GAO-23-106761: Improper Payments: Opportunities for Interagency Collaboration and Improvements
Summary
GAO-23-106761, Improper Payments: Opportunities for Interagency Collaboration and Improvements, a Government Accountability Office report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives, dated September 28, 2023. It is GAO's third quarterly report under House Report 117-389 and examines updates to OMB's high-priority program scorecard, the role of chief financial officers in managing improper payments, and opportunities for improvement. It states that reported cumulative executive agency improper payment estimates have totaled about $2.4 trillion since fiscal year 2003, including $247 billion for fiscal year 2022. GAO recommends that OMB review inspectors general reports on PIIA compliance and document and communicate to them any considerations that may warrant revisions to the scorecard.
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“GAO-23-106761: Improper Payments: Opportunities for Interagency Collaboration and Improvements.”
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U.S. Government Accountability Office
Improper Payments: Opportunities for
Interagency Collaboration and Improvements
GAO-23-106761
Report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives
September 28, 2023
Why This Matters Detecting and preventing improper payments—those that should not have been
made or were made in an incorrect amount, including overpayments and
underpayments—is critical to safeguarding federal funds. 1 Since fiscal year 2003,
reported cumulative executive agency improper payment estimates have totaled
about $2.4 trillion, including $247 billion for fiscal year 2022.
The Payment Integrity Information Act of 2019 (PIIA) requires the Office of
Management and Budget (OMB) to annually designate a list of high-priority
programs for greater levels of review and oversight. 2 OMB requires the agencies
administering these programs to provide certain information, such as actions for
reducing improper payments, in a scorecard format each quarter. 3
According to our survey of chief financial officers (CFO) from the 24 agencies
covered by the Chief Financial Officers Act of 1990 (CFO Act), CFOs play a role,
to different extents, in managing their agencies’ efforts to reduce improper
payments and overseeing compliance with PIIA reporting requirements. 4 The
CFO Act provided certain agency CFOs with leadership responsibilities for
overseeing all financial management activities within their respective agencies. 5
We have made prior recommendations to agencies to help detect and prevent
improper payments, and recommended that Congress consider clarifying certain
CFO responsibilities.
House Report 117-389, which accompanied the Legislative Branch
Appropriations Act, 2023, includes a provision for GAO to provide quarterly
reports on improper payments. This is our third quarterly report, and it examines
recent updates to the high-priority scorecard, CFOs’ role in managing improper
payments, and opportunities for improvement. 6
Key Takeaways • For programs OMB designated as high priority, scorecards contain key
information that is important for both OMB and inspectors general (IG) in
overseeing efforts to address improper payments.
• While OMB has solicited feedback from IGs on an ad-hoc basis, additional
collaboration is imperative as OMB considers revising the scorecard.
• CFOs at CFO Act agencies view their role to include some level of
responsibility for tasks related to managing improper payments.
• While federal agencies, OMB, and Congress have made efforts in recent
years to improve payment integrity, additional opportunities remain to reduce
improper payments.
• We recommend that OMB review reports on compliance with applicable PIIA
criteria from IGs of agencies with high-priority programs, and document and
communicate to IGs any considerations of their reported issues that may
warrant revisions to the scorecard’s format and content.
Page 1 GAO-23-106761 Improper Payments
What is a scorecard A payment-integrity scorecard, also known as a high-priority program scorecard,
and its purpose? highlights actions that agencies with high-priority programs planned and took to
mitigate root causes of overpayments.
PIIA requires OMB to annually designate a list of high-priority programs for
greater levels of review and oversight. OMB considers a program high-priority if it
has estimated improper payments resulting in monetary loss of more than $100
million annually. 7 OMB collects and publishes this information quarterly in a
scorecard on PaymentAccuracy.gov. 8
OMB states that the purpose of the scorecard is to help demonstrate to Congress
and the public the progress agencies have made, at the program level, to
improve payment integrity and reduce improper payments.
