GAO-25-107552: Improper Payments: Agency Reporting of Payment Integrity Information
Summary
GAO-25-107552, Improper Payments: Agency Reporting of Payment Integrity Information, a Government Accountability Office report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives, dated January 23, 2025. It is GAO's eighth quarterly report under House Report 117-389 and examines OMB's and inspectors general roles in implementing the Payment Integrity Information Act of 2019 and how agencies report payment integrity information. It states that agencies have reported cumulative improper payment estimates of about $2.8 trillion since fiscal year 2003, including $161.5 billion for fiscal year 2024. It reports that all 10 noncompliant agencies reported plans to come into compliance to OMB,, and that nine CFO Act agencies were noncompliant for 2 consecutive years.
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U.S. Government Accountability Office
Improper Payments: Agency Reporting of
Payment Integrity Information
GAO-25-107552
Report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives
January 23, 2025
Why This Matters Improper payments are a long-standing and significant problem in the federal
government. Since fiscal year 2003, executive branch agencies (agencies) have
reported cumulative improper payment estimates of about $2.8 trillion, including
$161.5 billion for fiscal year 2024. The Payment Integrity Information Act of 2019
(PIIA) requires agencies to manage improper payments by identifying risks,
taking corrective actions, and estimating and reporting on improper payments in
programs they administer. PIIA also requires each agency’s inspector general
(IG) to issue an annual report on compliance with applicable PIIA criteria.
Agencies’ understanding of the requirements and related key concepts of and
proper oversight of compliance with PIIA criteria is important to more effective
detection and prevention of improper payments. To provide relevant information
on improper payments to Congress and the public, agencies’ reported payment
integrity information must be timely, complete, accurate, and accessible.
The Office of Management and Budget (OMB) plays a key role in developing
guidance for agencies to estimate and report on improper payments. OMB
Circular No. A-123, appendix C, the current version of which OMB issued as
Memorandum M-21-19, includes guidance for IGs on how to determine agency
compliance with applicable PIIA criteria. It also includes guidance for agencies on
the corrective actions PIIA requires of them if they are found noncompliant.
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 eighth such report. It examines OMB’s
and IGs’ roles in implementing PIIA and how agencies report payment integrity
information, including instances of noncompliance and related plans to come into
compliance that PIIA requires and OMB guidance reflects.
Key Takeaways • The law requires agencies to report certain payment integrity information as
part of their annual financial statements. OMB guidance specifies this
reporting should include a hyperlink to PaymentAccuracy.gov, which is where
agencies’ payment integrity information is posted. 1 OMB’s guidance to
agencies indicates that the payment integrity information posted on
PaymentAccuracy.gov fulfills certain PIIA reporting requirements.
• In IG reports issued in 2023, 10 of the Chief Financial Officers (CFO) Act
agencies were found noncompliant with PIIA criteria for fiscal year 2022. 2
These agencies reported their plans to come into compliance on
PaymentAccuracy.gov. PIIA requires such agencies to report to the
appropriate authorizing and appropriations committees of Congress on their
plans to come into compliance. All 10 of the noncompliant agencies reported
these plans to OMB through the annual data call in accordance with OMB
guidance. The plans were then placed on PaymentAccuracy.gov, and the
Page 1 GAO-25-107552
agencies included a link to PaymentAccuracy.gov in their annual financial
statements.
• According to PaymentAccuracy.gov, nine CFO Act agencies were
noncompliant with PIIA criteria for one or more of the same programs or
activities for 2 consecutive years (fiscal years 2021 and 2022) and were
required to propose to OMB additional program integrity proposals that would
help them come into compliance. However, OMB guidance did not direct
such agencies to submit program integrity proposals until September 2024.
OMB will consider the agencies’ proposals and include as needed any
additional funding requests in the President’s Budget for fiscal year 2026,
which is due in February 2025.
• OMB staff told us they worked with congressional committees while the PIIA
bill was being drafted. They stated that since implementing the law, OMB has
not received congressional feedback on the usefulness of
PaymentAccuracy.gov to report payment integrity information. Congressional
committee staffers we interviewed expressed varying levels of familiarity with
data available on PaymentAccuracy.gov and offered suggestions for
improvements to payment integrity reporting.
