Common Features
Summary
GAO-23-106585, a June 2023 Government Accountability Office report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives, on programs reporting reductions in estimated improper payment rates. GAO identified 19 programs across eight agencies with reported reductions from fiscal year 2017 to fiscal year 2022, ranging from 0.1 to 85.6 net percentage points. The reported estimates for the 19 programs declined from approximately $55.0 billion for fiscal year 2017 to $44.5 billion for fiscal year 2022. The table includes Small Business Administration programs such as Disaster Loan Disbursements, listed at 13.7 percent and 3.1 percent. Agencies attributed reductions to corrective actions in two categories: accountability and internal collaboration, and technology, tools and training targeted to root causes.
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United States Government Accountability Office
Report to the Subcommittee on
Legislative Branch, Committee on
Appropriations, House of
Representatives
IMPROPER
June 2023
PAYMENTS
Programs Reporting
Reductions Had
Taken Corrective
Actions That Shared
Common Features
GAO-23-106585
June 2023
IMPROPER PAYMENTS
Programs Reporting Reductions Had Taken
Corrective Actions That Shared Common Features
Highlights of GAO-23-106585, 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 Agencies have reported reductions in estimated improper payment rates for
should not have been made or that several programs based on fiscal year 2017 compared to fiscal year 2022. GAO
were made in incorrect amounts— identified 19 programs across eight agencies with reported reductions, according
are a long-standing significant to fiscal year 2022 reporting. The reduction in estimated improper payment rates
problem in the federal government. ranged from 0.1 to 85.6 net percentage points. Of the five programs with the
Since fiscal year 2003, cumulative largest reported reductions, four were Department of Veterans Affairs (VA)
executive agency improper payment programs. The reported improper payment estimates for the 19 programs
estimates have totaled almost $2.4 declined from a total of approximately $55.0 billion for fiscal year 2017 to $44.5
trillion, including $247 billion for
billion for fiscal year 2022.
fiscal year 2022.
House Report 117-389, which Programs with Reductions in Estimated Improper Payment Rates Reported, FY 2017 and FY
2022
accompanied the Legislative Branch
Change in rate
Appropriations Act, 2023, includes a FY 2017 ratea FY 2022 rate (net percentage
provision for GAO to provide Agency Program (percentage) (percentage) points)
Corporation for AmeriCorps State and National 10.8 8.4 -2.4
quarterly reports on its ongoing National and
oversight of improper payments. Community
Service
This report examines programs with Department of Food and Nutrition Service’s Special 5.0 1.8 -3.2
Agriculture Supplemental Nutrition Program for
reported reductions in estimated Women, Infants, and Children Total
improper payment rates since fiscal Program
Department of Department of Defense Travel Pay 5.0 4.4 -0.6
year 2017. This report includes Defense
information about actions that Department of Administration for Children and Families 4.1 4.0 -0.2
agencies credit with helping them to Health and Child Care and Development Fund
achieve the reductions, common Human Services
Department of Centers for Medicare & Medicaid 9.5 7.5 -2.1
features of these actions, and the Health and Services (CMS) Medicare Fee-for-
key takeaways or lessons learned Human Services Serviceb
Department of CMS Medicare Prescription Drug 1.7 1.5 -0.1
that were identified by the agencies. Health and Benefit (Part D)
Human Services
GAO analyzed agencies’ improper Department of Beneficiary Travelb 25.1 7.9 -17.2
payment estimates reported on Veterans Affairs
Department of Communications, Utilities, and Other 24.4 2.7 -21.7
PaymentAccuracy.gov, as well as Veterans Affairs Rentb
information reported in agency Department of Medical Care Contracts and 16.6 7.5 -9.1
financial reports, and agency Veterans Affairs Agreementsb
responses. Department of
Veterans Affairs
Purchased Long Term Services and
Supportsb
100.0 47.5 -52.5
Department of Supplies and Materialsb 18.8 4.0 -14.7
Veterans Affairs
Department of Veterans Affairs Community Careb 93.4 7.8 -85.6
Veterans Affairs
Federal Universal Service Fund-Lifelineb 21.9 6.1 -15.8
Communications
Commission
Federal Universal Service Fund-Schools & 4.3 3.7 -0.6
Communications Libraries
Commission
Small Business 7(a) Guarantee Approvals 1.3 1.0 -0.3
Administration
Small Business 7(a) Guarantee Purchases 4.3 4.2 -0.1
Administration
Small Business Disaster Loan Disbursementsb 13.7 3.1 -10.6
Administration
Social Security Old-Age, Survivors, and Disability 0.3 0.2 -0.1
Administration Insurance
Social Security Supplemental Security Income 8.8 8.7 -0.1
Administration
United States Government Accountability Office
Legend: FY = fiscal year
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106585
Notes: Changes in rates may be attributable to a number of different causes, including agency
corrective actions, policy changes, and the uncertainty of the estimation processes. Listed changes in
rates may not equal the differences between the listed FY 2017 and FY 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.
b
The confidence intervals for this program’s reported FY 2017 and FY 2022 estimates did not overlap,
which serves as evidence that the reported reduction in estimated improper payment rate was likely
not due to variability arising from the estimation process.
Office of Management and Budget guidance directs agencies to analyze the root
causes of improper payments and implement corrective actions to reduce them.
Agencies attributed reductions in estimated improper payment rates to program-
specific corrective actions as well as broader reduction efforts. These actions and
efforts fell into two categories. The first category—establishing accountability and
facilitating internal collaboration—included examples such as the VA Veterans
Health Administration’s establishment of program-level senior accountable
officials and a payment integrity team. The second category—providing
technology, tools, and training targeted to root causes—included examples such
as Federal Communications Commission’s (FCC) launch of the National Verifier
system, which uses a combination of automated and manual processes to verify
Lifeline program eligibility.