Who uses the In addition to Congress and the public, IGs use the scorecards. IGs have
scorecard? responsibilities related to reviewing their respective agencies’ scorecards.
According to OMB’s guidance, IGs of agencies with high-priority programs must
assess the information provided on the scorecard and determine the extent of IG
oversight warranted to prevent monetary loss. Based on scorecard information,
the IG may also provide the agency head with recommendations for modifying
and improving agency plans to prevent and recover improper payments.
What information does The fiscal year 2023 scorecard contains key information on the program or
the scorecard contain? activity, the fiscal year estimated overpayment amount (including the estimate’s
sampling time frame), and the scorecard reporting period (i.e., the fiscal year and
quarter). In addition, the scorecard contains the following information:
• Historical overpayment rates (as a percentage of total outlays) and amounts
• A brief program description, summary of overpayment causes, and barriers to
prevention
• Discussion of actions the agency took in the preceding quarter and actions
planned in the following quarter to prevent overpayments
• Overpayment amounts associated with identified root causes, root cause
descriptions, and mitigation strategies (including descriptions and anticipated
effects)
• Goals and accomplishments related to reducing overpayments
• Overpayment recovery methods and descriptions of plans and actions to
recover overpayments
How has OMB updated The fiscal year 2023 second-quarter version of the scorecard is longer than the
the scorecard? prior version for the fiscal year 2022 fourth-quarter (two pages vs. one). 9 The
additional length is mainly due to the following new information:
• Summary of overpayment causes and barriers to prevention
• Actions taken in the quarter (quarter being reported on) to prevent
overpayments
• Actions planned in the following quarters to prevent overpayments
In addition, OMB removed the “key milestones” section from the prior version,
and replaced the term “monetary loss” with “overpayment” throughout the
scorecard. Figure 1 shows changes OMB made to the scorecard.
Page 2 GAO-23-106761 Improper Payments
Figure 1: Example of an Agency’s Fiscal Year 2023 Second-Quarter Scorecard
Why was the scorecard According to OMB staff, they updated the scorecard to provide intended users—
updated? Congress, the public, and IGs—with more context and detail regarding agencies’
actions to manage and mitigate improper payments. They told us that OMB had
received varying levels of detail from agencies in the past because certain
aspects of OMB’s instructions to agencies may not have been clear. OMB staff
said they have clarified instructions for agencies regarding how to provide
information.
How does OMB obtain According to OMB staff, they solicit feedback and comments from IGs on an ad-
feedback from related hoc basis when OMB updates its guidance for publication. For example, prior to
IGs on high-priority its March 2021 publication, OMB provided opportunities for IGs to comment on
program scorecards? the revisions to appendix C of OMB Circular No. A-123. 10
In prior years, OMB had an IG working group, through the Council of the
Inspectors General on Integrity and Efficiency and the Pandemic Response
Accountability Committee. The working group discussed issues related to
pandemic improper payments and issued alerts to agencies aimed at raising
awareness on key issues related to preventing waste, fraud, and abuse.
However, the working group no longer exists due to a decline in the prevalence
of pandemic-related spending.
OMB does not currently have a working group to collaborate regularly with IGs of
agencies with high-priority programs and to solicit and obtain feedback and
comments. However, OMB staff stated that all members of the executive branch,
Page 3 GAO-23-106761 Improper Payments
including IGs, may submit recommendations for changes to OMB guidance
related to payment integrity at any time via OMB’s website.
Per OMB’s guidance and based on what OMB staff told us, the information
reported by agencies in the scorecard is important for both OMB and IGs in
overseeing efforts to address improper payments. 11 OMB staff told us that they
rely on the work of the relevant IGs to identify deficiencies and trends in agency
compliance with OMB guidance on improper payments.
OMB’s guidance, consistent with PIIA, states that IGs have the key
responsibilities for reviewing their respective agencies’ scorecards. It also states
that IGs rely on such information to determine the extent of oversight warranted
to prevent monetary-loss improper payments, and to provide the agency head
with recommendations to prevent improper payments from occurring in the
future.