What are improper
payments? PIIA defines an improper payment as one that should not have been made or
was made in an incorrect amount under statutory, contractual, administrative, or
other legally applicable requirements. Improper payments include duplicate
payments as well as any payment made to an ineligible recipient; for an ineligible
good or service; and for a good or service not received, except for those
payments where authorized by law. 3
PIIA includes multiple requirements for OMB, including the following:
What is OMB’s role
in implementing • Identifying a list of high-priority federal programs for greater levels of
PIIA? oversight and review.
• Making agencies’ reports on high-priority programs available on a public
website.
• Developing and promulgating guidance for the IGs’ PIIA compliance
determination reports.
• Prescribing guidance for agencies on the form and content of their reports on
actions to reduce improper payments, recovery actions, and government-
wide reporting. OMB issued Memorandum M-21-19, which informs agencies
on how to meet the PIIA requirements to address 1 year or multiple
consecutive years of noncompliance. OMB also issued annual data call
guidance for agencies to report in-depth payment integrity information for
publication on PaymentAccuracy.gov in response to this requirement.
• Submitting to specified congressional committees and GAO an annual report
for the preceding fiscal year on actions agencies have taken to report
information regarding improper payments and recover them.
Page 2 GAO-25-107552
What does PIIA PIIA includes multiple requirements agencies must follow in reporting improper
require of payment information. For example, PIIA requires that agencies
agencies when
• assess risk and publish improper payments estimates for each program or
reporting
activity that meets certain requirements,
improper payment
information? • include any required improper payment estimates in the accompanying
materials to the annual financial statement of the agency, 4 and
• publish corrective action plans and improper payment reduction targets with
each reported estimate.
Where is agency Accessing specific agency information on PaymentAccuracy.gov is a multistep
improper payment process. Figure 1 depicts the steps a website user would follow to review the
information located on details of an agency’s compliance with PIIA criteria.
PaymentAccuracy.gov?
Figure 1: Process for Reviewing Agency-Reported Information on Compliance with Payment
Integrity Information Act of 2019 (PIIA) Criteria on PaymentAccuracy.gov
Page 3 GAO-25-107552
What is the IG’s Agency IGs conduct annual reviews of agency compliance with PIIA criteria and
role in reviewing submit their compliance reports to the head of the agency, certain congressional
agency compliance committees, and GAO, in accordance with PIIA requirements.
with PIIA criteria?
IGs follow guidance from the Council of the Inspectors General on Integrity and
Efficiency to conduct their annual reviews and determine whether the agencies
complied with PIIA criteria. 5 This guidance directs IGs to review information
reported on PaymentAccuracy.gov and analyze source data to ensure accuracy
and completeness of payment integrity information in the financial statements
and accompanying materials.
OMB Memorandum M-21-19 also provides guidance to IGs for reporting on
agency compliance. The IG compliance review begins when an agency publishes
its annual financial statements and the accompanying materials to the annual
financial statements, which is typically in mid-November. The IG office is to
publish its compliance report within 180 days after the publication date of the
agency’s annual financial statements or the publication date of the accompanying
materials, whichever is later. 6 OMB guidance directs the IG office to publish its
final report on the agency’s PIIA compliance on a public central website and
submit it to OMB. 7
What are agencies When IGs find agencies to be noncompliant with PIIA criteria for a program or
required to do activity, PIIA requires agencies to report to the appropriate authorizing and
when IGs find them appropriations committees of Congress on their plans to come into compliance.
noncompliant in a These plans must include
fiscal year? • measurable milestones to be accomplished in order to achieve compliance
for each program;
• the designation of a senior official accountable for the agency’s progress in
coming into compliance for each program; and
• the establishment of an accountability mechanism, such as a performance
agreement, with appropriate incentives and consequences tied to the
success of the senior official in leading the agency’s efforts to come into
compliance. 8
OMB Memorandum M-21-19 directs noncompliant agencies to provide their
plans to come into compliance in the next annual data call, during which in-depth
payment integrity information is collected and published on
PaymentAccuracy.gov. OMB guidance states that this information serves as the
plan agencies are required to submit to the appropriate authorizing and
appropriations committees of Congress.
PaymentAccuracy.gov includes certain payment integrity information that PIIA
requires of agencies. Website users can access agency information by fiscal
year using the “Supplemental Information” website tab under the “Annual
Improper Payments Dashboard” heading.
Which agencies IGs found 10 CFO Act agencies to be noncompliant with PIIA criteria for fiscal
were reported as year 2022 (see table 1).
noncompliant in
2022?