Agencies also described key takeaways or lessons learned as a result of their
reduction efforts. For example, VA described the importance of effective
management and of ensuring that dedicated personnel provide oversight within
both the VA Chief Financial Officer’s (CFO) and Veterans Health Administration
CFO’s offices. The Corporation for National and Community Service noted the
importance of targeted agency-wide actions and the need for strong
communication. Department of Defense officials described the importance of
training, collaboration, communication, and feedback. FCC cited the importance
of analyzing root causes on a quarterly basis. The Small Business Administration
described the importance of regular meetings with program offices to discuss
common issues and solutions. These examples underscore the importance of
effective corrective actions to address root causes of improper payments.
View GAO-23-106585. For more information,
contact M. Hannah Padilla at (202) 512-5683
or padillah@gao.gov.
United States Government Accountability Office
Contents
Letter 1
Background 4
Agencies Attributed Improper Payment Reductions to Various
Corrective Actions That Shared Some Common Features, and
Identified Key Takeaways 7
Agency Comments 20
Appendix I GAO Contact and Staff Acknowledgments 22
Table
Table 1: Programs with Reductions in Estimated Improper
Payment Rates Reported, Fiscal Years (FY) 2017 and
2022 7
Figures
Figure 1: Government-Wide Annual Totals of Reported Improper
Payment Estimates, Fiscal Years 2003–2022 2
Figure 2: Key Steps Related to Analyzing Improper Payments and
Major Components of Corrective Action Plans 6
Page i GAO-23-106585 Improper Payments
Abbreviations
AFR agency financial report
BCAP Beneficiary and Contributor Audit Program
CCDF Child Care and Development Fund
CFO chief financial officer
CMS Centers for Medicare & Medicaid Services
CNCS Corporation for National and Community Service
DOD Department of Defense
EBT electronic benefit transfer
FAR Federal Acquisition Regulation
FCC Federal Communications Commission
FFS Medicare Fee-for-Service
FNS Food and Nutrition Service
HHS Department of Health and Human Services
IG inspector general
IPERA Improper Payments Elimination and Recovery Act of 2010
NSCHC National Service Criminal History Checks
OASDI Old Age, Survivors, and Disability Insurance
OMB Office of Management and Budget
PIE Payroll Information Exchange
PIIA Payment Integrity Information Act of 2019
SBA Small Business Administration
SSA Social Security Administration
USAC Universal Service Administrative Company
USDA Department of Agriculture
USF Universal Service Fund
WIC Special Supplemental Nutrition Program for Women,
Infants, and Children
VA Department of Veterans Affairs
VHA Veterans Health Administration
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Page ii GAO-23-106585 Improper Payments
Letter
441 G St. N.W.
Washington, DC 20548
June 30, 2023
The Honorable Mark E. Amodei
Chairman
The Honorable Adriano Espaillat
Ranking Member
Subcommittee on Legislative Branch
Committee on Appropriations
House of Representatives
Improper payments are a long-standing, significant problem in the federal
government. 1 For fiscal year 2022, estimates of improper payments
totaled about $247 billion government-wide. 2 While this total represented
a decrease of about $34 billion from the prior fiscal year, it was an
increase of more than $40 billion from fiscal year 2020. 3 Since fiscal year
2003, when federal executive agencies were required by law to begin
annually reporting estimated improper payments for certain programs and
activities, cumulative estimates have totaled about $2.4 trillion. 4 Figure 1
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). Executive agency estimates of
improper payments also treat as improper any payments whose propriety cannot be
determined due to lacking or insufficient documentation. 31 U.S.C. § 3352(c)(2).
2The approximately $247 billion total in estimated improper payments is attributable to 82
federal programs or activities across 18 agencies. Notably, several agencies with large
programs that have been identified as susceptible to significant improper payments have
not reported estimates as required. These programs include the Department of Labor’s
Pandemic Unemployment Assistance program, the Department of Agriculture’s
Supplemental Nutrition Assistance Program, and the Department of Health and Human
Services’ Temporary Assistance for Needy Families program.
3Agencies report improper payment information at www.PaymentAccuracy.gov, a U.S.
government website managed by the Office of Management and Budget. The website
includes information about current and historical improper payment rates (i.e., agency-
reported amounts as a percentage of outlays) and amounts of estimated improper
payments. Prior-year improper payment estimates have not been adjusted for inflation.
4Enacted in November 2002, the Improper Payments Information Act of 2002 required
federal executive agencies to begin reporting estimated improper payments for certain
programs and activities. Pub. L. No. 107-300, 116 Stat. 2350. Statutes that govern
improper payment reporting define “executive agency” as a department, or agency, or an
instrumentality in the executive branch of the U.S. government. 31 U.S.C. § 102.
Page 1 GAO-23-106585 Improper Payments
summarizes aggregated improper payment estimates from fiscal year
2003 through fiscal year 2022.
Figure 1: Government-Wide Annual Totals of Reported Improper Payment Estimates, Fiscal Years 2003–2022
Note: Fiscal year amounts equal the sum of agencies’ reported improper payment estimates for each
fiscal year.
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. 5
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.
5Our 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 2 GAO-23-106585 Improper Payments
While more work needs to be done to address this government-wide
material weakness in internal control, we have noted some
improvements. For example, in August 2020, as part of our report on
progress made in federal financial management since enactment of the
Chief Financial Officers Act of 1990, we noted that agencies have made
progress in estimating improper payments and implementing corrective
actions to reduce them. 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 is our second report issued under this provision. 7
This report examines programs with reported reductions in estimated
improper payment rates since fiscal year 2017, including actions that
agencies credit with helping them achieve reductions, common features
of these actions, and agencies’ related key takeaways or lessons learned.
To address our objective, we analyzed PaymentAccuracy.gov data from
fiscal year 2017 through fiscal year 2022. We identified 35 programs for
which agencies had reported improper payment estimates in each fiscal
year over that period. For those programs, we then compared fiscal year
2017 against fiscal year 2022 and identified 19 programs with reductions
in reported estimated improper payment rates. 8 For those 19 programs
identified, we asked agencies to describe the actions to which they
attributed the reported reductions. To identify common features
associated with agencies’ reduction efforts, we compared responses the
agencies provided and reviewed improper payment information agencies
reported in agency financial reports (AFR), on PaymentAccuracy.gov, and
in annual inspector general (IG) reports on agency compliance under the
Payment Integrity Information Act of 2019 (PIIA) and the Improper
6GAO, Federal Financial Management: Substantial Progress Made since Enactment of
the 1990 CFO Act; Refinements Would Yield Additional Benefits, GAO-20-566
(Washington, D.C.: Aug. 6, 2020).
