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GAO-24-106565: Fraud Risk Management: Agencies Should Continue Efforts to Implement Leading Practices

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GAO-24-106565, Fraud Risk Management: Agencies Should Continue Efforts to Implement Leading Practices, a Government Accountability Office Q&A report to congressional committees dated November 1, 2023. It reports results of a GAO survey of the 24 Chief Financial Officers Act of 1990 agencies on steps taken to manage fraud risks; for example, 20 agencies reported designating an entity responsible for fraud risk management. Agencies reported the availability of resources and tools for data analytics among challenges to managing fraud risks. It cites a September 2023 GAO estimate that fraud in the Department of Labor's Unemployment Insurance programs from April 2020 through May 2023 was likely between $100 billion and $135 billion.

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“GAO-24-106565: Fraud Risk Management: Agencies Should Continue Efforts to Implement Leading Practices.” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-24-106565-fraud-risk-management-agencies-should-continue-efforts-t-0e2f571b43/, SHA-256 1a4fef22d68a42a2aea15d89f162acacbe877dab9e3e6f219dfa7e68d6cfa3b0.

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                      U.S. Government Accountability Office

Fraud Risk Management: Agencies Should
Continue Efforts to Implement Leading
Practices
GAO-24-106565
Q&A Report to Congressional Committees
November 1, 2023



Why This Matters          Fraud poses a significant risk to the integrity of federal programs and erodes
                          public trust in government. 1 It contributes to financial and nonfinancial risks that
                          waste taxpayer dollars, threaten national security, or put consumers at risk.
                          Additionally, fraud—which involves obtaining something of value through willful
                          misrepresentation—continues to add to the improper payments made by the
                          government. 2 The public health crisis, economic instability, and increased flow of
                          federal funds associated with the COVID-19 pandemic have expanded
                          opportunities for fraud. The extent of fraud associated with COVID-19 programs
                          has not yet been fully determined. However, available measures and estimates
                          indicate substantial levels of fraud occurred. For example, in September 2023,
                          we estimated that the fraud in the Department of Labor’s Unemployment
                          Insurance programs during the pandemic—from April 2020 through May 2023—
                          was likely between $100 billion and $135 billion. 3
                          In February 2023, the Comptroller General of the United States testified before
                          the Committee on Oversight and Accountability of the U.S. House of
                          Representatives that federal agencies’ lag in implementing fraud risk
                          management was a major factor that contributed to the substantial levels of fraud
                          in pandemic relief programs. 4 Specifically, he testified that two of the major
                          factors contributing to agencies’ exposure to fraud in COVID-19 relief programs
                          were that they (1) did not strategically manage fraud risks; and (2) lacked
                          appropriate internal controls to prevent, detect, and recover fraudulent and other
                          improper payments.
                          In this report, we are providing information on federal agencies’ current fraud risk
                          management status, including reported agency challenges and incentives to
                          managing fraud risks. To conduct this work, GAO analyzed results from a survey.
                          GAO also reviewed narrative responses to select illustrative examples provided
                          by the agencies to support their responses, as well as relevant prior work,
                          including the status of related GAO recommendations made from July 28, 2015,
                          through August 31, 2023. We prepared this report under the authority of the
                          Comptroller General to conduct work to assist Congress with its oversight
                          responsibilities.


Key Takeaways             •   We surveyed the 24 Chief Financial Officers Act of 1990 (CFO Act) 5
                              agencies on the reported steps taken to manage fraud risks. 6 For example,
                              20 agencies reported designating an entity to be responsible for fraud risk
                              management.
                          •   Agencies described challenges that could impede their efforts to manage
                              fraud risks. For instance, agencies reported the availability of resources (such
Page 1                                                                             GAO-24-106565 Fraud Risk Management
                            as staff and funding) and tools for data analytics as being great or moderate
                            challenges.
                        •   Agencies described factors that could motivate them to manage fraud risk.
                            For example, agencies cited the ability to counter reputational impacts as a
                            factor that would motivate their efforts a lot or somewhat.
                        •   From July 2015 through August 2023, we made 173 recommendations to
                            over 40 agency or program offices related to certain areas aligned with
                            leading practices from GAO’s A Framework for Managing Fraud Risks in
                            Federal Programs (Fraud Risk Framework). 7 As of August 2023, agencies
                            needed to take additional action to fully address 95 of these
                            recommendations.
                        •   Our prior work also identified two congressional actions that could strengthen
                            oversight of federal agencies’ fraud risk management efforts: (1) reinstating
                            the requirement for agencies to report on their antifraud controls and fraud
                            risk management efforts in agency financial reports and (2) establishing a
                            permanent analytics center of excellence to aid the oversight community in
                            identifying improper payments and fraud.


