GAO-26-108044: Improper Payments: Agency Actions Needed to Help Save Taxpayer Dollars
Summary
GAO-26-108044, Improper Payments: Agency Actions Needed to Help Save Taxpayer Dollars, a June 2026 Government Accountability Office report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives, described as GAO's 11th and final report under House Report 117-389. It states that executive branch agencies reported cumulative improper payment estimates of about $3 trillion since fiscal year 2003, including $186 billion for fiscal year 2025. GAO identified seven agencies with programs reporting estimated improper payment rates of 10 percent or higher for 2, 3, or 4 consecutive fiscal years from 2021 through 2024. GAO makes six recommendations, including one to OMB to clarify its guidance on required annual reports by noncompliant agencies.
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United States Government Accountability Office
Report to the Subcommittee on
Legislative Branch, Committee on
Appropriations, House of
Representatives
IMPROPER
June 2026
PAYMENTS
Agency Actions
Needed to Help Save
Taxpayer Dollars
GAO-26-108044
IMPROPER PAYMENTS
Highlights Agency Actions Needed to Help Save Taxpayer Dollars
GAO-26-108044 June 2026
A report to the Subcommittee on Legislative Branch, Committee on Appropriations, House of Representatives
Contact: Kristen Kociolek at KociolekK@gao.gov
What GAO Found Why GAO Did This Study
Executive branch agencies are required to report improper payment estimates for Executive branch agencies have
each risk-susceptible program. GAO identified seven agencies with programs reported cumulative improper payment
reporting estimated improper payment rates of 10 percent or higher for 2, 3, or 4 estimates of about $3 trillion since fiscal
consecutive fiscal years from 2021 through 2024. year 2003, including $186 billion for
fiscal year 2025. To help save taxpayer
Consecutive Fiscal Years of Noncompliance Reported for Agencies’ Improper dollars, it is imperative that agencies
Payment Rates Since Payment Integrity Information Act of 2019 Implementation prioritize reducing their improper
payments and timely report on their
efforts to do so.
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
GAO’s 11th and final report.
This report examines actions that
agencies have taken to meet certain
To improve transparency, agencies that are noncompliant under the Payment PIIA reporting requirements for
Integrity Information Act of 2019 (PIIA) are required to report annually to programs that had estimated improper
Congress and GAO. The Office of Management and Budget (OMB) provides payment rates of 10 percent or higher
guidance on PIIA requirements to agencies. However, GAO found that the for 2 or more consecutive years. For
guidance does not direct noncompliant agencies to submit the required annual programs with reported noncompliance,
reports. Unless OMB updates its guidance, Congress may not have the GAO reviewed relevant laws and OMB
information it needs to assess agencies’ actions to address improper payments guidance and analyzed agencies’
policies and procedures, budget
and hold them accountable.
information, and information on
Reporting requirements for noncompliant agencies vary, depending on how PaymentAccuracy.gov.
many consecutive fiscal years programs are noncompliant with PIIA. GAO found
that all agencies with noncompliant programs for 2 consecutive years had either What GAO Recommends
submitted additional program integrity proposals to OMB, as required, or taken
GAO is making six recommendations,
other actions to help bring their programs into compliance.
including one to OMB to clarify its
Four of the six agencies with programs found noncompliant for 3 consecutive guidance for agencies to report required
years submitted the required 3-year noncompliance information to Congress, annual information, and one each to the
OMB, and GAO. The Departments of Labor (DOL) and the Treasury did not Departments of Labor, Education,
submit the information timely, and the Treasury did not report to GAO. Health and Human Services (HHS), the
Treasury, and Agriculture (USDA) to
All four agencies with programs found noncompliant for 4 consecutive years design and implement a process to help
submitted reports to Congress and OMB as required by PIIA and OMB guidance. ensure tracking and monitoring of PIIA
reporting requirements for their
Five of the seven agencies did not have sufficient documented policies and programs and to help save taxpayer
procedures to ensure consistent timely reporting for their noncompliant dollars. DOL, Education, HHS,
programs. When agencies do not meet PIIA’s annual and consecutive year Treasury, and USDA agreed with the
reporting requirements, Congress loses visibility into which programs continue to recommendations. OMB did not provide
pose elevated risks and whether agencies are taking meaningful steps to comments.
address them. Having such policies and procedures will help ensure that
Congress receives timely information needed to inform legislative decision- In addition, GAO’s prior work has
making and support efforts for reducing government-wide improper payments highlighted numerous actions that
and saving taxpayer dollars. agencies and Congress can take to
reduce improper payments and fraud.
United States Government Accountability Office
Contents
Letter 1
Background 4
Agency Reporting for Annual and Consecutive Years of
Noncompliance 7
How Agencies’ Reported Compliance Efforts for 4-Year
Noncompliant Programs Aligned with GAO’s Key Practices for
Addressing High-Risk Areas 14
Agency Processes for Reporting PIIA-Noncompliant Programs 18
Conclusions 21
Recommendations for Executive Action 23
Agency Comments 24
Appendix I Payment-Integrity Related Matters for Congressional
Consideration 25
Appendix II GAO Questions for Assessing Agencies’ Compliance Efforts
Related to Key Practices for Addressing High-Risk Areas 27
Appendix III Payment Integrity Information Act of 2019 Criteria and Office of
Management and Budget Guidance 29
Appendix IV Alignment of Certain Agencies’ Actions with GAO’s Key Practices
for Addressing High-Risk Areas 31
Appendix V GAO Open Recommendations on Improper Payments and Fraud
for Certain Agencies 36
Appendix VI Comments from the Corporation for National and Community
Service 38
Page i GAO-26-108044 Improper Payments
Appendix VII Comments from the Department of Labor 39
Appendix VIII Comments from the Department of Education 40
Appendix IX Comments from the Department of Health and Human Services 41
Appendix X Comments from the Department of the Treasury 43
Appendix XI GAO Contact and Staff Acknowledgments 46
Tables
Table 1: Estimated Improper Payment Rates Reported for
Programs with Rates of 10 Percent or Higher for 2, 3, or 4
Consecutive Fiscal Years Since PIIA Implementation,
Fiscal Years 2021–2024 6
Table 2: Agencies’ Submission of 3-Year PIIA Noncompliance
Information for Fiscal Year 2023 12
Table 3: Agencies’ Submission of 4-Year PIIA Noncompliance
Information for Fiscal Year 2024 13
Table 4: How Agencies’ Compliance Efforts for 4 Years of
Noncompliance Aligned with GAO’s Key Practices for
Addressing High-Risk Areas 31
Table 5: GAO Open Recommendations on Improper Payments
and Fraud to the Department of Labor (DOL) and the
Department of the Treasury 36
Figure
Figure 1: Key Practices for Addressing Areas on GAO’s High-Risk
List 15
Page ii GAO-26-108044 Improper Payments
Abbreviations
CFO chief financial officer
CNCS Corporation for National and Community Service
DOL Department of Labor
ECP Emergency Conservation Program
ETA Employment & Training Administration
FSA Farm Service Agency
HHS Department of Health and Human Services
IG inspector general
IRS Internal Revenue Service
OIG Office of the Inspector General
OMB Office of Management and Budget
PIIA Payment Integrity Information Act of 2019
RTC refundable tax credit
UI Unemployment Insurance
USDA Department of Agriculture
VA Department of Veterans Affairs
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Page iii GAO-26-108044 Improper Payments
Letter
441 G St. N.W.
Washington, DC 20548
June 4, 2026
The Honorable David Valadao
Chairman
The Honorable Adriano Espaillat
Ranking Member
Subcommittee on Legislative Branch
Committee on Appropriations
House of Representatives
Executive branch agencies have reported cumulative improper payment
estimates of about $3 trillion since fiscal year 2003, including $186 billion
for fiscal year 2025. 1 Given the magnitude of these estimates, it is
imperative that agencies prioritize reducing improper payments. One way
to help ensure that they do so, and thereby save taxpayer dollars, is by
requiring they timely report to Congress, the Office of Management and
Budget (OMB), and GAO. This is particularly important if their programs
have reported estimated improper payment rates of 10 percent or higher
for 2 or more consecutive years.
The Payment Integrity Information Act of 2019 (PIIA) requires agencies to
manage improper payments. 2 Agencies are required to do so by
conducting risk assessments, taking corrective actions, and estimating
and reporting information on improper payments for programs they
administer. PIIA also requires agencies’ inspectors general (IG) to issue
annual reports on whether the agencies under their jurisdiction have
complied with applicable PIIA criteria, such as conducting improper
1The law defines an improper payment as one 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). When an executive agency’s review is unable
to discern whether a payment was proper because of insufficient or lack of documentation,
this payment must also be included in the improper payment estimate. 31 U.S.C. §
3352(c)(2)(A). Additionally, improper payments and fraud are distinct concepts that are not
interchangeable but are related. Fraud involves obtaining something of value through
willful misrepresentation (i.e., by making materially false statements of fact based on
actual knowledge, deliberate ignorance, or reckless disregard of falsity). While all
fraudulent payments are considered improper, not all improper payments are due to fraud.
Some, for example, are due to errors.
2Pub. L. No. 116-117, 134 Stat. 113 (2020) (codified at 31 U.S.C. §§ 3351-58).
Page 1 GAO-26-108044 Improper Payments
payment risk assessments and publishing improper payment estimates
and corrective action plans for risk-susceptible programs. 3 If an agency’s
program fails to meet any of these criteria, the IG reports the agency and
its program as noncompliant under PIIA. Any such agency is then
required to report certain information to Congress, OMB, and GAO. This
reporting by agencies is a mechanism for identifying programs with
ongoing noncompliance, which may indicate underlying payment integrity
control weaknesses. Congress can use this information to inform
legislative decision-making and support efforts for reducing government-
wide improper payments and saving taxpayer dollars.
Our High-Risk List identifies government operations with serious
vulnerabilities to fraud, waste, abuse, and mismanagement or that are in
need of transformation. 4 The areas on the High-Risk List include
programs reporting improper payment estimates, such as Medicare,
Medicaid, the unemployment insurance system, and the Earned Income
Tax Credit. While agencies are taking some steps to address improper
payments, much more needs to be done to control billions of dollars in
overpayments and prevent fraud. We have previously recommended
matters for congressional consideration related to payment integrity
across the government. See appendix I for a list of open payment
integrity-related matters for congressional consideration.
House Report 117-389, which accompanied the Legislative Branch
Appropriations Act, 2023, includes a provision for us to provide quarterly
reports on improper payments. This is our 11th and final quarterly report.