In addition, our prior work on leading practices to enhance interagency
collaboration shows that many of the meaningful results the federal government
seeks require the coordinated efforts of more than one agency. 12 Such leading
practices can help address crosscutting challenges, including involving relevant
participants. 13
Because both OMB and IGs rely on the information that each provides the other,
their collaboration is imperative. OMB receives copies of IGs’ annual reports on
agency compliance with PIIA criteria and related OMB guidance. These reports
include information on high-priority programs. However, OMB does not review
the reports to identify issues that may warrant revision to the scorecards format
and content, and OMB does not document and communicate to IGs its
consideration of any such issues noted in the reports. These steps can increase
collaboration between OMB and IGs of agencies with high-priority programs.
This additional collaboration could help better ensure that IGs have necessary
information to oversee agencies as they work to detect and prevent improper
payments, and that Congress and the public have more transparent information
about improper payments.
What is in the future for OMB staff told us they are continuously looking for ways to improve the
the scorecard? scorecard, and they have made agencies aware that OMB is placing more
emphasis on improving the information the scorecard provides. Given its
increased attention to scorecard changes, OMB staff expect that agencies will
also pay more attention to the scorecard.
What do laws and The laws and guidance we reviewed, including PIIA, the CFO Act, and OMB
Circular No. A-123, Appendix C, generally do not define specific roles and
guidance say is the
responsibilities that require CFOs to perform in managing their agencies’ efforts
CFO’s role in detecting to detect and prevent improper payments. Instead, we found that these
and preventing authorities direct requirements to the head of the agency and allow for variation
improper payments? in CFOs’ roles in detecting and preventing improper payments.
What do CFOs view as Based on our survey of CFOs from the 24 CFO Act agencies, CFOs view their
their role in reducing role to include some level of responsibility for tasks related to managing improper
improper payments? payments. Our survey asked CFOs to indicate the CFO’s level of responsibility
for completing certain tasks. While responses varied, for the tasks we surveyed,
the majority of CFOs viewed that completing them was either solely the CFO’s
responsibility, a responsibility of staff in the CFO office, or a responsibility shared
by staff within and outside the CFO office.
Page 4 GAO-23-106761 Improper Payments
Figure 2 shows survey responses regarding the CFO’s role in managing
improper payments.
Figure 2: Chief Financial Officers' (CFO) View on Their Role in Managing Improper Payments
Note: Responses related to the following survey question: Select the option that, in your view, best reflects the
Chief Financial Officer’s (CFO) level of responsibility for completing the following tasks at your agency.
What do CFOs view Based on our survey of CFOs from the 24 CFO Act agencies, the majority think
their role should be in that the responsibility for developing and implementing an agency’s approach to
mitigating and mitigating improper payments should be shared by the CFO and other agency
overseeing improper positions. However, most CFOs think that the CFO should be solely responsible
for overseeing that improper payments information is prepared and reported in
payments?
accordance with OMB guidance.
Figure 3 shows additional CFO responses about agency responsibilities in
managing improper payments.
Page 5 GAO-23-106761 Improper Payments
Figure 3: Chief Financial Officers' (CFO) Views on Various Responsibilities in Managing
Improper Payments
What work has GAO In emergencies, the risk of improper payments may be higher because the need
done related to to provide assistance quickly can hinder the implementation of effective controls.
detecting and In July 2023, we issued our Framework for Managing Improper Payments in
preventing improper Emergency Assistance Programs, which provides Congress and federal
agencies with an overall approach to detect and prevent improper payments in
payments?
emergency assistance programs. It can also be useful for managing improper
payments in non-emergency assistance programs, or even during normal
program operations. 14
We have also made many priority recommendations to federal agencies and
identified matters for congressional consideration, related to improper
payments. 15 Our 2023 priority recommendation letters included 59 priority
recommendations related to improper payments to agencies that reported
improper payment estimates for the most recent fiscal year, as well as to OMB.