7Our first report was issued in March 2023. GAO, Improper Payments: Fiscal Year 2022
Estimates and Opportunities for Improvement, GAO-23-106285 (Washington, D.C.: Mar.
29, 2023).
8The improper payment rates and totals in this report are subject to uncertainty, meaning
the actual amounts may differ from the reported estimates. Due to this uncertainty, it is
possible that one or more agencies have reported reductions in programs’ estimated
improper payment rates even though the actual incidence of improper payments in these
programs either remained unchanged or increased over the period we reviewed.
Page 3 GAO-23-106585 Improper Payments
Payments Elimination and Recovery Act of 2010 (IPERA). 9 We also
asked agencies to describe any key takeaways or lessons learned.
We conducted this performance audit from January 2023 to June 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.
Although there have been a number of changes in the law regarding
Background executive agency improper payments over the last 2 decades—most
recently with PIIA in March 2020—the core framework for managing
improper payments has remained consistent over that time. Specifically,
executive branch agencies are required to periodically assess, estimate,
analyze, and report on improper payments in the programs they
administer.
PIIA and related Office of Management and Budget (OMB) guidance
require executive branch agencies to take various steps regarding
improper payments, including
1. reviewing periodically all programs and activities above $10 million in
annual outlays and identifying those that may be susceptible to
significant improper payments (commonly referred to as a risk
assessment);
2. developing improper payment estimates for those programs and
activities that agency risk assessments, OMB, or statutes identify as
being susceptible to significant improper payments;
3. analyzing the root causes of improper payments and developing
corrective actions to reduce them; and
9IPERA, Pub. L. No. 111-204, 124 Stat. 2224, established a requirement for agency IGs to
report annually on their respective agencies’ compliance with specified criteria. In March
2020, PIIA repealed IPERA and the other reporting-related improper payment statutes and
enacted substantially similar provisions, including those related to IGs’ reporting on
agency compliance with criteria and the compliance criteria themselves. Pub. L. No. 116-
117, 134 Stat. 113 (codified at 31 U.S.C. §§ 3351-58).
Page 4 GAO-23-106585 Improper Payments
4. reporting on the results of addressing the foregoing requirements. 10
Figure 2 illustrates these steps, as well as the major components of
analyzing root causes of improper payments and developing corrective
action plans to remediate them. PIIA also requires executive branch
agencies’ IGs to annually determine and report on whether their
respective agencies complied with six statutory criteria. Programs that
OMB designates as high-priority may be subject to additional
requirements related to corrective action plans, reporting, and compliance
reviews. 11
1031 U.S.C. § 3352 and OMB Circular A-123 Appendix C, Requirements for Payment
Integrity Improvement, OMB Memorandum M-21-19 (2021). Under PIIA, improper
payments are considered “significant” if in the preceding fiscal year they may have
exceeded either (1) 1.5 percent of program outlays and $10 million or (2) $100 million
(regardless of the improper payment rate).
11PIIA requires OMB to annually designate a list of high-priority programs for greater
levels of review and oversight. Under PIIA, agencies with high-priority programs are
subject to additional reporting requirements. 31 U.S.C. § 3352(b). OMB has assigned a
high-priority 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.
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. The information provided to OMB includes
actions the program has taken or intends to take to prevent improper payments and
actions to recover monetary loss improper payments.
Page 5 GAO-23-106585 Improper Payments
Figure 2: Key Steps Related to Analyzing Improper Payments and Major Components of Corrective Action Plans
Estimating improper payments and identifying their root causes help to
ensure that agencies develop and implement effective corrective actions
to reduce improper payments. PIIA requires agencies with programs
susceptible to significant improper payments to report a description of the
causes of the improper payments identified, actions that the agency has
planned or taken to correct those causes, and the planned or actual
completion dates of those actions.
OMB Circular A-123 Appendix C, Requirements for Payment Integrity
Improvement, (OMB M-21-19), provides guidance to agencies on their
responsibilities for preventing and reducing improper payments. OMB M-
21-19 directs agencies with programs deemed susceptible to significant
improper payments to implement corrective action plans to address root
causes, and to monitor and measure the effectiveness and progress of
improper payment mitigation strategies and corrective actions.
Page 6 GAO-23-106585 Improper Payments
Agencies Attributed
Improper Payment
Reductions to Various
Corrective Actions
That Shared Some
Common Features,
and Identified Key
Takeaways
Agencies Have Reported We identified 19 programs for which agencies reported reductions in
Reductions in Estimated estimated improper payment rates based on fiscal year 2017 compared to
fiscal year 2022 (see table 1). Of the five programs with the largest
Improper Payment Rates
reported reductions, four were Department of Veterans Affairs programs.
for Several Programs The reductions in estimated improper payment rates ranged from 0.1 to
since Fiscal Year 2017 85.6 net percentage points. The improper payments estimates for the 19
programs declined from a total of approximately $55.0 billion for fiscal
year 2017 to $44.5 billion for fiscal year 2022.