This report examines the extent to which (1) agencies met PIIA annual
reporting requirements for noncompliant programs with estimated
improper payment rates of 10 percent or higher for 2, 3, or 4 consecutive
years; (2) agencies’ compliance efforts for programs with 4 consecutive
years of noncompliance aligned with our key practices for addressing
high-risk areas; and (3) these agencies had processes to track and
monitor the reporting of PIIA noncompliance. Additionally, we have
ongoing work assessing agencies’ steps to address improper payments,
including identifying root causes and developing targeted corrective
action plans.
3See app. III for the complete list of criteria.
4GAO, High-Risk Series: Heightened Attention Could Save Billions More and Improve
Government Efficiency and Effectiveness, GAO-25-107743 (Washington, D.C.: Feb. 25,
2025).
Page 2 GAO-26-108044 Improper Payments
To address these objectives, we reviewed relevant federal statutes,
guidance, and standards related to reporting on improper payments,
including PIIA and OMB guidance. 5 We obtained and analyzed improper
payment data for fiscal years 2021 through 2024 on
PaymentAccuracy.gov to identify agencies and programs that reported
estimated improper payment rates of 10 percent or higher for consecutive
fiscal years. 6 For such agencies, we reviewed IG compliance reports and
agency financial reports from fiscal years 2021 through 2024. We also
reviewed relevant GAO reports.
To address the first objective, we identified seven agencies—the
Corporation for National and Community Service (CNCS) 7 and the
Departments of Labor (DOL), Education, Health and Human Services
(HHS), the Treasury, Agriculture (USDA), and Veterans Affairs (VA)—with
programs reporting estimated improper payment rates of 10 percent or
higher for 2, 3, or 4 consecutive fiscal years (2021, 2022, 2023, and
2024). We reviewed information these agencies reported on
PaymentAccuracy.gov to assess whether annual PIIA reporting
requirements were met. We also analyzed agencies’ budget
information—posted on agency websites and reported in the fiscal year
2026 President’s Budget—to determine whether the agencies submitted
additional program integrity budget proposals to help them come into
compliance. 8 Further, we analyzed documentation from the seven
agencies against applicable PIIA criteria and OMB implementing
guidance to assess whether they submitted required information to
appropriate congressional committees, OMB, and GAO.
5Office of Management and Budget, Requirements for Payment Integrity Improvement,
OMB Circular No. A-123, Appendix C (Mar. 5, 2021), issued as OMB Memorandum No.
M-21-19 (OMB M-21-19).
6PaymentAccuracy.gov is a website that the Department of the Treasury established, in
coordination with the Department of Justice and OMB, to serve as a centralized location
for information about improper payments.
7In September 2020, CNCS changed its operating name to AmeriCorps. The agency’s
legal name remains the Corporation for National and Community Service. Agency
Operating Name, Adoption of New Logos, & Retirement of Logos, 85 Fed. Reg. 65239
(Oct. 15, 2020).
8We previously reported that OMB would provide guidance on the process for submitting
program integrity proposals for 2 consecutive years of noncompliance with PIIA criteria for
the first time during development of the fiscal year 2026 President’s Budget. See GAO,
Improper Payments: Agency Reporting of Payment Integrity Information, GAO-25-107552
(Washington, D.C.: Jan. 23, 2025). The President’s Budget for fiscal year 2026 was
publicly released in May 2025.
Page 3 GAO-26-108044 Improper Payments
To address the second objective, for the four agencies that had
noncompliant programs or activities for 4 consecutive years—DOL,
Treasury, USDA, and VA—we reviewed reported compliance efforts on
PaymentAccuracy.gov to determine how these efforts aligned with our
key practices for addressing high-risk areas. 9 See appendix II for a list of
the questions we used to assess agencies’ reported compliance efforts.
To address the third objective, we obtained and reviewed documentation
from the seven agencies to assess whether they had sufficient processes
in place to track and monitor actions to meet the PIIA reporting
requirements and to ensure that required reports are submitted to
Congress, OMB, and GAO.
We conducted this performance audit from January 2025 to May 2026 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Congress passed PIIA to improve efforts to identify and reduce
Background government-wide improper payments. PIIA includes six criteria for
compliance, which OMB guidance expands to 10 by breaking some
criteria into subcomponents and, in some cases, adding new elements.
PIIA and implementing OMB guidance require IGs to annually report on
whether agencies and their programs met those criteria. For example, IGs
report whether agencies published improper payment information with
their annual agency financial reports and accompanying materials on their
websites. See appendix III for the list of PIIA criteria and OMB guidance.
To assess whether agencies and programs are compliant, IGs, in part,
review information that agencies reported on PaymentAccuracy.gov and
analyze source data to ensure accuracy and completeness of payment
integrity information in the financial statements and accompanying
9When determining which federal programs and functions should be designated as high-
risk areas, we consider the potential for improper payments or fraud, among other factors.
For programs identified as high-risk areas, our criteria for removal from the High-Risk List
can help inform agency efforts to reduce improper payments.
Page 4 GAO-26-108044 Improper Payments
materials. 10 If an IG concludes that any of the agency’s programs or
activities are noncompliant with PIIA in a given fiscal year, the agency is
required to take additional actions for each consecutive year of
noncompliance.
Since the implementation of PIIA in fiscal year 2021, IGs have reported
that several federal programs consistently failed to comply with PIIA
criteria because estimated improper payment rates exceeded certain
statutory thresholds. PIIA instructs IGs to report agencies as
noncompliant if any of the agency’s improper payment estimates equal or
exceed 10 percent of that program’s outlays.
Agencies with programs that remain noncompliant with PIIA for multiple
consecutive years are often the same programs that account for some of
the largest improper payment estimates government-wide. PIIA
establishes different reporting requirements for agencies depending on
how many consecutive years their programs are found noncompliant. In
reports for fiscal years 2021 through 2024, IGs found 13 programs from
seven agencies noncompliant for 2 consecutive fiscal years (2021 and
2022) because the agencies reported estimated improper payment rates
of 10 percent or higher. Eight programs from six agencies have done so
for 3 consecutive fiscal years (2021, 2022, and 2023). Six programs from
four agencies have done so for 4 consecutive fiscal years (from 2021
through 2024). Table 1 lists these programs and their reported estimated
improper payment rates. 11
10IGs 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. See Council of the Inspectors General on Integrity and Efficiency,
Guidance for Payment Integrity Information Act OIG Compliance Reviews (Nov. 2025).
OMB Memorandum M-21-19 also provides guidance to IGs for reporting on agency
compliance.
11OMB guidance states that to the extent possible, data used for estimating improper
payments should coincide with the fiscal year being reported. However, agencies may use
a different 12-month reporting period with approval from OMB. The agencies we reviewed
used sampling and testing data that varied in age. For example, to estimate improper
payments for fiscal year 2024, the Department of Labor reported on
PaymentAccuracy.gov that it used the sampling and testing data from July 2023 to June
2024 for the Federal State Unemployment Insurance program. However, the Department
of Agriculture reported that it used the sampling and testing data from October 2022 to
September 2023 for the Emergency Conservation Program-Disasters.
Page 5 GAO-26-108044 Improper Payments
Table 1: Estimated Improper Payment Rates Reported for Programs with Rates of 10 Percent or Higher for 2, 3, or 4
Consecutive Fiscal Years Since PIIA Implementation, Fiscal Years 2021–2024
Fiscal year estimated
improper payment rate Consecutive fiscal years of
(percent) PIIA noncompliance
Two Three Four
years years years
(2021- (2021- (2021-
Agency Program 2021 2022 2023 2024 2022) 2023) 2024)
Corporation for The Foster Grandparent Program 19.3 23.7 9.9 17.6 X n/a n/a
National and The Retired and Senior Volunteer Program 13.7 17.2 NR NR X n/a n/a
Community
Service The Senior Companion Program 20.4 26.2 15.6 NR X X n/a
Department of Commodity Credit Corporation Trade Mitigation 11.4 19.3 NR NR X n/a n/a
Agriculture Program
Farm Service Agency Emergency Conservation 13.5 29.2 40.4 45.2 X X X
Program - Disasters
Department of Title I Grants to Local Educational Agencies 14.8 35.7 0a NR X n/a n/a
Education
Department of Centers for Medicare & Medicaid Services - 31.8 26.7 12.8 6.1 X X n/a
Health and Children’s Health Insurance Program
Human Services Centers for Medicare & Medicaid Services - 21.7 15.6 8.6 5.1 X n/a n/a
Medicaid
Department of Employment & Training Administration - Federal 18.9 22.2 16.5 15.9 X X X
Labor State Unemployment Insurance
Department of the Internal Revenue Service - Additional Child Tax 13.3 15.8 14.5 10.7 X X X
Treasury Credit
Internal Revenue Service - American Opportunity 26.3 36.1 31.6 27.7 X X X
Tax Credit
Internal Revenue Service - Earned Income Tax 27.8 31.6 33.5 27.3 X X X
Credit
Department of Purchased Long-Term Services and Supports 72.8 47.5 38.7 13.5 X X X
Veterans Affairs
n/a = not applicable.
NR = Not reported. A designation of NR may be due to a program’s lack of a reporting requirement for that fiscal year, not failure to report.
PIIA = Payment Integrity Information Act of 2019.
X = PIIA noncompliant.
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-26-108044
Note: Estimated improper payment rates include both improper and unknown payments as reported
on PaymentAccuracy.gov. Executive agency estimates of improper payments also treat as improper
any payments that cannot be determined to be proper due to lacking or insufficient documentation.
Agencies report payment integrity information in their annual agency financial reports and on
PaymentAccuracy.gov. These sources contain additional agency-reported information, including
estimated improper and unknown payment amounts and rates, root causes, and corrective actions.
a
In fiscal year 2023, the Department of Education reported that it implemented effective mitigation
strategies that resulted in the reduction of the improper payment rate to 0 percent. However, in its
audit of Education’s fiscal year 2023 compliance with the payment integrity information reporting
Page 6 GAO-26-108044 Improper Payments
requirements, Education’s Office of Inspector General found that the Title I improper payment
estimate was not reliable due to issues with the sampling and estimation methodology.