Page 4 GAO-25-107552
Table 1: Chief Financial Officers Act Agencies Reported as Noncompliant with Payment
Integrity Information Act of 2019 (PIIA) Criteria for Fiscal Year 2022
Agency (program) Agency noncompliant for Reported information on
fiscal year 2022 per agency’s plan to come into
PaymentAccuracy.gov compliance on
PaymentAccuracy.gov in
2023
Department of Agriculture Yes Yes
- Farm Service
Agency’s Agriculture
Risk Coverage and
Price Loss Coverage
- Farm Service
Agency’s Trade
Mitigation Program
- Farm Service
Agency’s Livestock
Forage Disaster
Program
- Farm Service
Agency’s Emergency
Conservation
Program
- Staff Office - Office of
the Chief Information
Officer
Department of Defense Yes Yes
- Civilian Pay
- Commercial Pay
- DoD Travel Pay
- Military Health
Benefits–Healthcare
- Military Pay–Army
- Military Pay–Navy
- Military Pay–Air Force
- Military Pay–Marine
Corps
- Military Retirement
Department of Education Yes Yes
- Title I
- Special Education
- Education
Stabilization Fund
Department of Health and Yes Yes
Human Services
- Medicaid
- Medicare Fee-for-
Service
- Children’s Health
Insurance Program
- Advance Premium
Tax Credit
- COVID-19 Uninsured
Program
- Foster Care
- Head Start
- Temporary Assistance
for Needy Families
Page 5 GAO-25-107552
Agency (program) Agency noncompliant for Reported information on
fiscal year 2022 per agency’s plan to come into
PaymentAccuracy.gov compliance on
PaymentAccuracy.gov in
2023
Department of Homeland Yes Yes
Security
- Federal Emergency
Management
Agency’s Funeral
Assistance Program
Department of Housing and Yes Yes
Urban Development
- Office of Public and
Indian Housing’s
Tenant Based Rental
Assistance
- Office of Multifamily
Housing's Project-
Based Rental
Assistance
Department of Labor Yes Yes
- Unemployment
Insurance
- Pandemic
Unemployment
Assistance
Department of the Treasury Yes Yes
- Earned Income Tax
Credit
- Additional Child Tax
Credit
- American Opportunity
Tax Credit
- Net Premium Tax
Credit
Department of Veterans Affairs Yes Yes
- Pension
- Purchased Long-Term
Services and Support
Small Business Administration Yes Yes
- 7(a) Loan Guaranty
Purchases
- Disaster Assistance
Loans
- COVID Economic
Injury Disaster Loan
- Economic Injury
Disaster Loan
Emergency
Assistance
- Paycheck Protection
Program
- Restaurant
Revitalization Fund
- Shuttered Venues
Operator Grant
Source: GAO analysis of PaymentAccuracy.gov data and IG PIIA compliance reviews for fiscal year 2022. │ GAO-25-107552
Note: Inspectors general identified the above agencies as noncompliant with PIIA criteria and specified programs or activities that contributed to the
findings of noncompliance.
Page 6 GAO-25-107552
PIIA requires agencies to include certain improper payment information in the
accompanying materials to their annual financial statements. 9 OMB’s Circular A-
136 directs agencies to include in the agency financial report a hyperlink to
PaymentAccuracy.gov. 10 OMB also directs noncompliant agencies to report their
plans to come into compliance through the annual data call, which occurs in
October following the IG’s determination of the agency’s compliance with PIIA
criteria. OMB posts the agencies’ information reported through the annual data
call on PaymentAccuracy.gov.
Each of the 10 agencies found noncompliant for 2022 included improper
payment information in the accompanying materials to their annual financial
statements and made reference there to PaymentAccuracy.gov, typically in a
brief statement indicating that more detailed information could be found on the
website.
What are agencies When an agency has been noncompliant for 2 consecutive fiscal years for the
required to do when same program or activity, PIIA requires the agency to submit to OMB additional
IGs find them program integrity proposals that would help the agency come into compliance. 11
noncompliant for 2 During preparation of the President’s Budget for 2025, OMB delayed
implementation of program integrity proposal submissions for 1 year due to the
consecutive years?
timing of issuing budget preparation guidance to agencies. Additional
requirements in PIIA address what agencies must do in instances of 3 and 4 or
more consecutive years of noncompliance for the same program or activity.