Table 1: Programs with Reductions in Estimated Improper Payment Rates Reported, Fiscal Years (FY) 2017 and 2022
Agency and program FY 2017 FY 2017 ratea FY 2022 FY 2022 rate Change in rate
amount (percentage) amount (percentage) (net
(millions of (millions of percentage
dollars) dollars) points)
Corporation for National and Community Service
AmeriCorps State and National 26.8 10.8 21.5 8.4 -2.4
Department of Agriculture
Food and Nutrition Service’s Special 197.1 5.0 47.8 1.8 -3.2
Supplemental Nutrition Program for Women,
Infants, and Children Total Program
Department of Defense
Department of Defense Travel Pay 263.3 5.0 368.5 4.4 -0.6
Department of Health and Human Services
Administration for Children and Families Child 237.3 4.1 344.7 4.0 -0.2
Care and Development Fund
Centers for Medicare & Medicaid Services 36,208.0 9.5 31,456.7 7.5 -2.1
(CMS) Medicare Fee-for-Serviceb
CMS Medicare Prescription Drug Benefit (Part 1,295.6 1.7 1,361.1 1.5 -0.1
D)
Department of Veterans Affairs
Page 7 GAO-23-106585 Improper Payments
Agency and program FY 2017 FY 2017 ratea FY 2022 FY 2022 rate Change in rate
amount (percentage) amount (percentage) (net
(millions of (millions of percentage
dollars) dollars) points)
Beneficiary Travelb 223.8 25.1 99.1 7.9 -17.2
Communications, Utilities, and Other Rentb 352.7 24.4 49.1 2.7 -21.7
Medical Care Contracts and Agreementsb 157.3 16.6 78.5 7.5 -9.1
Purchased Long Term Services and Supportb 1,890.5 100.0 1,285.5 47.5 -52.5
Supplies and Materialsb 479.8 18.8 132.0 4.0 -14.7
Veterans Affairs Community Careb 5,257.6 93.4 1,363.1 7.8 -85.6
Federal Communications Commission
Universal Service Fund-Lifelineb 336.4 21.9 37.2 6.1 -15.8
Universal Service Fund-Schools & Libraries 103.5 4.3 80.6 3.7 -0.6
Small Business Administration
7(a) Guarantee Approvals 233.9 1.3 298.1 1.0 -0.3
7(a) Guarantee Purchases 28.4 4.3 29.8 4.2 -0.1
Disaster Loan Disbursementsb 123.4 13.7 34.7 3.1 -10.6
Social Security Administration
Old-Age, Survivors, and Disability Insurance 2,578.4 0.3 2,491.0 0.2 -0.1
Supplemental Security Income 5,019.9 8.8 4,906.0 8.7 -0.1
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-23-106585
Notes: This table is based on programs reporting in FY 2022 with estimates reported each year since
FY 2017. Agencies stopped reporting estimates for at least 46 programs from FY 2017 through FY
2022 because the programs fell below the statutory threshold for improper payment reporting and
were therefore no longer considered susceptible to significant improper payments. The table includes
both statistical and nonstatistical estimates of improper payment totals. Unless otherwise noted, we
were unable to determine whether the reportable reductions were attributable to the uncertainty of the
estimation processes or changes in underlying agency conditions. Reductions in estimated improper
payment rates may be due to a variety of causes, including agency corrective actions and changes in
policies. Listed changes in rates may not equal the differences between the listed FY 2017 and FY
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.
b
The confidence intervals for this program’s reported FY 2017 and FY 2022 estimates did not overlap,
which serves as evidence that the reported reduction in estimated improper payment rate was likely
not due to variability arising from the estimation process.
Reductions in the reported improper payment rates over this period may
be attributable to a number of different causes, including agency
corrective actions, policy changes, and variability from the estimation
processes. We reviewed the confidence intervals reported by agencies
for their fiscal year 2017 and fiscal year 2022 estimates. We found that
the variability from the estimation process was unlikely to be a possible
source for the observed reductions in nine of the 19 programs but could
be a possible source for the remaining 10 programs. For the remaining 10
Page 8 GAO-23-106585 Improper Payments
programs, variability in the estimation process may be a possible source
for the observed reductions.
Agencies Attributed As was shown in table 1, the 19 programs with reductions in reported
Reductions in Estimated improper payment rates from fiscal year 2017 through fiscal year 2022
are administered by eight agencies. These agencies attributed their
Improper Payment Rates
reductions in the programs’ estimated improper payment rates to various
to Various Corrective corrective actions. Agencies’ attributions regarding the sources of
Actions reductions are useful for understanding the types of corrective actions
that may lead to reductions in improper payments. However, these
descriptions should not be taken as complete explanations for reductions.
• Corporation for National and Community Service (CNCS). CNCS
officials attributed the reduction in the estimated improper payment
rate for the AmeriCorps State and National program to a reduction in
the incidence of noncompliance with National Service Criminal History
Checks (NSCHC) requirements. 12 These requirements include
checking three sources: the National Sex Offender Registry, certain
state-operated registries or repositories, and a Federal Bureau of
Investigation fingerprint-based system. These checks are a baseline
screening requirement established by law to protect the beneficiaries
of national service and must be completed correctly and on time.
According to CNCS officials, CNCS contracted with a new vendor to
provide criminal history checks compliant with NSCHC requirements,
leading to a reduction in the improper payment rate after 2019.
• Department of Agriculture (USDA). USDA officials attributed the
reduction in the estimated improper payment rate for the Special
Supplemental Nutrition Program for Women, Infants, and Children
(WIC) to states’ implementation of electronic benefit transfer (EBT)
systems. 13 According to USDA officials, EBT provides WIC state
agencies with more accurate and timely data that they can use to
12In September 2020, CNCS changed its operating name to AmeriCorps. The agency’s
legal name remains CNCS. AmeriCorps State and National is a grant program that
provides funds to Tribes, states, territories, and community-based organizations that
leverages members who serve full- or part-time on projects that align with certain priority
areas, including economic opportunity education, healthy futures, and services for
veterans and military families.
13WIC provides supplemental food, nutrition education (e.g., breastfeeding promotion and
support), and health and social service program referrals to low-income pregnant,
breastfeeding, and postpartum women; infants; and children up to age 5 who are found to
be at nutritional risk. USDA’s Food and Nutrition Service oversees WIC at the federal level
and provides grants to state agencies, which in turn provide food benefits and services to
participants through 1,900 local agencies in 10,000 clinic sites.
Page 9 GAO-23-106585 Improper Payments
monitor food costs and identify suspect transactions. USDA’s Food
and Nutrition Service (FNS) initially estimated WIC vendor errors
based on past data that included both paper and EBT errors. As
states implemented EBT systems, paper errors were eliminated as a
source of improper payments, causing WIC’s estimated improper
payment rate to decrease beginning in fiscal year 2019.