Agency Reporting for
Annual and
Consecutive Years of
Noncompliance
What does PIIA require For each year they are found noncompliant, PIIA requires agencies to,
noncompliant agencies to among other things, submit an annual report to the appropriate
authorizing and appropriations congressional committees and GAO. 12
report to Congress and
This report must include (1) a list of each program or activity that was
GAO? determined to be noncompliant for 1, 2, 3, 4, or more consecutive years
and (2) actions that the agency plans to take to bring the program or
activity into compliance. 13
Which agencies did not We found that six of the seven agencies we reviewed—CNCS, DOL,
meet the annual reporting HHS, Treasury, USDA, and VA—did not report all PIIA-required annual
information about their noncompliant programs in fiscal year 2024.
requirement?
Specifically, while these agencies reported planned corrective actions to
bring programs into compliance on PaymentAccuracy.gov, they did not
report a list of all programs that have been noncompliant for consecutive
years. Instead, these agencies reported the number of consecutive years
that the agencies, not their programs, were noncompliant. Education
reported that it reduced the Title I grant program’s estimated improper
payment rate to 0 percent in fiscal year 2023 and that it had no programs
12For each fiscal year of noncompliance, PIIA also requires agencies to submit a plan to
the appropriate authorizing and appropriations committees of Congress describing the
actions the agency will take to come into compliance. These plans must include (1)
measurable milestones to be accomplished to achieve compliance for each program; (2)
the designation of a senior official accountable for the agency’s progress in coming into
compliance for each program; and (3) 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.
31 U.S.C. § 3353(b)(1).
1331 U.S.C. § 3353(b)(5).
Page 7 GAO-26-108044 Improper Payments
determined to be noncompliant in fiscal year 2024. 14 Accordingly,
Education did not report annual noncompliance information in fiscal year
2024.
Officials from all seven of the agencies stated that they follow OMB
guidance regarding the reporting requirements by posting certain
information on PaymentAccuracy.gov. We found that while the OMB
guidance directs agencies to provide information in the OMB annual data
call describing actions that the agency will take to come into compliance,
it does not direct agencies to submit the separate annual report to
Congress and GAO containing (1) a list of each noncompliant program or
activity that was determined to be noncompliant for 1, 2, 3, 4, or more
consecutive years and (2) actions planned to bring the program or activity
into compliance, 15 as required by PIIA. 16
Without updated OMB guidance clarifying agency annual reporting
requirements, agencies will be less likely to timely provide the key
payment integrity information needed for Congress to assess agencies’
actions for addressing improper payments and hold them accountable. In
addition, reporting a list of noncompliant programs for consecutive years
would provide Congress with valuable information for targeted oversight
and assessment of whether corrective actions are appropriate and will
help save taxpayer dollars.
What does PIIA require an When an agency has been noncompliant with PIIA criteria for 2
agency to do for 2 consecutive fiscal years for the same program or activity, PIIA requires it
to submit additional program integrity proposals to OMB that would help
consecutive years of the agency come into compliance. 17 OMB guidance directs agencies to
noncompliance? include these proposals in their next budget submissions supporting the
development of the annual President’s Budget.
14In fiscal year 2023, Education reported that it implemented effective mitigation strategies
that resulted in the reduction of the improper payment rate to 0 percent. However, in its
audit of Education’s fiscal year 2023 compliance with the payment integrity information
reporting requirements, Education’s Office of Inspector General found that the Title I
improper payment estimate was not reliable due to issues with the sampling and
estimation methodology.
15OMB M-21-19.
1631 U.S.C. § 3353(b)(5).
1731 U.S.C. § 3353(b)(2).
Page 8 GAO-26-108044 Improper Payments
If OMB determines that additional funding would help an agency come
into compliance, the agency must obligate additional funds in an amount
that OMB determines. To do so, the agency must exercise available
reprogramming or transfer authority. 18 If further funding is needed to
reach the full amount OMB determined, the agency is required to request
additional reprogramming or transfer authority from Congress.
Which agencies submitted Two of the seven agencies that were noncompliant for 2 consecutive
additional program years (2021 and 2022)—DOL and HHS—submitted additional program
integrity proposals to OMB for the fiscal year 2026 President’s Budget. 19
integrity proposals?
DOL. The agency proposed a funding increase of $79 million to carry out
its reemployment services and eligibility assessments program. According
to an agency official, the purpose of the proposal included strengthening
program integrity by reducing improper payments through detection and
prevention. The proposal also included a separate increase of $25 million
for unemployment insurance identity verification program integrity
activities. The agency stated that these identity proofing services can
significantly reduce overpayments due to identity fraud.
HHS. In its proposal, HHS requested an increase in mandatory Health
Care Fraud and Abuse Control program funding to help address health
care payment integrity, including activities related to identifying and
reducing improper payments and preventing and detecting fraud. 20 HHS
officials told us that the agency plans to intensify its compliance efforts.
These efforts include working with states to implement corrective action
plans, providing technical assistance to states, monitoring progress of its
compliance efforts, and conducting audits of beneficiary eligibility
18Reprogramming means shifting funds within an appropriation or fund account to use for
purposes other than those contemplated at the time of appropriation. Agencies may
generally reprogram funds without additional statutory authority within the scope of their
duty to manage funds. On the other hand, a transfer involves shifting all or part of the
budget authority in one appropriation or fund account to another. Unlike reprogramming,
agencies may only transfer funds if specifically authorized by law.
19As mentioned in footnote 8, we previously reported that OMB would provide guidance
on the process for submitting program integrity proposals for 2 consecutive years of
noncompliance with PIIA criteria during the development of the fiscal year 2026
President’s Budget.
20In addition, HHS officials told us that these additional program integrity proposals reflect
the priorities of the previous administration, which may differ from those of the current
administration.
Page 9 GAO-26-108044 Improper Payments
determinations in states identified as having higher estimated improper
payment rates.
What other actions did The five agencies that did not submit additional program integrity
agencies take to help proposals—CNCS, Education, Treasury, USDA, and VA—took other
actions to help bring their programs into compliance.
bring their programs into
compliance? CNCS. CNCS officials explained that the organizations receiving CNCS
grants, rather than the agency itself, generally make payments.
Therefore, CNCS officials told us that the agency plans to implement
corrective actions in fiscal year 2025 targeted at such organizations. For
example, CNCS will require written confirmation from grantees found to
have made improper payments for which CNCS staff members
responsible for the areas where improper payments occurred have
reviewed all information and completed all related training.
Education. According to Education officials, the improper payment rates
for Title I grants to local educational agencies in fiscal years 2021 and
2022 were due almost entirely to “unknown” payments. 21 Subsequently, in
fiscal year 2023, Education reported that it implemented effective
mitigation strategies that eliminated improper payments. 22
Treasury. Officials from Treasury’s Internal Revenue Service (IRS) told
us that IRS continues to focus on its compliance efforts. Such efforts
relate to refundable tax credits and include improving outreach and
education for taxpayers and paid tax preparers, collaborating with federal
and state stakeholders, and conducting educational events to support tax
preparer compliance. However, they stated that any budget reductions
and limited staffing resources may affect the agency’s ability to continue
these outreach and compliance efforts.
21According to OMB guidance, in federal agency improper payment estimation, an
unknown payment is a payment that could be either proper or improper, but the agency is
unable to discern whether the payment was proper or improper as a result of insufficient
or lack of documentation. By law, improper payment estimates must treat unknown
payments as improper under PIIA. 31 U.S.C. § 3353(c)(2).
22As mentioned in footnote 14, Education reported that it implemented effective mitigation
strategies in fiscal year 2023 that resulted in the reduction of the improper payment rate to
0 percent. However, in its audit of Education’s fiscal year 2023 compliance with the
payment integrity information reporting requirements, Education’s Office of Inspector
General found that the Title I improper payment estimate was not reliable due to issues
with the sampling and estimation methodology.
Page 10 GAO-26-108044 Improper Payments
USDA. According to USDA officials, the agency did not submit timely
additional program integrity proposals for its Emergency Conservation
Program - Disasters program. However, these officials told us that the
agency subsequently submitted a separate request through a
memorandum to OMB for approval to proceed with proposed actions to
reduce improper payments, including additional funding for software
enhancements that will enable USDA to automatically generate a list of
applications for compliance spot checks.
VA. VA officials stated that the agency’s corrective actions included
implementation of a standardized rate schedule for community nursing
home payments and transitioning more payments from a legacy system
requiring manual validation to an automated claims adjudication system
to help reduce improper payments in the Purchased Long-Term Services
and Supports program. 23
What does PIIA require an When an agency’s IG determines the same program or activity has been
agency to do for 3 noncompliant for 3 consecutive fiscal years, PIIA requires the agency to
submit certain documentation to appropriate authorizing and
consecutive years of
appropriations committees and GAO. OMB guidance expands this
noncompliance? requirement to include submission to OMB. All of these submissions must
occur within 30 days of the noncompliance determination. Specifically, the
agency generally must submit (1) reauthorization proposals for each
relevant program or activity and (2) proposed statutory changes to bring
the program or activity into compliance. 24
However, if the agency determines that these actions will not bring the
program or activity into compliance, the agency must alternatively submit
to the committees, OMB, and GAO a description of the actions the
agency is taking to bring its program or activity into compliance and a
timeline for when it expects to achieve compliance.
Which agencies met the 3- Of the six agencies that were noncompliant with PIIA for 3 consecutive
year noncompliance years (2021, 2022, and 2023), four met the reporting requirement.
reporting requirements?
23VA’s IG reported that the majority of improper and unknown payments in fiscal year
2023 for its Purchased Long-Term Services and Supports program were technically
improper, due to a failure to comply with applicable statutes or regulations. Department of
Veterans Affairs, Office of Inspector General, Review of VA’s Compliance with the
Payment Integrity Information Act for Fiscal Year 2023, 24-00510-167 (May 23, 2024).
2431 U.S.C. § 3353(b)(3).
Page 11 GAO-26-108044 Improper Payments
Four agencies––CNCS, HHS, USDA, and VA––met the 3-year reporting
requirement by submitting required information to the appropriate
congressional committees, OMB, and GAO within 30 days of their IGs’
third consecutive noncompliance determination in fiscal year 2023.
Two agencies––DOL and Treasury––submitted required information but
did not do so within 30 days, as required. DOL submitted its 3-year
noncompliance information late to appropriate congressional committees,
OMB, and GAO. Treasury submitted its information late to appropriate
congressional committees and OMB and did not submit a report to GAO.
Table 2 summarizes these six agencies’ submissions of their 3-year
noncompliance information.
Table 2: Agencies’ Submission of 3-Year PIIA Noncompliance Information for Fiscal Year 2023
Did agency submit required information to
Congress, OMB, and GAO?