What resources and      To help agencies and federal program managers strategically manage their fraud
recommendations has     risks—both during normal operations and in emergencies—GAO published the
GAO issued to help      Fraud Risk Framework in July 2015. The Fraud Risk Framework provides a
agencies manage fraud   comprehensive set of leading practices—organized into four components—to
                        guide agency managers when developing efforts to combat fraud (see fig.1).
risks?
                        Figure 1: The Fraud Risk Management Framework




                        Additionally, the Fraud Reduction and Data Analytics Act of 2015 (FRDAA)
                        required the Office of Management and Budget (OMB) to incorporate the leading
                        practices from the Fraud Risk Framework into guidelines for federal agencies. 8 In
                        March 2020, the Payment Integrity Information Act of 2019 (PIIA) replaced
                        FRDAA but maintained the requirements for OMB to provide guidance to
                        agencies in implementing controls that incorporate the Fraud Risk Framework. 9
                        In January 2022, we issued our antifraud resource—an online interactive tool that
                        can help inform federal officials, Congress, the media, and the public about key
                        characteristics of fraud schemes and provide resources for combating them. 10




Page 2                                                                         GAO-24-106565 Fraud Risk Management
                        Our prior work has highlighted areas in which federal agencies need to take
                        additional actions to help ensure they are effectively managing fraud risks
                        consistent with leading practices, such as by designating an entity to lead fraud
                        risk management activities. Specifically, from July 2015 through August 2023, we
                        made 20 recommendations to federal agencies in this area. These include
                        recommendations to dedicate an entity to oversee fraud risk management
                        activities or to document the fraud risk management responsibilities of the
                        antifraud entity. Of the 20 recommendations, 18 had not been implemented as of
                        August 2023.
                        In addition, our prior work has included recommendations for agencies to use
                        data analytics to better manage fraud risk. Specifically, from July 2015 through
                        August 2023, we made 47 recommendations to federal agencies in this area.
                        These include recommendations to design and implement data-analytics
                        activities to prevent and detect fraud, such as using data matching to verify self-
                        reported information. Of the 47 recommendations, 25 had not been implemented
                        as of August 2023.


How many agencies       Twenty of the 24 CFO Act agencies stated that they have an entity that is
have designated an      responsible for fraud risk management activities (see fig. 2).
entity that is
                        Figure 2: Chief Financial Officers Act Agencies That Reported Designating an Entity to Be
responsible for         Responsible for Fraud Risk Management Activities
managing fraud risks?




                        Of the four CFO Act agencies that responded that there is no entity responsible
                        for fraud risk management activities within their agency, one reported plans to
                        designate such an entity in the future.
                        As discussed in GAO’s Fraud Risk Framework, when agencies formally
                        designate an entity to design and oversee fraud risk management activities, their
                        efforts can be more visible across the agency, particularly to executive
                        leadership. Such an entity can demonstrate a senior-level commitment to
                        integrity and combating fraud.




Page 3                                                                               GAO-24-106565 Fraud Risk Management
What steps have          CFO Act agencies reported their status in implementing other leading practices
agencies taken to        from GAO’s Fraud Risk Framework, such as identifying and assessing risks to
implement other          determine a fraud risk profile (see fig. 3).
leading practices from
                         Figure 3: Chief Financial Officers Act Agencies’ Reported Status in Implementing Other
GAO’s Fraud Risk         Leading Practices from GAO’s Fraud Risk Framework
Framework?




                         Twenty of the 24 CFO Act agencies reported that they design and implement
                         specific control activities to prevent and detect fraud on a regular and ongoing
                         basis. For example, in response to our survey, the Department of Energy
                         reported that it has a Data Analytics Working Group that is implementing a data
                         analytics program to enhance the detection of fraud, payment integrity, and data-
                         driven decision-making. The Fraud Risk Framework cites data matching, data
                         mining, and other data analytics as examples of control activities that can help to
                         prevent and detect fraud. Such techniques also can enable agencies to identify
                         improper payments that have already been awarded, thus assisting agencies in
                         recovering these dollars.