• Department of Defense (DOD). DOD officials attributed the reduction
in the estimated improper payment rate for the DOD Travel Pay
program to a department-wide effort to increase collaboration and
internal training. 14 For example, because incorrect, missing, or invalid
receipts were among the top causes of improper payments in the
program, according to DOD officials, the agency trained approving
officials and program users to properly identify receipts prior to
approval for payment. In addition, DOD updated its Defense Travel
System to include a prepayment “audit” feature to determine if
travelers uploaded or attached supporting documentation with their
claims.
• Department of Health and Human Services (HHS). HHS reported
reductions in estimated improper payment rates for three programs:
Medicare Fee-for-Service (FFS), Medicare Part D, and the Child Care
and Development Fund (CCDF). 15
HHS officials attributed the reduction in the estimated improper
payment rates for Medicare FFS and Medicare Part D programs to a
number of mitigation strategies and corrective actions described in
HHS’s AFRs. For Medicare FFS, these included automation—
specifically, the use of automated controls called edits that are
programmed into claims processing—and changes to internal
processes or policies to expand or continue requirements related to
prior authorization for certain high-cost items. For Medicare Part D,
mitigation strategies and corrective actions included training and
outreach related to invalid or incomplete documentation, as well as
14The DOD Travel Pay program issues payments disbursed by the Defense Finance and
Accounting Service, the Army, the Navy, the Air Force, and the Marine Corps to active,
reserve, and National Guard military service members and civilian employees for
temporary and permanent travel and transportation-related expenses.
15Medicare FFS is a federal health insurance program for people aged 65 and older,
people younger than 65 with certain disabilities, and people of all ages with end-stage
renal disease. Medicare Part D is a federal prescription drug benefit program for Medicare
beneficiaries. CCDF is a joint federal and state program, administered by the states, that
provides childcare financial assistance to low-income working families.
Page 10 GAO-23-106585 Improper Payments
audits that help both to educate plan sponsors and to identify, reduce,
and recover improper payments.
HHS officials attributed the reduction in the CCDF estimated improper
payment rate to targeted ongoing technical assistance and training.
For example, federal and state staff conducted joint case reviews.
This allowed HHS to gain insight into states’ error measurement
methodologies and to provide technical assistance to help ensure
consistent reviews.
• Department of Veterans Affairs (VA). VA reported reductions in
estimated improper payment rates for six programs: Beneficiary
Travel; Communications, Utilities, and Other Rent; Medical Care
Contracts and Agreements; Purchased Long Term Services and
Supports; Supplies and Materials; and VA Community Care. 16
VA officials attributed the reduction in the Beneficiary Travel
program’s estimated improper payment rate to implementation of new
software, which, according to VA officials, provided customized and
enhanced tools to streamline claims and automate eligibility
determinations.
VA officials attributed the reductions in the estimated improper
payment rates for the Communications, Utilities, and Other Rent;
Medical Care Contracts and Agreements; and Supplies and Materials
programs to successful remediation of payment errors that were made
due to data entry errors, incorrect payment methods, or payments not
in accordance with contracts.
VA officials attributed the reductions in the estimated improper
payment rates for the Purchased Long Term Services and Support
16VA’s Veterans Health Administration provides a broad range of primary care, specialized
care, and related medical and social support services. The Beneficiary Travel program
provides mileage reimbursement, common carrier, and special transportation services to
eligible veterans and other beneficiaries. The Communications, Utilities, and Other Rent
program funds communications, utility services, and charges for possession and use of
land structures or equipment owned by others. The Medical Care Contracts and
Agreements program includes payments for contracts for research, medical and
educational data or services, and contracted emergency medical services. The Supplies
and Materials program includes items acquired by contract or other forms of purchase that
are ordinarily consumed or expended within 1 year of use. The Purchased Long Term
Services and Supports program provides services for veterans of all ages, including older,
frail, or chronically ill patients; their families; and their caregivers. The VA Community Care
program allows VA to authorize veteran care at community care facilities if needed
services are not available through VA, or when the veteran is unable to travel to a VA
facility.
Page 11 GAO-23-106585 Improper Payments
and VA Community Care programs to elimination of errors related to
contracts that were noncompliant with Federal Acquisition Regulation
(FAR) requirements following enactment of the VA MISSION Act of
2018. 17
• Federal Communications Commission (FCC). FCC reported
reductions in estimated improper payment rates for the Universal
Service Fund (USF) Lifeline and USF Schools and Libraries
programs. 18 FCC officials attributed the reduction in the estimated
improper payment rate for the Lifeline program to the National Verifier
system, which FCC believes reduced enrollment errors and improper
payment rates. National Verifier was deployed across the country over
several years and was fully deployed in 2020. The system aims to
increase program integrity by applying a consistent eligibility review
standard and process for Lifeline enrollments. FCC officials primarily
attributed the reduction in the Schools and Libraries program’s
estimated improper payment rate to the use of open data sets and
other coding capabilities that improved the efficiency of eligibility
validations on invoices.
• Small Business Administration (SBA). SBA reported reductions in
estimated improper payment rates for 7(a) Loan Guarantee
Approvals, 7(a) Loan Guarantee Purchases, and Disaster Loan
Disbursements. 19 SBA officials attributed the reductions to SBA’s
efforts to refine the definition of improper payment in alignment with
OMB guidance. SBA officials noted that they had developed an
internal memorandum that defined improper payments and identified
reporting and reconciliation processes for improper payments and
corrective actions. The memorandum also required training and
17Pub. L. No. 115-182, 132 Stat. 1393. Section 102 of this law provided authority for VA to
enter into certain provider agreements that are not treated as acquisition contracts subject
to the FAR. 38 U.S.C. § 1703A(i).
18USF is funded through mandatory contributions from U.S. telecommunications services
providers to support the goal of universal service nationwide and includes four programs:
the High Cost Program (also known as the Connect America Fund), the Lifeline Program,
the Rural Health Care Program, and the Schools and Libraries Program (also known as E-
Rate). The Universal Service Administrative administers these programs under FCC’s
direction.