Agency Congress OMB GAO
Corporation for National and Community Service ✓ ✓ ✓
Department of Agriculture ✓ ✓ ✓
Department of Health and Human Services ✓ ✓ ✓
Department of Labor ✗ ✗ ✗
Department of the Treasury ✗ ✗ O
Department of Veterans Affairs ✓ ✓ ✓
✓ = Submitted on time; ✗ = Submitted late; O = Did not submit.
PIIA = Payment Integrity Information Act of 2019.
Source: GAO analysis of agencies’ submission of 3-year PIIA noncompliance information to Congress, the Office of Management and Budget, and GAO. | GAO-26-108044
What does PIIA require an When an agency has been noncompliant for 4 or more consecutive fiscal
agency to do for 4 years for the same program or activity, PIIA and OMB guidance direct the
agency to submit certain documentation to appropriate authorizing and
consecutive years of
appropriations committees and OMB within 30 days of its IG’s
noncompliance? noncompliance determination. 25 Specifically, the agency must submit a
report that includes
• the activities the agency has taken to comply with the requirements
for 1, 2, 3, 4, or more consecutive years of noncompliance;
2531 U.S.C. § 3353(b)(4); OMB M-21-19.
Page 12 GAO-26-108044 Improper Payments
• a description of any requirements that were fulfilled for 1, 2, 3, 4, or
more consecutive years of noncompliance that are still relevant and
that the agency is pursuing to bring the program or activity into
compliance and prevent and reduce improper payments;
• a description of any new corrective actions; and
• a timeline for when the program or activity will achieve compliance
based on the actions described within the report.
Which agencies met the 4- All four agencies noncompliant with PIIA criteria for the same program or
year noncompliance activity for 4 consecutive years (2021 through 2024)––DOL, Treasury,
USDA, and VA––met the requirement by submitting required information
reporting requirements?
in a report to the appropriate congressional committees and OMB. Table
3 summarizes these four agencies’ submissions of their 4-year
noncompliance information.
Table 3: Agencies’ Submission of 4-Year PIIA Noncompliance Information for Fiscal Year 2024
Did agency submit required information to
Congress and OMB?
Agency Congress OMB
Department of Agriculture ✓ ✓
Department of Labor ✓ ✓
Department of the Treasury ✓ ✓
Department of Veterans Affairs ✓ ✓
✓ = Submitted.
PIIA = Payment Integrity Information Act of 2019.
Source: GAO analysis of agencies’ submission of 4-year PIIA noncompliance information to Congress and the Office of Management and Budget. | GAO-26-108044
Page 13 GAO-26-108044 Improper Payments
How Agencies’
Reported Compliance
Efforts for 4-Year
Noncompliant
Programs Aligned
with GAO’s Key
Practices for
Addressing High-Risk
Areas
What must agencies When determining which federal programs and functions should be
demonstrate for an area to designated as high-risk areas, we consider the potential for improper
payments or fraud, among other factors. For programs identified as high-
be removed from GAO’s
risk areas, our criteria for removal from the High-Risk List can help inform
High-Risk List? agency efforts to reduce improper payments and save taxpayer dollars.
There are five key practices we use to assess agency progress in
addressing high-risk areas: (1) leadership commitment, (2) agency
capacity, (3) an action plan, (4) monitoring efforts, and (5) demonstrated
progress (see fig. 1). 26
26GAO, High-Risk Series: Key Practices to Successfully Address High-Risk Areas and
Remove Them from the List, GAO-22-105184 (Washington, D.C.: Mar. 3, 2022).
Page 14 GAO-26-108044 Improper Payments
Figure 1: Key Practices for Addressing Areas on GAO’s High-Risk List
How did agency-reported Based on our review of the fiscal year 2024 information on
compliance efforts align PaymentAccuracy.gov, the four agencies that have been noncompliant
with PIIA for 4 consecutive fiscal years (2021 through 2024)—DOL,
with key practices for
Treasury, USDA, and VA—reported employing a variety of efforts to
addressing high-risk
areas?
Page 15 GAO-26-108044 Improper Payments
mitigate improper payments. 27 Some of these compliance efforts aligned
with key practices for addressing high-risk areas. For example:
Leadership commitment. All four agencies designated accountable
officials responsible for the progress of the agency coming into
compliance with applicable PIIA criteria. Three agencies—Treasury,
USDA, and VA—outlined accountability mechanisms, such as a process
for holding the designated official responsible for leading compliance
efforts under PIIA. DOL did not specify an accountability mechanism but
did outline performance requirements focused on the program. While
varied, all four agencies documented some level of internal coordination
between intra-agency partners and stakeholders to increase access to
information used to mitigate improper payments, such as involving chief
financial officers and holding regular meetings to discuss improper
payment topics.
Capacity. All four agencies reported on their funding or actions needed to
improve or maintain payment integrity. For example, DOL reported that it
requested funding increases to support technology modernization that will
improve states’ abilities to detect and prevent fraud and other improper
payments in the Federal State Unemployment Insurance program. VA
reported that it had what it needed to improve or maintain payment
integrity, including adequate funding to implement improvements planned
to internal controls, human capital, information systems, and other
infrastructure.
Treasury reported that it needed statutory changes and restructuring of
refundable tax credits to reduce the improper payment rate to less than
10 percent. 28 USDA reported that it needed additional funding for
software enhancements to improve the agency’s ability to monitor
program implementation to improve and maintain payment integrity. All
four agencies reported that they had some of the capacity needed in the
27We focused our review on these four agencies that reported noncompliance in the most
recent reporting year, which at the time of our review was 2024.
28According to Treasury’s fiscal year 2024 PIIA 4-year compliance report submitted to
Congress, OMB, and GAO, Treasury stated that absent additional legislative action, its
ability to achieve compliance is limited. IRS’s fiscal year 2025 budget submission included
two legislative proposals specific to paid preparers: (1) increasing penalties against and
addressing noncompliance or inappropriate behavior by paid preparers and (2)
establishing mandatory minimum competency standards for paid preparers.
Page 16 GAO-26-108044 Improper Payments
form of technology, training, or both to help resolve the risk of improper
payments over time.
Action plan. All four agencies identified root causes of improper
payments, described corrective action plans, and included planned
completion dates for their corrective actions in response to findings and
recommendations made by their respective IGs in the fiscal year 2024
PIIA compliance reports. As summarized in appendix IV, IGs of the four
agencies have made various recommendations for agency actions to
address their findings. In addition, two of the four agencies—DOL and
Treasury––have open GAO recommendations related to their programs
that reported estimated improper payment rates of more than 10 percent
for 4 consecutive years (see app. V). It is critical that these agencies take
actions to implement IG and GAO recommendations to help reduce
improper payments.
Monitoring. All four agencies reported steps they take to monitor and
validate the effectiveness and sustainability of actions to correct PIIA
noncompliance. For example, one agency reported that it requires states
to conduct quality assurance audits to determine if payments were
accurate or improper.
Demonstrated progress. Three agencies—DOL, USDA, and VA—
described how they measured the effectiveness of corrective actions.
However, Treasury did not provide this information on
PaymentAccuracy.gov. Instead, Treasury emphasized that without
significant restructuring of the refundable tax credits programs, including
the legislative actions discussed above, the improper payment rate of
those programs will not be reduced below 10 percent.
In addition, DOL, Treasury, and VA reported reductions in their improper
payment estimates for their respective noncompliant programs from fiscal
years 2023 to 2024, although their rates remained above 10 percent.
However, USDA continued to report increasing improper payment
estimates for its Emergency Conservation Program from fiscal years 2023
to 2024. According to its IG, USDA and its state agencies did not have
adequate policies and procedures to reduce improper payments.
Specifically, USDA reported that while it continues to support state-level
efforts to enhance payment integrity and prevent improper payments
through training and technical assistance, states either did not properly
follow statutory requirements for payment eligibility, failed to access data
Page 17 GAO-26-108044 Improper Payments
and information needed to validate payment accuracy, or did not properly
review documentation prior to issuing payments.
See appendix IV for detailed information on agencies’ reported
compliance efforts related to key practices for addressing high-risk areas.
Agency Processes for
Reporting PIIA-
Noncompliant
Programs
Which agencies have Of the seven agencies we reviewed that had noncompliant programs with
processes to track and estimated improper payment rates of 10 percent or higher for 2 or more
consecutive years, only VA and CNCS had established and documented
monitor their reporting for
sufficient processes in their policies and procedures to track and monitor
PIIA noncompliance? their reporting for PIIA noncompliance.
VA. VA has established and documented processes in its policies and
procedures to track and monitor reporting for PIIA noncompliance. VA’s
policies and procedures describe its processes for tracking and
completing required reporting activities for noncompliant programs. In
addition, VA issues an annual internal memorandum to help ensure that it
accomplishes reporting activities and milestones.
CNCS. In response to our inquiries, CNCS revised its payment integrity
guidance in September 2025 to outline steps for addressing improper
payments, including processes related to reporting for noncompliant
programs. 29 Prior to these revisions, CNCS’s guidance did not include
specific procedures, such as milestones for tracking and monitoring
noncompliant programs and coordinating with stakeholders, to help
ensure that the agency meets the PIIA reporting requirements.
29Corporation for National and Community Service, Office of the Chief Risk Officer,
Standard Operating Procedure Payment Integrity Information Act of 2019 (Washington,
D.C.: Sept. 23, 2025).
Page 18 GAO-26-108044 Improper Payments
Which agencies did not We found that the five remaining agencies did not have sufficient
have processes to track processes, documented in policies and procedures, to track and monitor
their reporting for PIIA noncompliance.
and monitor their reporting
for PIIA noncompliance? DOL. DOL’s process did not ensure timely submission of the required
reporting for PIIA noncompliance. Its process for tracking and monitoring
the reporting for PIIA noncompliance is not documented in policies and
procedures. The current process consists of notifications that its Office of
the Chief Financial Officer emails to responsible staff after the IG
determines a program to be noncompliant. These emails remind the units
that oversee the program of upcoming reporting requirements and due
dates. We found that the agency’s Office of the Chief Financial Officer
promptly sent its notification after the IG determined the unemployment
insurance program to be noncompliant for 3 consecutive fiscal years.
However, there were timing issues within DOL that resulted in it not
submitting the required reporting information on time. Without establishing
a process, documented in policies and procedures, to track and monitor
the submission of required PIIA noncompliance reporting, there is an
increased risk that DOL will not submit the required information timely.