What factors are         CFO Act agencies’ survey responses indicated the following factors to be
important to agencies    extremely or very important when managing fraud risks:
when managing fraud
risks?                       •   Resources to dedicate to fraud risk management
                             •   The amount lost to fraud
                             •   Potential for bad publicity or reputational impact




Page 4                                                                                GAO-24-106565 Fraud Risk Management
                        Figure 4 shows additional information from CFO Act agencies about the
                        importance of various factors to the maturity of their fraud risk management
                        efforts.

                        Figure 4: Factors Chief Financial Officers (CFO) Act Agencies Reported as Important to the
                        Maturity of their Fraud Risk Management Efforts




                        aOne of the 24 CFO Act agencies did not provide a response for this factor within the survey.




What challenges do      CFO Act agencies’ survey responses indicated the following factors as a great or
agencies face in        moderate challenge to their fraud risk management efforts:
managing fraud risks?
                             •    Having available staffing, funding, or other resources to conduct fraud risk
                                  management activities
                             •    Having and using tools and techniques for data analytics
                             •    Having available expertise to conduct fraud risk management activities

                        Figure 5 shows additional information from CFO Act agencies about reported
                        challenges to their fraud risk management efforts.



Page 5                                                                                             GAO-24-106565 Fraud Risk Management
         Figure 5: Reported Challenges to Chief Financial Officers Act Agencies’ Fraud Risk
         Management Efforts




         As shown in figure 5, 21 of the 24 CFO Act agencies considered the factor
         “having and using tools and techniques for data analytics” a great or moderate
         challenge to managing fraud risks. For example, the National Aeronautics and
         Space Administration stated it could benefit from investments in data analytics
         tools and capabilities to identify current fraud schemes.

         When we surveyed federal agencies in 2018, including the 24 CFO Act agencies,
         the top challenges they reported generally related to staffing and resources.
         Specifically, those agencies most frequently indicated the following factors as a
         great or moderate challenge: (1) availability of resources, (2) limited tools and
         techniques for data analytics, and (3) lack of available expertise. 11

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What factors could      CFO Act agencies’ survey responses indicated the following factors as highly or
strengthen an agency’s somewhat motivating to their fraud risk management efforts:
efforts to manage fraud
risks?                    • Congressionally directed prioritization of budget funds for program
                                   integrity improvements
                               •   Ability to counter reputational impacts if fraud is found
                               •   Ability to demonstrate financial returns from fraud risk management

                           Figure 6 shows additional information about factors that the agencies reported.

                           Figure 6: Factors Chief Financial Officers Act Agencies Reported as Motivating to
                           Increasing the Maturity of Their Fraud Risk Management Efforts




                           As shown in figure 6, 19 of the 24 CFO Act agencies reported that the “ability to
                           counter reputational impacts if fraud is found” could motivate an agency’s fraud
                           risk management efforts a lot or somewhat. For example, the Department of
                           Homeland Security told us that it is driven to keep fraud to a minimum because
                           fraud, waste, and abuse would reduce the public’s confidence in the department.

                           Our prior work has also identified actions that Congress can take to strengthen
                           fraud risk management practices across the government. 12 The first would be to
                           reinstate the requirement for agencies to report on their antifraud controls and
                           fraud risk management efforts in agency financial reports. This can help facilitate

Page 7                                                                                  GAO-24-106565 Fraud Risk Management
                   congressional oversight and focus agency attention on strategic fraud risk
                   management—both during normal operations and in emergencies—and help
                   align their efforts with leading practices. 13 The second would be to establish a
                   permanent analytics center of excellence to aid the oversight community in
                   identifying improper payments and fraud. Establishing such capability would
                   further aid the oversight community’s efforts to assess and identify fraud, as well
                   as to help agencies identify areas of potential fraud risks so that they can
                   implement preventive and detective controls or evaluate existing controls for
                   opportunities for improvement. Creating a permanent government-wide analytics
                   capability could also yield future financial benefits, both through identifying
                   potentially improper and fraudulent payments that the government could seek to
                   recover and by identifying vulnerabilities that the government could address to
                   prevent similar future payments.