19The 7(a) Loan program provides small businesses with short- and long-term working
capital, capital to refinance current business debt, and capital for specific business
expenditures. For payment integrity reporting, SBA divides the 7(a) Loan program into
7(a) Loan Guarantee Approvals and 7(a) Loan Guarantee Purchases. SBA’s Disaster
Loan Disbursements program provides low-interest loans to help businesses and
homeowners recover from declared disasters.
Page 12 GAO-23-106585 Improper Payments
recurring meetings for program office staff to discuss findings, policy,
corrective actions, and training. SBA officials attributed the reduction
in the estimated improper payment rates for these programs to
extensive training for internal employees and external lenders
involved in loan disbursement.
• Social Security Administration (SSA). SSA reported reductions in
estimated improper payment rates for the Old Age, Survivors, and
Disability Insurance (OASDI) and Supplemental Security Income
programs. 20 SSA officials attributed the reductions in the estimated
improper payment rates for these programs to standardizing
processes such as those used to determine the underlying causes of
payment errors, develop corrective action plans, and determine cost-
effective actions.
Corrective Actions and The eight agencies with reductions in estimated improper payment rates
Reduction Efforts Share from fiscal year 2017 to fiscal year 2022 attributed the reductions to both
program-specific corrective actions and broader non-program-specific
Some Common Features
efforts. Based on our review of the agencies’ AFRs and interviews with
officials representing the eight agencies, we found that strategies and
efforts for mitigating improper payments varied between agencies. The
most commonly reported mitigation efforts fell under two broad
categories: (1) establishing accountability and facilitating internal
collaboration and (2) providing technology, tools, and training targeted to
root causes.
Actions and Efforts to Establish Agency officials and AFRs noted the following examples of efforts related
Accountability and Facilitate to establishing accountability and facilitating internal collaboration that
Internal Collaboration may have contributed to reductions in estimated improper payment
rates: 21
• CNCS. The agency established a cross-agency corrective action
planning group that tracks all improper payments through root-cause
categories in order to take appropriate action on known issues. In
addition, CNCS officials noted that constant communication with
20OASDI provides retirement and survivors’ benefits to qualified workers and their family
members. Supplemental Security Income provides financial support to older adults, as
well as adults and children who are blind or disabled and who have limited income and
resources.
21Agencies establish accountability through mechanisms that hold an entity or person
responsible, such as designating a senior agency official accountable and establishing
performance incentives or benchmarks. Agencies facilitate internal collaboration through
coordination between intra-agency partners and stakeholders to increase access to
information used to mitigate improper payments, such as sharing documents, processes,
and opportunities, and holding regular meetings to discuss improper payment topics.
Page 13 GAO-23-106585 Improper Payments
grantees is necessary to address improper payments in the program.
For example, CNCS offered introductory calls to grantees to describe
the process, recorded trainings, and offered additional calls during the
process for clarification of requests.
• USDA. For WIC, USDA focused management evaluation resources
on activities that support corrective action implementation and
validation, including meetings. Management evaluations include on-
site reviews of state and local agency operations and reviews of
program-specific documentation. FNS focuses WIC management
evaluations on key areas related to program integrity, and analyzes
the resulting evaluation data to identify opportunities to improve
program administration and integrity. For example, evaluations help
ensure program integrity by assessing WIC state agency compliance
with program requirements, evaluating the accomplishment of WIC
program objectives, and providing technical assistance to state
agencies while also supporting state agency efforts to improve and
innovate.
• DOD. The agency established senior accountable officials at the
senior executive service level in each of the military services and
defense agencies to promote accountability for the DOD payment
integrity efforts.
DOD also developed and implemented processes and tools to
evaluate, monitor, and measure improper payments for DOD Travel
Pay, including developing performance metrics and tracking them via
spreadsheets and database dashboards, performing periodic quality
assurance reviews of metrics and corrective action implementation,
and monitoring recovery of overpayments. In addition, DOD took
various actions to improve internal collaboration. For example, DOD
holds quarterly senior accountable official meetings to discuss and
track the progress of its corrective action plans. The agency also
holds conferences with approving officials and lead defense travel
administrators to spread awareness of payment errors and share best
practices for correcting them. Lastly, DOD’s Defense Finance and
Accounting Service updates approving officials and travelers on
common improper payment errors monthly.
• HHS. The agency supported states in establishing mitigation
strategies and corrective actions for CCDF improper payments. HHS’s
fiscal year 2022 AFR notes that states must report on the causes of
errors identified in the prior and current review cycles, as well as on
the actions they will take to correct those causes. According to HHS,
the Office of Child Care’s National Center on Subsidy Innovation and
Accountability was funded to provide technical assistance to states
Page 14 GAO-23-106585 Improper Payments
and territories for CCDF-related program integrity and accountability
matters. HHS also promoted collaboration by conducting site visits in
states needing assistance to address improper payment root causes.
• VA. The agency’s Veterans Health Administration (VHA) established
program-level senior accountable officials to increase accountability
and involvement of program offices in reducing improper payments. In
addition, the VHA Associate Chief Financial Officer (CFO) established
compliance benchmarks for all VHA high-risk programs and set goals
for each senior accountable official to meet PIIA compliance by
specified dates. According to VA officials, VHA undertook various
internal collaboration efforts to help reduce improper payments,
including the following:
• Establishment of a payment integrity team. The team works with
subject-matter experts to obtain documents for payment
validation, which helps the team assess payments by high-risk
programs and establish and monitor corrective actions.
• Regular meetings with management. VHA holds quarterly
meetings with senior accountable officials and monthly meetings
with contacts from VHA’s regional health care networks to
facilitate accountability and to share PIIA testing results.
• Annual corrective action plan effectiveness reviews. VHA carries
out the reviews to determine if corrective actions are correctly
aligned to root causes and proper mitigation strategies are
selected to reduce improper payments.