Education. Education’s department-wide guidance on managing
improper payments and related risks does not include processes to
monitor and track the submission of required reporting for PIIA
noncompliance. 30 Specifically, although Education officials told us that the
agency has some processes to ensure that it meets required reporting
submission timelines, such as internal reporting calendars and recurring
meetings with the IG, these processes are not documented in policies
and procedures.
Without a department-wide process, documented in policies and
procedures, to track and monitor the submission of required PIIA
noncompliance reporting, there is an increased risk that Education offices
will not submit the required information timely.
HHS. Although not documented in formal policies and procedures, HHS
officials told us that HHS has some processes and tools for tracking,
monitoring, and submitting the required PIIA noncompliance reports. For
example, it uses a spreadsheet to track its IG’s recommendations,
delegates noncompliance reporting for each program to the respective
30Department of Education, Payment Integrity Departmental Directive, ACSD-OFO-051
(Sept. 2023).
Page 19 GAO-26-108044 Improper Payments
operating division, and designates HHS’s Division of Payment Integrity
and Improvement to oversee the department-wide noncompliance
reporting process.
HHS officials told us they believe that HHS’s multiple layers of processes
help ensure that it effectively tracks and monitors noncompliant programs.
However, without these processes being documented in policies and
procedures, there is an increased risk that they will not be consistently
performed and that HHS will not submit the required information timely.
Treasury. Treasury’s process did not ensure timely submission of the
required reporting for PIIA noncompliance. Treasury’s department-wide
guidance provides general instructions for submitting the required PIIA
noncompliance reporting. 31 However, this guidance does not include
specific processes to track and monitor such reporting to help ensure
timely submission.
Treasury is responsible for administering the improper payment
compliance program for all its components, including IRS. IRS developed
its own guidance, in addition to the department-wide guidance, which
provides general instructions for responsible staff as well as a schedule
for delivery of required information to Treasury. 32 As discussed above,
although IRS officials prepared and sent the required information to
Treasury recipients for approval and submission after the 3 consecutive
fiscal years of noncompliance, Treasury did not submit the information to
Congress, OMB, and GAO, as required.
According to Treasury officials, this was due to a departure of responsible
staff at Treasury. Further, we found that Treasury’s guidance lacks
sufficiently documented roles and responsibilities to help account for such
a situation and ensure that it submits the required information on time.
Treasury was unaware that it had not submitted the required information
until we requested a copy of the submitted information. Subsequently,
Treasury submitted the information to Congress and OMB in March 2025,
31Department of the Treasury, Office of the Treasury Deputy Chief Financial Officer, Fiscal
Year 2024 Annual Treasury Guidance for Payment Integrity Reporting in Accordance with
OMB Circular A 123 Appendix C: Requirements for Payment Integrity Improvement (May
2024).
32Department of the Treasury, Internal Revenue Service, Improper Payments Compliance
and Reporting Standard Operating Procedure (Mar. 2025).
Page 20 GAO-26-108044 Improper Payments
about 9 months after the statutory due date. As indicated in table 2
above, Treasury did not submit the report to GAO.
Without a department-wide process, documented in policies and
procedures, to track and monitor the submission of required PIIA
noncompliance reporting, there is an increased risk that Treasury offices
will not submit the required information timely.
USDA. According to USDA officials, USDA’s component agencies have
some processes in place for monitoring noncompliant programs.
However, these processes are not documented in departmental policies
and procedures. USDA officials told us that they recognize that uniform,
departmental guidance is necessary to ensure that staff consistently track
all programs and identify PIIA noncompliance requirements for reporting.
USDA officials said that the department has plans to develop such
guidance; however, it has not developed any specific milestones or
project plans to do so. Until USDA has a department-wide process,
documented in policies and procedures, to track and monitor the
submission of required PIIA noncompliance reporting, there is an
increased risk that USDA will not submit the required information timely.
As applicable to all federal executive agencies, the federal internal control
standards state that management should design control activities to
mitigate risks to achieving the entity’s objectives and implement those
control activities through policies and procedures. As part of these
standards, management monitors the status of remediation efforts to
ensure that they are completed timely. 33
Without sufficiently detailed documented policies and procedures, these
five agencies—DOL, Education, HHS, Treasury, and USDA—have less
assurance that they will consistently and timely meet the PIIA reporting
requirements, particularly in the event of staff turnover or changes in
roles. Further, if agencies do not report timely, Congress and OMB may
not have the key payment integrity information needed for their oversight
of government-wide improper payment reduction efforts, which can lead
to saving taxpayer dollars.
Improper payments are a long-standing, significant problem in the federal
Conclusions government. As we have reported, although agencies report improper
33GAO, Standards for Internal Control in the Federal Government, GAO-25-107721
(Washington, D.C.: May 15, 2025).
Page 21 GAO-26-108044 Improper Payments
payment estimates annually, the federal government is unable to
determine the full extent to which improper payments occur or reasonably
ensure that actions are taken to reduce them. We have previously noted
that some IGs have also reported issues related to agencies’ improper
payments. As such, it is critical that agencies take actions to implement
IG and GAO recommendations to help reduce improper payments and
save taxpayer dollars.
OMB provides government-wide guidance for agencies to meet the PIIA
requirements. Unless OMB, through its guidance, explicitly directs
agencies to report required annual information about program
noncompliance, Congress may continue to lack the key payment integrity
information needed to assess agencies’ actions to reduce improper
payments and hold them accountable.
In addition, we found that five of the seven agencies we reviewed—DOL,
Education, HHS, Treasury, and USDA—had some internal processes in
place to help ensure that they met PIIA reporting requirements for their
noncompliant programs or activities. However, they did not have sufficient
processes, documented in policies and procedures, to track and monitor
the reporting of PIIA noncompliance.
These findings also have important implications for congressional
oversight. Agencies with programs that remain noncompliant with PIIA for
multiple consecutive years are often the same programs that account for
some of the largest improper payment estimates government-wide. When
agencies do not meet PIIA’s annual and consecutive year reporting
requirements, Congress loses visibility into which programs continue to
pose elevated risks and whether agencies are taking meaningful steps to
address them.
Having sufficient, documented processes is essential for agencies to
meet the PIIA noncompliance reporting requirements and ultimately help
save taxpayer dollars. Documentation of such processes would help
ensure that agency staff are clear about what procedures to follow to
meet the reporting requirements, particularly in the event of staff turnover
or changes in roles, ultimately helping to ensure that Congress has the
information needed to assess agency efforts to reduce improper
payments and save taxpayer dollars.
Page 22 GAO-26-108044 Improper Payments
We are making the following six recommendations—one each to OMB,
Recommendations for DOL, Education, HHS, Treasury, and USDA.
Executive Action
The Director of the Office of Management and Budget should clarify that
agencies found noncompliant with PIIA criteria should report required
annual information to GAO and the appropriate authorizing and
appropriations congressional committees. Pursuant to 31 U.S.C. §
3353(b)(5), this information should include (1) a list of programs that have
been noncompliant for 1, 2, 3, 4, or more years and (2) actions planned to
bring the programs or activities into compliance. (Recommendation 1)
The Secretary of Labor should design and implement a process,
documented in policies and procedures, to help ensure the tracking,
monitoring, and timely submission of required PIIA-noncompliant program
information to appropriate authorizing and appropriations congressional
committees, OMB, and GAO. (Recommendation 2)
The Secretary of Education should design and implement a process,
documented in policies and procedures, to help ensure the tracking,
monitoring, and timely submission of required PIIA-noncompliant program
information to appropriate authorizing and appropriations congressional
committees, OMB, and GAO. (Recommendation 3)
The Secretary of Health and Human Services should design and
implement a process, documented in policies and procedures, to help
ensure the tracking, monitoring, and timely submission of required PIIA-
noncompliant program information to appropriate authorizing and
appropriations congressional committees, OMB, and GAO.
(Recommendation 4)
The Secretary of the Treasury, in coordination with the Commissioner of
Internal Revenue, should design and implement a process, documented
in policies and procedures, to help ensure the tracking, monitoring, and
timely submission of required PIIA-noncompliant program information to
appropriate authorizing and appropriations congressional committees,
OMB, and GAO. (Recommendation 5)
The Secretary of Agriculture should design and implement a process,
documented in policies and procedures, to help ensure the tracking,
monitoring, and timely submission of required PIIA-noncompliant program
information to appropriate authorizing and appropriations congressional
committees, OMB, and GAO. (Recommendation 6)
Page 23 GAO-26-108044 Improper Payments
We provided a draft of this report to OMB, CNCS, DOL, USDA,
Agency Comments Education, HHS, Treasury, and VA for review and comment.
CNCS, DOL, Education, HHS, and Treasury provided written comments,
which are reproduced in appendixes VI, VII, VIII, IX, and X, respectively.
DOL, Education, HHS, and Treasury agreed with our recommendations
and expressed plans to design and implement processes to help ensure
the tracking, monitoring, and timely submission of required PIIA-
noncompliant program information; we made no recommendations to
CNCS.
USDA provided comments via email stating that the agency agreed with
our recommendation and stated that, within 30 days, USDA will draft
internal policies and procedures to track, monitor, and timely submit
required PIIA noncompliance information to the appropriate congressional
committees, OMB, and GAO. USDA told us that it anticipates
implementing the formal policy by September 30, 2026.
VA provided technical comments, which we incorporated as appropriate.
OMB did not provide comments on our draft report.
We are sending copies of this report to the appropriate congressional
committees, the Director of the Office of Management and Budget, the
Chief Executive Officer of the Corporation for National and Community
Service, the Secretary of Agriculture, the Secretary of Education, the
Secretary of Health and Human Services, the Secretary of Labor, the
Secretary of the Treasury, the Secretary of Veterans Affairs, and other
interested parties. In addition, the report is available at no charge on the
GAO website at https://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at KociolekK@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made key contributions to this report are
listed in appendix XI.
Kristen Kociolek
Managing Director, Financial Management and Assurance
Page 24 GAO-26-108044 Improper Payments
Appendix I: Payment-Integrity Related
Appendix I: Payment-Integrity Related Matters
for Congressional Consideration
Matters for Congressional Consideration
We have previously recommended matters for congressional
consideration to strengthen payment integrity across the government. 1 As
of January 2026, these seven matters remain open.