OMB Memorandum M-21-19 provides detailed guidance for agencies with 2
consecutive years of noncompliance on submitting the required additional
proposals to OMB. This guidance directs agencies to include their proposals in
their next annual budget submission supporting the development of the annual
President’s Budget. The proposals must describe how each request, such as a
legislative or administrative reform, would help the program come into
compliance. OMB staff stated that the proposals may take the form of narrative
documents, spreadsheets, or slides.
According to its staff, OMB will for the first time provide guidance on the process
for submitting program integrity proposals for 2 consecutive years of
noncompliance with PIIA criteria during development of the fiscal year 2026
President’s Budget, the process for which began in September 2024. Staff stated
that the guidance would cover agencies with 2 consecutive years of
noncompliance for Years 1 and 2 of PIIA implementation (fiscal years 2021 and
2022). OMB finalized its budget preparation guidance for agencies for the fiscal
year 2025 President’s Budget in spring 2023, before IGs issued compliance
reports for fiscal year 2022 in May–June 2023. Because agencies had already
begun budget package preparation, OMB staff stated that it was too late in the
cycle for agencies with 2 consecutive years of noncompliance to be expected to
include program integrity proposals in their packages. Figure 2 shows the
timeline illustrating key milestones in the improper payments reporting process.
Page 7 GAO-25-107552
Figure 2: Timeline of Key Milestones in the Improper Payments Reporting Process
Which agencies were According to data reported on PaymentAccuracy.gov, nine CFO Act agencies
reported as were noncompliant with PIIA criteria for one or more programs or activities for 2
noncompliant on consecutive years (fiscal years 2021 and 2022). These agencies, with the
PaymentAccuracy.gov exception of the Department of Homeland Security (DHS), are the same as those
identified in table 1 as noncompliant in 2022. DHS was found noncompliant with
for 2 consecutive
PIIA criteria at the agency level in 2021 and 2022; however, DHS IG attributed
years? the findings of noncompliance to different programs in each year.
What is OMB’s role in OMB is responsible for developing the annual President’s Budget, which the
President is required to submit to Congress no later than the first Monday in
developing the
February, prior to the start of the upcoming fiscal year. 12 OMB coordinates the
President’s Budget, development of the proposal by issuing circulars, memorandums, and guidance
including information documents to the heads of the agencies. Agencies then prepare their budget
PIIA requires? requests in accordance with these instructions and guidance.
OMB’s coordination of the budget-development process includes
• issuing OMB Circular No. A-11 and other related guidance to agencies in the
spring and summer of each year, 13
• setting timelines for agencies to provide budget requests to OMB,
• reviewing the requests and providing budget approval decisions to agencies,
and
• finalizing the content of the President’s Budget.
To what extent has
OMB communicated OMB staff stated that they communicated with congressional staff when
with Congress about Congress was drafting PIIA, including discussions about using
PaymentAccuracy.gov to report improper payment information from agencies to
PIIA reporting?
ensure that the website included information that would meet congressional
needs. In particular, OMB sought feedback about the information and its display
that congressional staff had already used and would like to see for future use on
PaymentAccuracy.gov.
Page 8 GAO-25-107552
OMB staff stated that after initial implementation they made efforts to ensure
congressional staff knew that PIIA information is centrally located on
PaymentAccuracy.gov. Specifically, OMB directs agencies to include a brief
summary of PIIA and associated reporting practices in agency financial reports
and performance and accountability reports that agencies are required to submit
to Congress each year. OMB guidance states that each agency’s annual financial
statement must include a link to the PIIA reporting information on
PaymentAccuracy.gov. These links direct congressional staff and the public to
that website in order to view more complete and detailed payment integrity
information.
OMB staff stated that they have not received or sought congressional feedback
on the usefulness of PaymentAccuracy.gov for reporting payment integrity
information since they made updates to the information and its display on the
website from 2020 through 2023. They did not identify any current plans to
actively seek additional feedback from Congress regarding the updates.
What have Selected congressional committee staff we met with provided their perspectives
congressional staff about PaymentAcccuracy.gov and its role in providing information on improper
noted about payments for their oversight work. None of the committee staff we interviewed
PaymentAccuracy.gov? said they had been involved in communications with OMB during drafting of PIIA.
Some committee staffers stated that they were familiar with
PaymentAccuracy.gov and used it in their oversight work. Some expressed
appreciation for the website and cited their belief in its utility. Some noted
technical challenges to accessing or analyzing information. For example, one
staffer noted that a pop-up window obscured certain text included in “The
Numbers” section of the website, making the information hard to read. The staffer
also described datasets taking a long time to load. Another staffer described the
website as “clunky” and suggested that presenting government-wide data, in
addition to presenting data for individual agencies, could improve it.