• FCC. The Universal Service Administrative Company (USAC), which
is the not-for-profit company that FCC designated to administer USF,
established payment recapture audits and an improper payment
testing program called the Beneficiary and Contributor Audit Program
(BCAP) to help detect improper payments. USAC designed BCAP to
identify overpayments that must be recaptured; to assess compliance
with FCC rules; and to deter waste, fraud, and abuse. According to
FCC officials, BCAP meets regularly with its payment quality
assurance group to discuss improper payment topics, issues, and
improvement strategies.
• SBA. To help prevent improper payments for disaster loan
disbursements and improve accountability, SBA noted its corrective
actions, including plans to tie elements of officials’ performance plans
to reducing the estimated improper payment rate. SBA also
established strategies to promote internal collaboration. Per SBA
officials, SBA internal offices coordinate through regular meetings to
discuss current findings and corrective action plan results. For
Page 15 GAO-23-106585 Improper Payments
example, loan origination and loan closing departments meet biweekly
with the Disaster Internal Controls Division to discuss policy, audit
exceptions, corrective actions, root causes, and training needs. Lastly,
SBA works with the program offices on issues related to compliance
with internal policies.
• SSA. The agency developed and implemented a standardized
process called the Improper Payments Alignment Strategy, which
involved documenting underlying causes of errors, risks, and
challenges and evaluating corrective actions. The process allowed
SSA to centralize its coordination and monitoring of all improper
payment mitigation initiatives for a more focused approach along with
prioritizing corrective actions, according to SSA officials. In addition,
SSA holds two recurring meetings with senior leadership to discuss
improper payment issues. It holds a monthly meeting between senior
leadership and staff to discuss progress and challenges related to
implementation of improper payment initiatives, and a quarterly
meeting with senior executives who serve on SSA’s Improper
Payments Oversight Board. 22
Actions and Efforts to Provide Agency officials and AFRs noted examples of efforts to provide
Technology, Tools, and technology, tools, and training designed to address root causes of
Training to Address Root improper payments. 23 Examples included the following:
Causes
• CNCS. The agency provided tools and training to reduce
noncompliance with NSCHC requirements. By law, NSCHCs are
required for all national service participants and staff in covered
positions. According to the fiscal year 2019 CNCS Annual
Management Report, over 67 percent of CNCS’s estimated improper
payments categorized as having insufficient documentation had a
noncompliant NSCHC component. The agency has reduced the
barriers to NSCHC compliance by providing grantees with access to
its new vendor’s services for criminal history checks. For example,
according to CNCS officials, the agency identified a vendor to support
22According to SSA, the Improper Payment Oversight Board provides leadership,
oversight, and accountability for the agency’s improper payments initiatives. The board
ensures the alignment of corrective actions with the Agency Strategic Plan and major
information technology investments.
23Agencies reported providing technology and tools—such as software, automation, and
information systems—to help address root causes improper payments. Agencies also
reported providing training on topics such as proper payment processing methods to help
ensure that staff and stakeholders have the proper skill sets and knowledge related to
common causes of improper payments.
Page 16 GAO-23-106585 Improper Payments
its existing contract to provide grantees with access to all components
of NSCHC screening requirements. 24 Additionally, CNCS requires all
grantees, including AmeriCorps program grantees, to complete
annual training on NSCHC screening requirements. In 2019, CNCS
provided seven such training opportunities.
• USDA. FNS has also released several tools for WIC state agencies
that aim to improve vendor management and certification. These
resources include the WIC Vendor Management and Food Delivery
Handbook, a new toolkit for assessing and developing WIC vendor
peer group systems, and an updated tool for assessing WIC vendor
cost neutrality. 25 In addition, USDA provided numerous training
opportunities on key improper payment topics and released
comprehensive handbooks for vendor management and certification
and eligibility training in fiscal year 2017.
• DOD. DOD provided training on common errors and causes of DOD
Travel Pay improper payments. According to DOD officials, the DOD
Travel Pay program operates on a decentralized authorization
system, in which officials across DOD approve travel payments.
Because of this, DOD’s strategy for reducing program improper
payments concentrated on improving internal training for authorizing
officials. This training outlined common errors and causes of improper
payments. In addition, DOD components provide updates on the
progress of corrective action plans through a web-based collaborative
platform, and provide training for approving officials specifically
related to improper payments.
• HHS. HHS provided training and technical assistance. Officials told us
that the agency attributed its reduction in the CCDF estimated
improper payment rate in part to the ongoing training and technical
assistance it provided to states. Specifically, HHS provided support
related to changing policies and procedures, implementing payment-
integrity rate methodology, addressing root causes, and establishing
corrective action plans. HHS officials also credited states updating
24If the grantees did not perform all of the required components of the NSCHC on national
service participants and staff before the payment date, the payment is considered
improper.
25State agencies must ensure that above-50-percent vendors (vendors that derive more
than 50 percent of their annual food sale revenue from the WIC program) do not result in
higher costs to the program than if participants had transacted at regular vendors. State
agencies are required to compare average payments to all regular vendors. If average
payments to all above-50-percent vendors do not exceed average payments to all regular
vendors, the state will have achieved cost neutrality.
Page 17 GAO-23-106585 Improper Payments
and developing their information technology systems with helping to
reduce improper payments in the CCDF program.
HHS’s fiscal year 2022 AFR notes that, due to the high volume of
Medicare claims that HHS processes daily and the significant cost
associated with conducting medical reviews of an individual claim,
HHS relies on automated edits to identify inappropriate claims for the
Medicare FFS program. HHS designed its systems to detect
anomalies and prevent payment for many erroneous claims.
• VA. VHA developed a PIIA dashboard that according to VA officials,
allowed leadership to identify where errors were occurring and target
those areas for follow-up. VHA also worked with program subject-
matter experts to gain access to systems containing the
documentation required for improper payment testing, leading to more
accurate and efficient information gathering and review. Furthermore,
VA officials told us that the agency developed an internal system for
sharing corrective action plans that helped enhance the process.