1. Congress should consider passing legislation requiring the Office of
Management and Budget (OMB) to provide guidance for agencies to
develop plans for internal control that would then immediately be
ready for use in, or adaptation for, future emergencies or crises and
requiring agencies to report these internal control plans to OMB and
Congress.
2. Congress should consider amending the Payment Integrity
Information Act of 2019 (PIIA) to designate all new federal programs
making more than $100 million in payments in any one fiscal year as
“susceptible to significant improper payments” for their initial years of
operation.
3. Congress should consider amending PIIA to reinstate the requirement
that agencies report on their antifraud controls and fraud risk
management efforts in their annual financial reports.
4. Congress should consider establishing a permanent analytics center
of excellence to aid the oversight community in identifying improper
payments and fraud.
5. Congress should consider clarifying that (1) chief financial officers
(CFO) at Chief Financial Officers Act agencies have oversight
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, discussed in an existing matter for
congressional consideration in our August 2020 report, 2 include
internal controls over spending data and improper payment
information.
6. Congress should consider requiring agency CFOs to (1) submit a
statement in agencies’ annual financial reports certifying the reliability
1GAO, 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); Emergency Relief Funds: Significant Improvements
Are Needed to Address Fraud and Improper Payments, GAO-23-106556 (Washington,
D.C.: Feb. 1, 2023); and Federal Financial Management: Substantial Progress Made since
Enactment of the 1990 Chief Financial Officers Act; Refinements Would Yield Added
Benefits, GAO-20-566 (Washington, D.C.: Aug. 6, 2020).
2GAO-20-566.
Page 25 GAO-26-108044 Improper Payments
Appendix I: Payment-Integrity Related Matters
for Congressional Consideration
of improper payments risk assessments and the validity of improper
payment estimates and describing the CFO’s actions 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 of improper payments.
7. Congress should consider legislation to require improper payment
information required to be reported under PIIA to be included in
agencies’ annual financial reports.
In addition to these government-wide matters for congressional
consideration, we have also made recommendations to Congress that
would enhance the integrity of individual programs that we reviewed. As
of January 2026, these matters remain open.
1. If Congress agrees that significant paid preparer errors exist, it should
consider legislation granting the Internal Revenue Service the
authority to regulate paid tax preparers. 3
2. Congress should consider granting the Department of Labor the
additional authority it is seeking to access wage data to help verify
claimants’ reported income and help ensure the proper payment of
benefits. 4
3GAO, Paid Tax Return Preparers: In a Limited Study, Preparers Made Significant Errors,
GAO-14-467T (Washington, D.C.: Apr. 8, 2014).
4GAO, Federal Employees’ Compensation Act: Case Examples Illustrate Vulnerabilities
That Could Result in Improper Payments or Overlapping Benefits, GAO-13-386
(Washington, D.C.: Apr. 3, 2013).
Page 26 GAO-26-108044 Improper Payments
Appendix II: GAO Questions for Assessing
Appendix II: GAO Questions for Assessing
Agencies’ Compliance Efforts Related to Key
Agencies’ Compliance Efforts Related to Key
Practices for Addressing High-Risk Areas
Practices for Addressing High-Risk Areas
GAO’s High-Risk List identifies government operations with serious
vulnerabilities to fraud, waste, abuse, and mismanagement or in need of
transformation. Listed below are the questions that we used to evaluate
agencies’ reported information on PaymentAccuracy.gov to determine
how agencies’ reported compliance efforts aligned with GAO’s five key
practices for addressing the areas on our High-Risk List.
1. Has the agency identified an official accountable for bringing the
Leadership program into compliance under the Payment Integrity Information Act of
Commitment 2019 (PIIA)?
2. Did the agency describe an accountability mechanism tied to the
success of this official (e.g., establishing performance incentives or
benchmarks)?
3. Did the agency facilitate internal collaboration through coordination
between intra-agency partners and stakeholders to increase access to
information used to mitigate improper payments (e.g., involving chief
financial officers and holding regular meetings to discuss improper
payment topics)?
4. Does the agency report that it has what is needed to improve or
Capacity maintain payment integrity?
5. Did the agency identify its efforts to provide technology, tools, and
training designed to address root causes of improper payments (e.g.,
software, automation, information systems, and training on proper
payment processing methods)?
6. For the noncompliant programs, has the agency identified root causes
Action Plan of improper payments and described corrective actions?
7. Did the agency establish and include planned completion dates for the
corrective actions?
8. In the most recent PIIA compliance report, did the agency inspector
general have any findings related to the reported root causes or
corrective actions? If so, does the agency have planned actions to
address them?
9. Are there any related open GAO recommendations? If so, does the
agency have planned actions to address them?
Page 27 GAO-26-108044 Improper Payments
Appendix II: GAO Questions for Assessing
Agencies’ Compliance Efforts Related to Key
Practices for Addressing High-Risk Areas
10. Did agency report steps it would take to monitor and validate
Monitoring effectiveness and sustainability of actions to reduce improper payments
(e.g., use the Department of the Treasury’s systems, such as Do Not Pay,
to monitor improper payments)?
11. Did the agency monitor progress?
12. Did the agency report how it measures effectiveness of corrective
Demonstrated actions (i.e., establishment of reduction targets)?
Progress
13. Has the agency reported year-over-year reductions in the improper
payment estimates for the noncompliant programs?
Page 28 GAO-26-108044 Improper Payments
Appendix III: Payment Integrity Information
Appendix III: Payment Integrity Information Act
of 2019 Criteria and Office of Management and
Act of 2019 Criteria and Office of
Budget Guidance
Management and Budget Guidance
When an inspector general (IG) determines that the agency is not in
compliance with applicable Payment Integrity Information Act of 2019
(PIIA) criteria or related Office of Management and Budget (OMB)
guidance, the agency is subject to additional reporting and other
requirements. PIIA, together with related OMB guidance, instructs IGs to
report on whether their agencies are compliant with 10 criteria. 1 To meet
these criteria, agencies must
(1a) publish payment integrity information with their annual financial
statements,
(1b) post their annual financial statements and accompanying materials
on their websites,
(2a) conduct improper payment risk assessments for each program with
annual outlays greater than $10 million at least once every 3 fiscal years,
(2b) adequately conclude whether each program is likely to make
improper payments and unknown payments above or below the statutory
threshold (either $100 million or both 1.5 percent of program outlays and
$10 million of all reported program and activity payments made by the
agency during that fiscal year),
(3) publish improper payment and unknown payment estimates for
programs susceptible to significant improper payments and unknown
payments in the accompanying materials to their annual financial
statements,
(4) publish corrective action plans for each program for which an estimate
above the statutory threshold was published in the accompanying
materials to their annual financial statements,
(5a) publish an improper payment and unknown payment reduction target
for each program for which an estimate above the statutory threshold was
published in the accompanying materials to their annual financial
statements,
1PIIA includes six criteria for compliance, which OMB’s guidance expands to 10 by
breaking some criteria into subcomponents and, in some cases, adding new elements. 31
U.S.C. § 3351(2); Office of Management and Budget, Requirements for Payment Integrity
Improvement, OMB Circular No. A-123, Appendix C (Mar. 5, 2021), issued as OMB
Memorandum No. M-21-19.
Page 29 GAO-26-108044 Improper Payments
Appendix III: Payment Integrity Information Act
of 2019 Criteria and Office of Management and
Budget Guidance
(5b) demonstrate improvements to payment integrity or reach a tolerable
improper payment and unknown payment rate,
(5c) develop plans to meet their improper payment and unknown payment
reduction targets, 2 and
(6) report improper payment and unknown payment estimates of less
than 10 percent for each program for which they published estimates in
the accompanying materials to their annual financial statements.
The criteria described above do not apply to all programs or agencies.
For example, if an agency determines through its risk assessment that
none of its programs or activities are susceptible to significant improper
payments, criteria three through six would not be applicable.
2The criteria numbered 5a, 5b, and 5c in OMB’s guidance relate to 31 U.S.C. §
3351(2)(E), which states that compliance means that the executive agency publishes
improper payments reduction targets prepared under 31 U.S.C. § 3352(d) that the
executive agency may have in the accompanying materials to the annual financial
statements for each program or activity assessed to be at risk, and has demonstrated
improvements and developed a plan to meet the reduction targets.
Page 30 GAO-26-108044 Improper Payments
Appendix IV: Alignment of Certain Agencies’Appendix IV: Alignment of Certain Agencies’
Actions with GAO’s Key Practices for
Actions with GAO’s Key Practices for
Addressing High-Risk Areas
Addressing High-Risk Areas
Agencies with programs or activities found to be noncompliant for 4 or
more consecutive years under the Payment Integrity Information Act of
2019 (PIIA) are required to report on their compliance efforts. Table 4
provides detailed information that agencies reported on
PaymentAccuracy.gov. We summarized such information based on how
agencies’ reported compliance efforts to reduce improper payments
aligned with our key practices for addressing high-risk areas.
Table 4: How Agencies’ Compliance Efforts for 4 Years of Noncompliance Aligned with GAO’s Key Practices for Addressing
High-Risk Areas
Agency/program Key practice/agency efforts
Department of Labor (DOL) Leadership commitment. To help initiate and sustain progress, DOL reported that it
Employment & Training Administration designated the Administrator of the Office of Unemployment Insurance as the accountable
(ETA) – Federal State Unemployment official for bringing the program into compliance with the Payment Integrity Information Act of
Insurance (UI) 2019 (PIIA). According to DOL, the office’s performance management plan focuses on
requirements for states to maintain improper payment rates below 10 percent, with corrective
actions if they fail to do so. Additionally, DOL reported that its ETA, through the DOL-funded
national UI Integrity Center, (1) assisted states with projects to provide UI, fraud prevention,
and development of fraud risk management resources and strategies and (2) coordinated
with the Office of Inspector General (OIG) to discuss emerging UI fraud issues and antifraud
measures.
Capacity. Capacity represents the resources (i.e., skilled staff, adequate funding, internal
controls, technology, and management and organization infrastructure) to resolve key risks.
DOL reported that its fiscal year 2025 budget requested funds for technology upgrades, ID
verification services, and antifraud activities. DOL stated that it would continue to provide
technical assistance on proposed UI integrity legislation as needed and promote the UI
integrity legislative package as set out in DOL’s 2025 budget proposal. DOL also stated that
the DOL-funded national UI Integrity Center provides resources, training, and enhanced data
tools to help states reduce improper payments.
Action plan. To define the root causes and solutions and provide an approach for
substantially completing corrective measures, DOL reported identifying the following as its
most commonly occurring UI improper payments:
“Work search” improper payments occur when UI claimants fail to properly document their
work search efforts or fail to comply with state work search requirements.