Agency Comments    We provided a draft of this report to OMB for review and comment. OMB did not
                   have any comments on the report.


How GAO Did This   We surveyed the 24 CFO Act agencies for information on their fraud risk
Study              management efforts, directing the survey to the CFO of each agency. We asked
                   that the CFOs, or their designee(s), answer the questionnaire at the agency-wide
                   level, relying on their perspective, as well as coordinating their responses with
                   appropriate agency staff. To develop the questionnaire, we reviewed the leading
                   practices from GAO’s Fraud Risk Framework and our 2018 survey on agencies’
                   status in implementing fraud risk management requirements. We incorporated
                   comments from internal and external reviewers, including our survey specialist
                   and OMB officials. We then 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. Our survey asked
                   questions at the departmental level. However, responses may reflect activities at
                   the program or operation level or for multiple programs or operations. Responses
                   do not necessarily reflect that CFO Act agencies are in alignment with leading
                   practices from GAO’s Fraud Risk Framework.
                   We also analyzed closed-end responses and reviewed narrative responses to
                   select illustrative examples provided by the agencies to support their responses.
                   In addition, we reviewed relevant GAO reports for (1) the status of related GAO
                   recommendations made from July 28, 2015, which coincides with the issuance of
                   the Fraud Risk Framework, through August 31, 2023; and (2) examples of steps
                   agencies have taken to implement fraud risk management activities, including
                   challenges and incentives to preventing, detecting, and responding to fraud. We
                   also interviewed OMB officials about these activities.
                   We conducted this performance audit from January 2023 to November 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-24-106565 Fraud Risk Management
List of Addressees
                     The Honorable Gary C. Peters
                     Chairman
                     The Honorable Rand Paul, M.D.
                     Ranking Member
                     Committee on Homeland Security and Governmental Affairs
                     United States Senate

                     The Honorable James Comer
                     Chairman
                     The Honorable Jamie Raskin
                     Ranking Member
                     Committee on Oversight and Accountability
                     House of Representatives


GAO Contact          For more information, contact: Rebecca Shea, Director, Forensic Audits and
Information          Investigative Service, at (202) 512-6722 or SheaR@gao.gov.
                     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: Jonathon Oldmixon (Assistant Director), Paulissa Earl
                     (Analyst in Charge), David Dornisch, Colin Fallon, Kristina Hammon, Barbara
                     Lewis, Brooke Linsenbardt, Lydie Loth, Maria McMullen, James Murphy, Tina
                     Paek, Isaac Pavkovic, Noah Riley, Sylvia Simioni, and Erin Villas.
                     Connect with GAO on Facebook, Flickr, Twitter, and YouTube. Subscribe to our
                     RSS Feeds or Email Updates. Listen to our Podcasts.
                     Visit GAO on the web at https://www.gao.gov.
                     This work of the United States may include copyrighted material, details at
                     https://www.gao.gov/copyright


Endnotes
                     1Whether an act is fraudulent is determined through the judicial or other adjudicative system and is

                     beyond management’s professional responsibility for assessing risk. GAO, Standards for Internal
                     Control in the Federal Government, GAO-14-704G (Washington, D.C.: Sept. 10, 2014).

                     2An improper payment is defined 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).
                     While not all improper payments are the result of fraud, all payments made as a result of fraudulent
                     activities are considered to be improper payments. GAO, Fraud Risk Management: Key Areas for
                     Federal Agency and Congressional Action, GAO-23-106567 (Washington, D.C.: Apr. 13, 2023).

                     3GAO, Unemployment Insurance: Estimated Amount of Fraud during Pandemic Likely Between

                     $100 Billion and $135 Billon, GAO-23-106696 (Washington, D.C.: Sept. 12, 2023).

                     4GAO, Emergency Relief Funds: Significant Improvements Are Needed to Address Fraud and

                     Improper Payments, GAO-23-106556 (Washington, D.C.: Feb. 1, 2023).