For the Beneficiary Travel program, VHA implemented new software
to provide a customized and enhanced tool to streamline claims,
automate eligibility determinations, handle payment processing, help
detect and prevent improper payments, and enhance reporting and
auditing capabilities. VA also provides training targeted to causes of
improper payments. For example, for the Purchased Long Term
Services and Support program, VA conducts quarterly staff training on
avoiding ineligible vendors by verifying approved vendor lists prior to
authorization.
• FCC. FCC and USAC launched the National Verifier system to
address program integrity issues. FCC and USAC began work on the
National Verifier in 2017 after FCC adopted the approach in a 2016
order. According to FCC, the National Verifier significantly reduces
improper payments related to prior program integrity issues, such as
ineligible subscribers, deceased subscribers, duplicate subscribers,
and oversubscribed addresses. The National Verifier uses a
combination of automated and manual processes to verify eligibility
and avoid duplicate enrollments, confirming whether a consumer is
qualified for the Lifeline program.
In addition, according to FCC officials, the Schools and Libraries
program’s use of open data and other coding capabilities allowed it to
improve its eligibility validation for invoices, resulting in lower improper
payment error rates. USAC also implemented outreach efforts to
reduce improper payments and the potential causes of errors that
were identified during audits and payment quality assurance reviews.
Page 18 GAO-23-106585 Improper Payments
Additional outreach efforts include newsletters and webinars that are
used to educate carriers on rules and program requirements.
• SBA. According to SBA officials, the agency provides extensive
training on improper payment issues and corrective actions to internal
employees and external lenders involved in the 7(a) Guarantee
Approvals, 7(a) Guarantee Purchases, and Disaster Loan
Disbursements lending process. SBA also provides training to staff
and external parties on updated methods and information to help
ensure compliance with current guidance.
• SSA. SSA developed wage-reporting tools. According to SSA, several
factors determine whether disability beneficiaries who work can
continue to receive monthly benefits. Based on 5-year data from fiscal
year 2017 through fiscal year 2021, SSA estimated that beneficiaries’
or representative payees’ failure to report work accounted for 83
percent of improper payment errors related to Substantial Gainful
Activity, one of the root causes of OASDI overpayments. In addition,
Supplemental Security Income recipients’ or representative payees’
failure to report change in work accounted for 87 percent of
Supplemental Security Income improper payment errors. To reduce
the reliance on self-reporting of wages, SSA is developing new wage-
reporting tools, such as the Payroll Information Exchange (PIE), which
allow the agency to exchange information with commercial payroll
providers. In addition, in fiscal year 2022, SSA developed the capacity
to automate the process of obtaining and recording wage and
employment data information received via PIE to appropriate systems.
Agencies Reported Key We asked the eight agencies with reductions in estimated improper
Takeaways or Lessons payment rates from fiscal years 2017 to 2022 to describe their key
takeaways or lessons learned from efforts to reduce improper payments.
Learned from Reductions
Agencies provided several examples:
• CNCS officials described the importance of targeted agency-wide
actions, as well as the need for strong communication, particularly
between the agency and its grantees. CNCS also noted the
importance of office of inspector general engagement as well as
preparation and planning for change management.
• DOD officials noted the importance of providing adequate training,
promoting collaboration, and providing regular communication and
feedback to DOD components regarding errors or issues related
to improper payments.
Page 19 GAO-23-106585 Improper Payments
• VA officials noted the importance of establishing proper tone at
the top. 26 They also cited the importance of ensuring that
dedicated personnel provide oversight within both the VA CFO
and VHA CFO offices. VA officials also noted the importance of
ensuring that policies specify roles and responsibilities and
provide the structure needed to drive consistent implementation of
PIIA requirements. They also cited the importance of ensuring that
improper payment testing aligned with PIIA and OMB guidance
and that any related audit findings were addressed. Finally, VA
officials emphasized the importance of evaluating mitigation
strategies and corrective actions for effectiveness.
• FCC officials cited the importance of analyzing root causes on a
quarterly basis.
• SBA officials stated that it was important to hold regular meetings
with all program offices to discuss common issues and solutions.
These examples underscore the importance of effective corrective actions
to address root causes of improper payments. We have previously found
that developing corrective action plans that respond to identified root
causes of improper payments is a critical component in government-wide
efforts to reduce improper payments. 27 Agency processes to monitor the
progress and measure the effectiveness of such plans are essential to
evaluating efforts to address improper payments. 28
We provided a draft of this report to CNCS, USDA, DOD, HHS, VA, FCC,
Agency Comments SBA, and SSA for review and comment. CNCS, HHS, SBA, and SSA
provided technical comments, which we have incorporated as
appropriate.
We are sending copies of this report to the appropriate congressional
committees; the Chief Executive Officer of the Corporation for National
and Community Service; the Secretaries of Agriculture, Defense, Health
and Human Services, and Veterans Affairs; the Chair of the Federal
26According to federal internal control standards, management enforces accountability of
individuals performing their internal control responsibilities. Accountability is driven by the
tone at the top and supported by the commitment to integrity and ethical values,
organizational structure, and expectations of competence, which influence the control
culture of the entity. GAO, Standards for Internal Control in the Federal Government,
GAO-14-704G (Washington, D.C.: Sept. 2014).
27GAO, Payment Integrity: Selected Agencies Should Improve Efforts to Evaluate
Effectiveness of Corrective Actions to Reduce Improper Payments, GAO-20-336
(Washington, D.C.: Apr. 1, 2020).
28GAO-20-336.
Page 20 GAO-23-106585 Improper Payments
Communications Commission; the Administrator of the Small Business
Administration; the Acting Commissioner of the Social Security
Administration; the Director of the Office of Management and Budget; and
other interested parties. 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
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix I.
M. Hannah Padilla
Director, Financial Management and Assurance
Page 21 GAO-23-106585 Improper Payments
Appendix I: GAO Contact and Staff
Appendix I: 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 Sabrina Rivera (Auditor in Charge), Tech Le, Edgar Fletes, Courtney Cox,
Acknowledgments Seth Brewington, Jason Kelly, Jared Smith, and Amanda Stogsdill made
key contributions to this report.
Page 22 GAO-23-106585 Improper Payments
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