• “Benefit year earnings” improper payments occur when UI claimants either fail to report
earnings or incorrectly report earnings from employment.
• “Separation” improper payments occur when UI claimants receive benefits and are later
determined to be ineligible due to a disqualifying separation from previous employment.
DOL reported that its corrective actions to address these types of improper payments include
issuing guidance and technical assistance to states, strengthening ID verification, providing
states with additional payment integrity data sources, and expanding fraud detection tools.
DOL stated that its planned completion dates for these corrective actions are in fiscal year
2028.
To improve DOL’s compliance efforts with PIIA, the OIG, in its report issued in May 2025,
recommended that
1. the Assistant Secretary for ETA maintain ETA’s current focus on increasing technical
assistance and funding to states to improve improper payment reduction strategies to
reduce the improper payments estimate rate below the 10 percent threshold and
Page 31 GAO-26-108044 Improper Payments
Appendix IV: Alignment of Certain Agencies’
Actions with GAO’s Key Practices for
Addressing High-Risk Areas
Agency/program Key practice/agency efforts
2. the Chief Financial Officer update review procedures to ensure accurate responses to
Office of Management and Budget (OMB) payment integrity data call prompts; ensure
compliance with PIIA; and ensure that information is complete, accurate, and consistent
before the final submission of the OMB payment integrity data call, and further refine
reviews of published information on PaymentAccuracy.gov.
Monitoring. To help agency leaders track and independently validate effectiveness and
sustainability of corrective measures, ETA reported that it holds states accountable for
reducing UI improper payments through using performance measures and monitoring states
to ensure that the administration of the state’s UI program is in compliance with federal law
and state law. ETA also reports holding states accountable for UI performance deficiencies
by requiring states to submit corrective action plans outlining milestones to improve program
performance and requiring states to submit quarterly updates detailing state actions toward
implementation of the milestones. Furthermore, DOL reported that its ETA requires states to
conduct quality assurance audits of a sample of paid UI claims to determine if the payment
was accurate or improper and that states use a diagnostic tool to report the audit findings,
including the root cause and the responsibility for improper payments.
Demonstrated progress. To demonstrate progress in implementing corrective measures that
address the root causes of high-risk areas, ETA stated that it uses performance measures to
evaluate states’ UI operations and has established a fiscal year 2025 agency priority goal of
reducing the UI improper payment rate. According to DOL, ETA’s actions have helped
decrease the estimated UI improper payment rate from 16.5 percent in fiscal year 2023 to
15.9 percent in fiscal year 2024.
Department of the Treasury—Internal Leadership commitment. To initiate and sustain progress, IRS reported that it designated the
Revenue Service (IRS) Director of IRS Refund Integrity and Compliance Services as the accountable official. In
Additional Child Tax Credit addition, IRS reported sharing data with the Department of Health and Human Services
(HHS) and its Office of Child Support Enforcement and the Social Security Administration to
American Opportunity Tax Credit enable IRS to identify discrepancies in taxpayer claims and improve detection of improper
Earned Income Tax Credit Additional Child Tax Credit claims.
Capacity. Capacity represents the resources (i.e., skilled staff, adequate funding, internal
controls, technology, and management and organization infrastructure) to resolve key risks.
IRS reported using data sharing with HHS and outreach to improve payment accuracy. IRS
also reported that it has the necessary controls and resources but cited statutory limits as the
main barrier to reducing improper payments. IRS stated that it has proposed various
legislative changes over the years aimed at providing more effective tools for managing
refundable tax credits (RTC). For example, in the fiscal year 2025 President’s Budget, IRS
stated that it proposed an increase and expansion of its authority to address noncompliance
or inappropriate behavior by paid tax return preparers and e-file providers.
Action plan. To define the root causes and solutions and provide an approach for
substantially completing corrective measures, IRS reported that it identified statutory and
program design limits as the main causes of RTC improper payments, along with taxpayer
misreporting and complex eligibility rules. IRS stated that its planned corrective actions,
including pre-refund examinations and preparer oversight, were scheduled for completion in
fiscal year 2025.
To improve Treasury’s compliance efforts, Treasury’s OIG, in its report issued in May 2025,
recommended that the Commissioner, Taxpayer Services,
1. work with the Office of Tax Policy to request additional legislative considerations that will
help IRS reduce improper payments associated with RTCs;
2. conduct an analysis of the new identity verification procedures to (1) identify the impact
on taxpayer filing behavior and refundable credits claimed, (2) evaluate the number of
returns selected for post-refund review, and (3) measure the dollar impact to tax
administration and improper payments; and
Page 32 GAO-26-108044 Improper Payments
Appendix IV: Alignment of Certain Agencies’
Actions with GAO’s Key Practices for
Addressing High-Risk Areas
Agency/program Key practice/agency efforts
3. upon completing the analysis noted in Recommendation 2, determine whether the new
identity verification procedures should be continued.
Monitoring. To help agency leaders track and independently validate effectiveness and
sustainability of corrective measures, IRS stated that it annually updates its RTC compliance
plans and internal revenue manuals. IRS also provides training to employees who administer
RTCs.
Demonstrated progress. To demonstrate progress in implementing corrective measures that
address the root causes of high-risk areas, IRS cited recent declines in estimated improper
payment rates for RTCs. From fiscal year 2023 to fiscal year 2024, the Additional Child Tax
Credit improper payment rate decreased from 14.5 percent to 10.75 percent, the American
Opportunity Tax Credit improper payment rate decreased from 31.6 percent to 27.7 percent,
and the Earned Income Tax Credit improper payment rate decreased from 33.5 percent to
27.3 percent.
However, IRS emphasized that without significant restructuring of RTCs, including legislative
action, the RTC improper payment rate will not be reduced below 10 percent.
Department of Agriculture (USDA) Leadership commitment. To initiate and sustain progress, USDA reported that it designated
Farm Service Agency (FSA) the Acting Deputy Administrator for Farm Programs and the Deputy Administrator for Field
Emergency Conservation Program Operations as the accountable officials for ECP - Disasters compliance. According to USDA,
(ECP) - Disasters FSA’s employee performance plans focus on requirements for supervisors to timely address
PIIA findings, provide training to employees, and ensure that processes for program integrity
and proper audit documentation are included in software to monitor the administration of ECP
- Disasters.
Capacity. Capacity represents the resources (i.e., skilled staff, adequate funding, internal
controls, technology, and management and organization infrastructure) to resolve key risks.
USDA reported that it needs funds for future software upgrades. USDA stated that it
developed and released new software to process applications more efficiently and reduce
administrative errors. Additionally, USDA stated that it provides ongoing training to state
office staff on updated policy requirements and PIIA deficiencies. Furthermore, USDA
reported providing training on policy and software, PIIA findings, and root causes of improper
payments to all FSA employees with ECP - Disasters responsibilities.
Action plan. To define the root causes and solutions and provide an approach for
substantially completing corrective measures, USDA reported that it identified administrative
errors as the leading causes of its improper payments. According to USDA, these errors
included applications for ineligible participants; incompletely or improperly filed payment
documentation; and missing, incomplete, or improperly filed ECP - Disasters forms. USDA
stated that its planned corrective actions include (1) integrating ECP - Disasters program
spot-checks and program reviews into its internal Review and Documentation Tracking
System to improve oversight and ensure timely review completion, (2) implementing a new
policy requiring full completion of checklists before payments are issued, (3) reviewing a
percentage of ECP - Disasters agreements to ensure adherence to policy, and (4) providing
training to staff on updated policy requirements. USDA also stated that these planned
corrective actions are scheduled for completion in fiscal year 2025.
To improve USDA’s compliance efforts, the USDA OIG, in its report issued in May 2025,
recommended that the agency work with the Office of Chief Financial Officer to take the
following actions to ensure compliance with PIIA:
1. Improve processes and efforts to evaluate the effectiveness of corrective actions to
assist in the reduction of the improper payments estimate rate below the 10 percent
threshold.
2. Develop and monitor agency-level corrective actions corresponding to the identified root
causes of improper payments.
Page 33 GAO-26-108044 Improper Payments
Appendix IV: Alignment of Certain Agencies’
Actions with GAO’s Key Practices for
Addressing High-Risk Areas
Agency/program Key practice/agency efforts
3. Conduct ongoing monitoring of the state-level corrective actions and ensure that these
corrective actions are being implemented.
4. Continue working with states to identify state-specific corrective actions and ensure that
these corrective actions are being implemented.
5. Enhance corrective actions to specifically target and address the primary root causes
associated with the highest improper payment percentage.
Additionally, in its report issued in May 2025, OIG found that USDA failed to demonstrate
improvements in payment integrity for FSA ECP-Disasters. To improve USDA’s compliance
efforts in this area, the OIG recommended that management take the following actions to
ensure compliance with PIIA:
1. Maintain a focus on continuous improvement in the development and implementation of
new mitigation strategies (e.g., examination of existing controls in place and the
implementation of more effective controls) to decrease improper payment and unknown
payment rate to a tolerable rate each year. If a program’s improper payment and
unknown payment rate does not improve or increases, take sufficient steps to identify
root causes and implement appropriate corrective action that will reduce the rates year-
over-year until the rate is below 10 percent.
2. Where applicable and cost effective, implement automated enhancements to better
prevent and detect errors.
Monitoring. To help agency leaders track and independently validate effectiveness and
sustainability of corrective measures, USDA reported that it plans to incorporate internal FSA
ECP-Disasters program spot-checks and program reviews into its Internal Review and
Documentation Tracking System to document results, analyze results for training needs,
evaluate the progress of corrective actions related to these reviews, and identify areas for
improvement. Additionally, USDA stated that it solicited and received feedback from state and
county offices on the effectiveness of the ECP training offered.
Demonstrated progress. To demonstrate progress in implementing corrective measures that
address the root causes of high-risk areas, USDA stated that it published a payment integrity
dashboard in March 2025 to analyze internal review findings related to PIIA requirements.
According to USDA officials, the results of this analysis will help USDA target corrective
actions and provide additional training and oversight to states and counties with the highest
rates of improper payments. Despite establishing reduction targets for ECP-Disasters, USDA
reported that the improper payment rate for this program has increased from 40.4 percent in
fiscal year 2023 to 45.2 percent in fiscal year 2024.