Several staffers familiar with the website suggested improvements to the
“Program Scorecard” section of the website. For example, one staffer expressed
a desire for greater detail about the agency’s identification of root causes of
improper payments. Another staffer suggested that information for all programs,
not only high-priority programs, be included in this section, for comparison. This
staffer stated that without data for other programs that are not high priority, the
website user has no way to compare the magnitude of improper payments
across all programs.
Multiple committee staffers stated they were completely or somewhat unfamiliar
with the existence of the website and the payment integrity information available
there. They said they were more likely to consult agency financial reports, agency
websites, or other publicly available resources for such information. Taking steps
to clarify where key payment integrity information, such as noncompliant
agencies’ plans for coming into compliance, is reported could increase
transparency of that information and facilitate congressional oversight.
Conclusions
Improper payments are a long-standing and significant problem in the federal
government. OMB plays a key role in developing guidance for agencies to
estimate and report on improper payments, estimates of which totaled
approximately $161.5 billion for fiscal year 2024.
While OMB’s process for including noncompliant agencies’ plans to come into
compliance on PaymentAccuracy.gov is intended to address PIIA’s requirement
Page 9 GAO-25-107552
for reporting to the appropriate authorizing and appropriations committees of
Congress, this approach to reporting payment integrity information may be
ineffective. Specifically, the absence of explicit information in agency financial
reports specifying that plans to come into compliance are available on
PaymentAccuracy.gov, lack of congressional awareness about the information
included there, and potential expectations of direct communication between
noncompliant agencies and congressional committees as described in PIIA could
compromise Congress’s ability to obtain key payment integrity information
needed to conduct effective oversight of improper payments.
Recommendation for We recommend that the Director of the Office of Management and Budget clarify
Executive Action that agencies found noncompliant with PIIA criteria should state explicitly in their
annual financial statements that agency plans to come into compliance are
available on PaymentAccuracy.gov, or otherwise directly communicate such
plans to the appropriate congressional committees. (Recommendation 1)
Agency Comments We provided a draft of this report to OMB for review and comment. OMB did not
have any comments on the report and agreed with our recommendation.
How GAO Did This To conduct this work, we reviewed relevant federal statutes, standards, and
Study guidance related to managing improper payments, as well as relevant GAO
reports. We compiled and analyzed this information to describe the process
agencies are to follow in reporting noncompliance with PIIA criteria and related
corrective actions. We reviewed agency financial reports and IG PIIA compliance
reviews for the 24 CFO Act agencies for fiscal years 2021, 2022, and 2023 to
confirm language describing where payment integrity information is reported and
identify the agencies found noncompliant with PIIA criteria. Additionally, we
accessed PaymentAccuracy.gov to review noncompliant agencies’ reports of
plans to come into compliance and to outline the steps a website user would
follow to access information on an agency’s compliance with PIIA criteria.
Further, we interviewed OMB staff to gain an understanding of the guidance
OMB provides to agencies for complying with PIIA requirements. We also
obtained input from a nongeneralizable convenience sample of 15 congressional
staffers from a variety of budget and finance–related committees about their
familiarity with and use of PaymentAccuracy.gov for payment integrity oversight
purposes. The perspectives of the congressional committee staff we interviewed
in the context of individual website user experiences may not be representative
of all relevant congressional committee staff. However, their perspectives provide
insights into PaymentAcccuracy.gov and its usefulness for committee staff’s
oversight work.
We conducted this performance audit from April 2024 to December 2024 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 10 GAO-25-107552
List of Addressees The Honorable David Valadao
Chairman
The Honorable Adriano Espaillat
Ranking Member
Subcommittee on Legislative Branch
Committee on Appropriations
House of Representatives
We are sending copies of this report to the appropriate congressional
committees. In addition, the report is available at no charge on the GAO website
at https://www.gao.gov.
GAO Contact For more information, contact: M. Hannah Padilla, Director, Financial
Information Management and Assurance, PadillaH@gao.gov, (202) 512-5683.
Sarah Kaczmarek, Managing Director, Public Affairs, KaczmarekS@gao.gov,
(202) 512-4800.
A. Nicole Clowers, Managing Director, Congressional Relations,
ClowersA@gao.gov, (202) 512-4400.