For example:
• Improper payments in Medicaid and Medicare. We have four open priority
recommendations that, if implemented, could reduce improper payments,
such as by improving oversight of providers. 16 For example, we have
recommended that the Department of Health and Human Services’ Centers
for Medicare & Medicaid Services (CMS) complete a comprehensive, national
risk assessment and assure that state-reported resources to oversee
Medicaid expenditures are adequate and allocated based on areas of highest
risk. In addition, we recommended that CMS ensure that Medicare and
Medicaid documentation requirements demonstrate compliance with
coverage policies and effectively address program risks.
• Reducing improper payments at the Department of Agriculture. We have
three open priority recommendations that, if implemented, would allow the
agency to better confirm eligibility for supplemental assistance and nutrition
programs and ensure that potentially billions of dollars in payments to
program participants and recipients are accurately distributed. 17
• Reducing government-wide improper payments. OMB has ongoing efforts
to implement two open priority recommendations to (1) develop and
implement monitoring mechanisms that evaluate agency use of the Do Not
Pay working system and (2) incorporate appropriate measures to ensure that
Page 6 GAO-23-106761 Improper Payments
single audit guidance is issued timely and is responsive to users’ input and
needs. 18
We also have 21 matters for congressional consideration to improve federal
financial management, including opportunities to clarify CFOs’ responsibilities. 19
What work has GAO In prior reports, we recommended the following matters for congressional
done related to CFO consideration related to CFO responsibilities in improving federal financial
responsibilities in management and improper payments: 20
improving federal • Congress should clarify that (1) CFOs at CFO Act agencies have oversight
financial management? responsibility for internal controls over financial reporting and key financial
management information that includes spending data and improper payment
information and (2) executive-agency internal control assessment, reporting,
and audit requirements for key financial management information include
internal controls over spending data and improper payment information.
• Congress should require agency CFOs to (1) submit a statement in agencies'
annual financial reports certifying the reliability of improper payments risk
assessments, and the validity of improper payment estimates, and describing
the actions of the CFO to monitor the development and implementation of
any corrective action plans and (2) approve any methodology that is not
designed to produce a statistically valid estimate.
Based on responses to our survey, CFOs view their responsibilities to include
tasks related to managing improper payments. If implemented, our prior matters
could increase accountability and help to ensure that CFOs continue to view
reducing improper payments as a responsibility that is within their authority to
manage.
What additional work While federal agencies, OMB, and Congress have made efforts in recent years to
remains for agencies, improve payment integrity, more work remains to be done.
OMB, and Congress to As of August 2023, of the 18 agencies that reported improper payment estimates
improve payment in fiscal year 2022, eight had open (unaddressed) GAO priority recommendations
integrity? related to improper payments. In addition, 42 of our 59 priority recommendations
related to improper payments remained open; OMB closed one of three of our
priority recommendations to the agency. Also, there are 21 open GAO matters
for congressional consideration to improve federal financial management. See
appendixes V, VI, and VII of our first quarterly report for a list of open priority
recommendations and matters for congressional consideration. 21
By working collaboratively to address open priority recommendations and
matters for congressional consideration, federal agencies and Congress can
make progress toward detecting and preventing improper payments and
improving payment integrity.
Conclusions While OMB took steps to improve the high-priority scorecard’s format and
content, enhancing interagency collaboration between OMB and IGs would help
agencies improve their ability to detect and prevent improper payments. By
periodically reviewing relevant IGs’ reports of compliance with PIIA criteria and
documenting and communicating consideration of reported issues, OMB could
better ensure that IGs have necessary information to oversee agencies’ efforts to
reduce improper payments. Also, this could help ensure that Congress and the
public have more transparent information about the progress agencies have
made.