                     5The 24 agencies listed in the Chief Financial Officers Act of 1990 (CFO Act), as amended, are the

                     Departments of Agriculture, Commerce, Defense, Education, Energy, Health and Human Services,
                     Homeland Security, Housing and Urban Development, the Interior, Justice, Labor, State,


Page 9                                                                                  GAO-24-106565 Fraud Risk Management
          Transportation, the Treasury, and Veterans Affairs, as well as the Agency for International
          Development, Environmental Protection Agency, General Services Administration, National
          Aeronautics and Space Administration, National Science Foundation, Nuclear Regulatory
          Commission, Office of Personnel Management, Small Business Administration, and Social Security
          Administration. Pub. L. No. 101-576, § 205, 104 Stat. 2838 (1990), codified as amended at 31
          U.S.C. § 901(b). The CFO Act also established the CFO Council and designated the CFOs in the
          act, as well as senior officials of the Office of Management and Budget (OMB) and the Department
          of the Treasury, to work on such matters as consolidation and modernization of financial systems.
          31 U.S.C. § 901 note.
          6Survey Questions: Does your agency have a designated entity (or entities) that is responsible for

          fraud risk management activities? What is your agency’s status in (a) creating an organizational
          culture to combat fraud at all levels of the agency, (b) identifying and assessing risks to determine
          the fraud risk profile for programs or operations, (c) designing and implementing specific control
          activities to prevent and detect fraud, (d) monitoring fraud risk management activities for programs
          and operations, (e) evaluating the monitoring process and overall outcomes of fraud risk
          management activities, and (f) adapting fraud risk management activities based on the results of
          your evaluations? How important, if at all, are the following to your agency’s fraud risk management
          maturity level that you reported in the prior section? The “prior section” refers to the preceding
          survey questions on the steps agencies have taken to implement leading practices from GAO’s
          Fraud Risk Framework. How much of a challenge, if at all, does each factor pose to your agency’s
          fraud risk management efforts? How much, if at all, would the following factors motivate your
          agency to increase its maturity in fraud risk management efforts?
          7GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP (Washington,

          D.C.: July 28, 2015).
          8Pub. L. No. 114-186, 130 Stat. 546 (2016).

          9The Office of Management and Budget (OMB) incorporated guidelines to meet the requirements of

          the Fraud Reduction and Data Analytics Act of 2015 into its July 2016 update of Circular A-123,
          Management’s Responsibility for Enterprise Risk Management and Internal Control. OMB,
          Management’s Responsibility for Enterprise Risk Management and Internal Control, OMB Circular
          A-123 (Washington, D.C.: July 15, 2016). The Payment Integrity Information Act of 2019 requires
          these guidelines to remain in effect, subject to modification by OMB as necessary and in
          consultation with GAO. Pub. L. No. 116-117, § 2(a), 134 Stat. 113, 131-132 (2020), codified at 31
          U.S.C. § 3357.
          10GAO, “GAO Antifraud Resource” (Washington, D.C.: Jan. 10, 2022), accessed September 2023,

          https://gaoinnovations.gov/antifraud_resource/. We developed GAO’s Antifraud Resource to help
          federal officials and the public better understand and help combat federal fraud. The resource
          includes GAO’s Conceptual Fraud Model, which was developed to determine the nature of known
          fraud, both financial and nonfinancial, that affects federal programs and operations. The primary
          intended users of GAO’s Antifraud Resource are managers in the U.S. federal government;
          however, it may also be applicable to state, local, and foreign government agencies, as well as
          nonprofit entities and others responsible for fraud risk management.
          11In 2018, we found that agencies identified challenges with the Office of Management and

          Budget’s (OMB) Fraud Reduction and Data Analytics Act of 2015 implementation guidelines, which
          are incorporated into OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk
          Management and Internal Control. GAO recommended that OMB enhance its agency guidelines for
          establishing internal controls, and OMB did so. For this report, CFO Act agencies indicated within
          their survey responses that the factor “sufficiency of OMB guidelines on implementing fraud risk
          management” is less of a challenge when conducting their fraud risk management activities. GAO,
          Fraud Risk Management: OMB Should Improve Guidelines and Working-Group Efforts to Support
          Agencies’ Implementation of the Fraud Reduction and Data Analytics Act, GAO-19-34
          (Washington, D.C.: Dec. 4, 2018).
          12GAO, 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).
          13The Fraud Reduction and Data Analytics Act of 2015 and the Payment Integrity Information Act of

          2019 required agencies to report on their antifraud controls and fraud risk management efforts in
          their annual financial reports. However, the requirement to report such information ended with the
          fiscal year 2020 annual financial report and, since then, there has been no similar requirement for
          agencies to report on their efforts to manage fraud risks. GAO-22-105715.




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