Staff Acknowledgments: Shirley Abel (Assistant Director), Mary Ann Hardy
(Analyst in Charge), Gary Wiggins, Anthony Clark, Giovanna Cruz, Jared Smith,
Jason Kirwan, and Amanda Stogsdill made key contributions to this report.
Connect with GAO on Facebook, Flickr, X, and YouTube. Subscribe to our RSS
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Visit GAO on the web at https://www.gao.gov.
This is a work of the U.S. government but may include copyrighted material. For
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Endnotes
1PaymentAccuracy.gov is a website that the U.S. Department of the Treasury, in coordination with
the U.S. Department of Justice and Office of Management and Budget, established to create a
centralized location to publish information about improper payments made to individuals,
organizations, and contractors.
2The Chief Financial Officers Act of 1990, Pub. L. No. 101-576, 104 Stat. 2838 (codified as
amended in scattered sections of 31 U.S.C.), among other things, established chief financial
officers to oversee financial management activities at 23 major executive departments and
agencies. The list now includes 24 entities, which are often referred to collectively as CFO Act
agencies and is codified as amended at 31 U.S.C. § 901(b). PIIA includes six criteria for
compliance, which can be found at 31 U.S.C. § 3351. OMB M-21-19 expands these criteria to 10
by breaking them into subcomponents and, in some cases, adding new elements.
331 U.S.C. § 3351(4). Improper payments and fraud are two distinct concepts that are not
interchangeable but are related. For example, while all fraudulent payments are considered
improper, not all improper payments are due to fraud. Similarly, there are types of fraudulent
activity that do not result in improper payments (e.g., nonfinancial fraud). Improper payments of
federal funds, including those that state and local governments administered, may include different
types of erroneous payments. Some improper payments are fraud related and some are not. For
example, a non-fraud-related improper payment might result from unintentional administrative
errors, or payments made in the correct amount but without following applicable statutes and
regulations. Improper payments can also include underpayments caused by nonpayment or
incomplete payment to recipients to which the funds are owed. See GAO, Improper Payments and
Fraud: How They Are Related but Different, GAO-24-106608 (Washington, D.C.: Dec. 7, 2023), for
more detailed information on this topic.
431 U.S.C. § 3515 requires executive agency heads to prepare and submit to Congress and the
Director of OMB audited financial statements for the preceding fiscal year.
Page 11 GAO-25-107552
5Council of the Inspectors General on Integrity and Efficiency, Guidance for Payment Integrity
Information Act Compliance Reviews (Oct. 19, 2023).
6OMB’s definition of “accompanying materials” refers to public information in a location separate
from the annual financial statement of the agency. This information includes data on an external
website, such as PaymentAccuracy.gov, which the government updates each November with
agencies’ improper payments information.
7The Council of the Inspectors General on Integrity and Efficiency has designated the website
Oversight.gov for IGs to publish their agencies’ PIIA compliance reports.
831 U.S.C. § 3353(b)(1).
9The term “accompanying materials to the financial statements” is not defined in PIIA. However,
OMB defines the term in Memorandum M-21-19 (see endnote 6 above), and guidance from the
Council of the Inspectors General on Integrity and Efficiency states that “The most common
accompanying materials to the annual financial statement are the payment integrity information
published on PaymentAccuracy.gov.”
10OMB issued Circular A-136, Financial Reporting Requirements, on May 30, 2024. The circular
provides guidance for executive branch entities required to submit audited financial statements,
interim financial statements, and performance and accountability reports or agency financial reports
under the Chief Financial Officers Act of 1990 as amended; the Government Management Reform
Act of 1994; and the Accountability of Tax Dollars Act of 2002. OMB reissues Circular A-136 each
year.
1131 U.S.C. § 3353(b)(2).
12The President’s Budgets for fiscal years 2023, 2024, and 2025 were publicly released in March
2022, March 2023, and March 2024, respectively.
13The annual OMB Circular No. A-11, issued in July 2024 and August 2023 for the preparation of
the budget for fiscal years 2026 and 2025, respectively, provided an overview of the budget
process to agencies, covered development of the President’s Budget, and informed agencies how
to prepare and submit materials required for OMB and presidential review of agency requests and
for annual budget formulation. OMB also issues a budget-planning guidance memorandum known
as “spring guidance” early in the budget development phase, with detailed instructions and
deadlines for submitting budget requests and supporting materials to OMB.
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