Page 7 GAO-23-106761 Improper Payments
Recommendation for The Director of OMB, prior to updating the scorecard information and relevant
Executive Action guidance to agencies, or at least on an annual basis, should (1) review the
reports on compliance with the applicable Payment Integrity Information Act of
2019 criteria from the IGs of agencies with high-priority programs, and (2)
document and communicate to IGs any considerations of their reported issues
that may warrant revisions to the scorecard’s format and content.
(Recommendation 1)
Agency Comments We provided a draft of this report to the Director of OMB for review and
comment. OMB did not have any comments on the report.
How GAO Did This To compare and describe the information reported in the scorecard and changes
Study made to it, we obtained and reviewed the fiscal year 2022 fourth-quarter and
fiscal year 2023 second-quarter scorecards published on PaymentAccuracy.gov
for those programs OMB considers high priority. In addition, we interviewed OMB
staff to understand steps OMB had taken to improve the scorecard and its
process for collecting such data. Further, we coordinated with the Council of the
Inspectors General on Integrity and Efficiency to ensure that there were no
independence concerns with IGs with regard to our findings and
recommendation.
To describe the CFO’s role in managing improper payments at the 24 CFO Act
agencies, we (1) reviewed laws and guidance to identify any CFO responsibilities
related to managing improper payments; (2) reviewed recent GAO reports,
including recommendations and matters for congressional consideration; and (3)
collected and analyzed responses to relevant questions from a web-based
survey we sent to 24 agency CFOs.
To conduct this work, we surveyed the 24 CFO Act agencies for information on
the CFO’s role in managing improper payments and for information on the
agencies’ fraud risk management efforts. We plan to issue a subsequent report
with information on agencies’ fraud risk management efforts. To develop the
questionnaire, we reviewed our prior survey on agencies’ status in implementing
fraud risk management requirements. We also incorporated comments from
internal and external reviewers, including our survey specialist and an OMB staff.
We pretested the questionnaire with five agencies using cognitive interviewing
techniques and modified the survey instrument based on the comments we
received.
We fielded the survey from April 25, 2023, through June 8, 2023. We received
questionnaire responses from all 24 agencies, for a response rate of 100
percent. Our survey results reflect the information provided by and the opinions
of the agency officials who participated in our survey. We also analyzed closed-
ended responses.
We summarized recent open matters for congressional consideration and priority
recommendations to agencies related to improper payments and their status that
we previously identified as opportunities to detect and prevent improper
payments and improve payment integrity.
We conducted this performance audit from April 2023 to September 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.
Page 8 GAO-23-106761 Improper Payments
List of Addressees The Honorable Mark E. Amodei
Chairman
The Honorable Adriano Espaillat
Ranking Member
Subcommittee on Legislative Branch
Committee on Appropriations
House of Representatives
GAO Contact For more information, contact: M. Hannah Padilla, PadillaH@gao.gov, (202) 512-
Information 5683.
Chuck Young, Managing Director, Public Affairs, YoungC1@gao.gov, (202) 512-
4800.
A. Nicole Clowers, Managing Director, Congressional Relations,
ClowersA@gao.gov, (202) 512-4400.
Staff Acknowledgments: Daniel Flavin (Assistant Director), Jeremy Choi
(Auditor-in-Charge), Anthony Clark, David Dornisch, Tech Le, Lydie Loth, and
Laura Ruozzi.
Connect with GAO on Facebook, Flickr, Twitter, and YouTube. Subscribe to our
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Visit GAO on the web at https://www.gao.gov.
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Endnotes
1An improper payment 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).
2Under PIIA, agencies with high-priority programs are subject to additional reporting requirements.
31 U.S.C. § 3352(b).
3Office of Management and Budget, Requirements for Payment Integrity Improvement, Circular No.
A-123, Appendix C, OMB M-21-19 (Mar. 5, 2021).
4Under PIIA and OMB guidance, the core framework for managing improper payments, executive
branch agencies are required to periodically assess, estimate, analyze, and report on improper
payments in the programs they administer.
5The CFO Act, Pub. L. No. 101-576, 104 Stat. 2838 (Nov. 15, 1990) (codified as amended in
scattered sections of 31 U.S.C.), established CFO positions 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).
6For our first quarterly report, see GAO, Improper Payments: Fiscal Year 2022 Estimates and
Opportunities for Improvement, GAO-23-106285 (Washington, D.C.: Mar. 29, 2023). For our
second quarterly report, see GAO, Improper Payments: Programs Reporting Reductions Had
Taken Corrective Actions That Shared Common Features, GAO-23-106585 (Washington, D.C.:
June 30, 2023).
731 U.S.C. § 3352(b). 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.
8PaymentAccuracy.gov is an official U.S. government website that OMB manages. It contains
information about current and historical estimated improper payment rates (i.e., agency-reported
Page 9 GAO-23-106761 Improper Payments
improper payment amounts as a percentage of outlays), amounts of estimated improper payments,
root causes of monetary loss and improper payments, monetary-loss recovery efforts, and high-
priority program scorecards.
9Agencies did not report high-priority program scorecards for the first quarter of fiscal year 2023.
10Office of Management and Budget, Requirements for Payment Integrity Improvement.
11Office of Management and Budget, Requirements for Payment Integrity Improvement.
12GAO, Government Performance Management: Leading Practices to Enhance Interagency
Collaboration and Address Crosscutting Challenges, GAO-23-105520 (Washington, D.C.: May 24,
2023).
13Leading practices for collaboration include relevant participants—participating agencies
ensure that they have invited the relevant organizations and any individuals who may have a stake
in the collaborative effort.
14GAO, A Framework for Managing Improper Payments in Emergency Assistance Programs, GAO-
23-105876 (Washington, D.C.: July 2023).
15Priority recommendations are those that 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 them.
16GAO, Priority Open Recommendations: Department of Health and Human Services, GAO-23-
106467 (Washington, D.C.: May 10, 2023).
17GAO, Priority Open Recommendations: Department of Agriculture, GAO-23-106456 (Washington,
D.C.: May 12, 2023).
18GAO, Priority Open Recommendations: Office of Management and Budget, GAO-23-106298
(Washington, D.C.: May 23, 2023).
19GAO, Open Matters for Congressional Consideration: Action Can Produce Billions of Dollars in
Financial and Other Benefits for the Nation, GAO-23-106837 (Washington, D.C.: July 25, 2023).
20GAO, 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), and Emergency Relief Funds: Significant Improvements Are Needed to Ensure
Transparency and Accountability for COVID-19 and Beyond, GAO-22-105715 (Washington D.C.:
Mar. 17, 2022).
21See our first quarterly report, GAO-23-106285. In addition to the open priority recommendations
and matters for congressional considerations that we reported in March 2023, we identified six prior
priority recommendations and one matter for congressional consideration. See GAO, Restaurant
Revitalization Fund: Opportunities Exist to Improve Oversight, GAO-22-105442 (Washington, D.C.:
July 14, 2022); Coronavirus Food Assistance Program: USDA Should Conduct More Rigorous
Reviews of Payments to Producers, GAO-22-104397 (Washington, D.C.: Sept. 8, 2022); Paid Tax
Return Preparers: IRS Efforts to Oversee Refundable Credits Help Protect Taxpayers but
Additional Actions and Authority Are Needed, GAO-23-105217 (Washington, D.C.: Nov. 30, 2022);
Emergency Rental Assistance: Treasury's Oversight Is Limited by Incomplete Data and Risk
Assessment, GAO-23-105410 (Washington, D.C.: Dec. 20, 2022); and Railroad Retirement Board:
Actions Needed to Improve the Effectiveness and Oversight of Continuing Disability Reviews,
GAO-18-287 (Washington, D.C.: Feb. 21, 2018).
Page 10 GAO-23-106761 Improper Payments
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