Department of Veterans Affairs (VA) Leadership commitment. To initiate and sustain progress, VA reported that it designated the
Purchased Long-Term Services and Deputy Executive Director of Home and Community Based Purchase Care as the
Supports accountable official. According to VA, senior leaders are held to performance criteria covering
prevention, detection, and remediation of improper payments, with oversight from VA’s
Performance Review Board. VA also stated that it collaborates with third-party administrators
to correct billing practices and transition to an automated claims adjudication system.
Capacity. Capacity represents the resources (i.e., skilled staff, adequate funding, internal
controls, technology, and management and organization infrastructure) to resolve key risks.
VA reported that it has adequate resources and is not requesting additional funding. VA
stated that it is continuing to implement new software to streamline claims, automate eligibility
determinations, and enhance reporting and auditing capabilities. Additionally, VA stated that it
plans to develop new and enhanced claims processing training.
Action plan. To define the root causes and solutions and provide an approach for
substantially completing corrective measures, VA reported identifying data access issues,
manual processing errors, and documentation gaps as root causes. VA also reported
identifying the automation of eligibility determinations and additional training as its primary
mitigation strategies, with planned completion dates in fiscal year 2025.
Page 34 GAO-26-108044 Improper Payments
Appendix IV: Alignment of Certain Agencies’
Actions with GAO’s Key Practices for
Addressing High-Risk Areas
Agency/program Key practice/agency efforts
To improve VA’s compliance efforts, VA’s OIG, in its report issued in May 2025,
recommended that the Under Secretary for Health reduce improper and unknown payment
rates to below 10 percent for the Purchased Long-Term Services and Supports program.
(This repeat recommendation has been in place since the VA OIG’s fiscal year 2020 report,
which was the office’s first review under PIIA.)
Monitoring. To help agency leaders track and independently validate effectiveness and
sustainability of corrective measures, VA stated that it monitors the progress and results of
corrective action implementation each quarter. Additionally, VA stated that it performs an
annual effectiveness review to measure whether a corrective action has reduced or is
properly designed to reduce improper and unknown payments for a specific root cause,
based on a set benchmark. According to VA, the annual effectiveness review process allows
VA to create or update corrective actions as necessary.
Demonstrated progress. To demonstrate progress in implementing corrective measures that
address the root causes of high-risk areas, VA stated that it updates its corrective action
plans annually, monitors progress on implementing the corrective actions every quarter, and
performs an annual effectiveness review to measure whether corrective actions have reduced
or are properly designed to reduce improper payments, based on a set benchmark.
Additionally, VA stated that it has demonstrated progress by reporting decreasing improper
payment rates for the Purchased Long-Term Services and Supports program from 38.7
percent in fiscal year 2023 to 13.5 percent in fiscal year 2024.
Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-26-108044
Page 35 GAO-26-108044 Improper Payments
Appendix V: GAO Open Recommendations Appendix V: GAO Open Recommendations on
Improper Payments and Fraud for Certain
on Improper Payments and Fraud for Certain
Agencies
Agencies
GAO has made numerous recommendations to improve payment integrity
for agencies. Table 5 identifies open recommendations as of January
2026 to the Departments of Labor’s (DOL) unemployment insurance
program and the Treasury’s refundable tax credit program, which have
been noncompliant under the Payment Integrity Information Act of 2019
(PIIA) for 4 consecutive fiscal years. There were no payment integrity-
related GAO open recommendations for the Departments of Agriculture
or Veterans Affairs for programs we reviewed.
Table 5: GAO Open Recommendations on Improper Payments and Fraud to the Department of Labor (DOL) and the
Department of the Treasury
GAO report number GAO report title Recommendations
Recommendations to DOL: Unemployment insurance
GAO-25-106199 COVID-19 Relief: SBA The Secretary of Labor should ensure that the Employment and Training
and DOL Should Improve Administration reports the total overpayment recovery rate in place of, or along
Processes to Identify and with, the nonwaived overpayment recovery rate for the Unemployment Insurance
Recover Overpayments (UI) programs, particularly pandemic-related UI programs (i.e., Pandemic
Unemployment Assistance, Federal Pandemic Unemployment Compensation,
Pandemic Emergency Unemployment Compensation, and Mixed Earner
Unemployment Compensation). (Recommendation 4)
The Secretary of Labor should ensure that the Employment and Training
Administration expands its UI program guidance to require that future temporary
programs establish state overpayment recovery baselines to support DOL’s
monitoring of states’ progress in recovering identified overpayments.
(Recommendation 5)
GAO-22-105162 Unemployment The Secretary of Labor should develop and execute a transformation plan that
Insurance: meets GAO’s high-risk criteria for transformation; the plan should outline
Transformation Needed coordinated and sustained actions to address issues related to providing effective
to Address Program service and mitigating financial risk, including ways to demonstrate improvements.
Design, Infrastructure, Planned actions may include addressing audit recommendations and determining
and Integrity Risks whether legislative changes are needed, as appropriate. Planned actions may
also include achieving quantifiable results in reducing improper payment rates,
including those related to fraud; improving efficiency in claims processing and
restoring pre-pandemic payment timeliness levels; better reaching current worker
populations; and enhancing equity in benefit distribution. (Recommendation 1)
GAO-22-104438 Pandemic The Secretary of Labor should study and advise the Congress and other
Unemployment policymakers on the costs, benefits, and risks of various options to systematically
Assistance: Federal support self-employed and contingent workers during periods of involuntary
Program Supported unemployment outside of declared disasters, including considering options’
Contingent Workers Amid feasibility and approach to fraud prevention. (Recommendation 1)
Historic Demand, but
DOL Should Examine
Racial Disparities in
Benefit Receipt
Page 36 GAO-26-108044 Improper Payments
Appendix V: GAO Open Recommendations on
Improper Payments and Fraud for Certain
Agencies
GAO report number GAO report title Recommendations
GAO-18-486 Unemployment The Assistant Secretary of DOL’s Employment and Training Administration should
Insurance: Actions provide states with information about its determination that the use of state formal
Needed to Ensure warning policies is no longer permissible under federal law. (Recommendation 1)
Consistent Reporting of The Assistant Secretary of DOL’s Employment and Training Administration should
Overpayments and clarify information on work search verification requirements in its revised Benefit
Claimants’ Compliance Accuracy Measurement procedures. The revised procedures should include an
with Work Search explanation of what DOL considers to be sufficient verification of claimants’ work
Requirements search activities. (Recommendation 3)
Recommendations to Treasury and the Internal Revenue Service (IRS): Refundable tax credits
GAO-23-105217 Paid Tax Return The Commissioner of Internal Revenue should finalize the Service-wide Return
Preparers: IRS Efforts to Preparer Strategy and identify the resources needed to implement it.
Oversee Refundable (Recommendation 6)
Credits Help Protect
Taxpayers but Additional
Actions and Authority Are
Needed
GAO-22-105397 COVID-19: Current and The Secretary of the Treasury, in coordination with the Commissioner of Internal
Future Federal Revenue, should enhance collaboration among departmental components for
Preparedness Requires refundable tax credit communication and outreach efforts by including relevant
Fixes to Improve Health participants and clearly defining participant outcomes, roles, and responsibilities.
Data and Address (Recommendation 13)
Improper Payments The Commissioner of Internal Revenue should collect sufficient, relevant, and
comparable data on the usefulness and accessibility of its communications and
outreach efforts for refundable tax credits and use these data to develop
performance metrics to assess the effectiveness of ongoing efforts.
(Recommendation 15)
GAO-18-544 Tax Fraud and Based on the [updated and expanded analysis of the cost and benefits of
Noncompliance: IRS digitizing returns filed on paper], the Commissioner of Internal Revenue should
Could Further Leverage implement the most cost-effective method to digitize information provided by
the Return Review taxpayers who file returns on paper. (Recommendation 3)
Program to Strengthen Based on its evaluation of the Return Review Program, the Commissioner of
Tax Enforcement Internal Revenue should expand the Return Review Program to support identified
activities. (Recommendation 5)
GAO-16-475 Refundable Tax Credits: To strengthen efforts to identify and address noncompliance with the Earned
Comprehensive Income Tax Credit, Additional Child Tax Credit, and American Opportunity Tax
Compliance Strategy and Credit, the Commissioner of Internal Revenue should direct Refundable Credits
Expanded Use of Data Policy and Program Management to take necessary steps to ensure the reliability
Could Strengthen IRS’s of collections data and periodically review that data to (a) compute a collections
Efforts to Address rate for post-refund enforcement activities and (b) determine what additional
Noncompliance analyses would provide useful information about compliance results and costs of
post-refund audits and document-matching reviews. (Recommendation 4)
Source: GAO summary based on previously issued reports. | GAO-26-108044
Page 37 GAO-26-108044 Improper Payments
Appendix VI: Comments from the
Appendix VI: Comments from the Corporation
for National and Community Service
Corporation for National and Community
Service
Page 38 GAO-26-108044 Improper Payments
Appendix VII: Comments from the
Appendix VII: Comments from the Department
of Labor
Department of Labor
Page 39 GAO-26-108044 Improper Payments
Appendix VIII: Comments from the
Appendix VIII: Comments from the Department
of Education
Department of Education
Page 40 GAO-26-108044 Improper Payments
Appendix IX: Comments from the
Appendix IX: Comments from the Department
of Health and Human Services
Department of Health and Human Services
Page 41 GAO-26-108044 Improper Payments
Appendix IX: Comments from the Department
of Health and Human Services
Page 42 GAO-26-108044 Improper Payments
Appendix X: Comments from the Department
Appendix X: Comments from the Department
of the Treasury
of the Treasury
Page 43 GAO-26-108044 Improper Payments
Appendix X: Comments from the Department
of the Treasury
Page 44 GAO-26-108044 Improper Payments
Appendix X: Comments from the Department
of the Treasury
Page 45 GAO-26-108044 Improper Payments
Appendix XI: GAO Contact and Staff
Appendix XI: GAO Contact and Staff
Acknowledgments
Acknowledgments
Kristen Kociolek, KociolekK@gao.gov
GAO Contact
In addition to the contact named above, Hannah Padilla (Director), Shirley
Staff Abel (Assistant Director), Jeremy Choi, Stephanie Thomas, Isaac White,
Acknowledgments and Gary Wiggins made key contributions to this report. Seth Brewington,
Marcia Carlsen, Patrick Frey, Jason Kelly, Jason Kirwan, Dylan Silver,
Amanda Stogsdill, and Alexa Young also contributed to this report.
Page 46 GAO-26-108044 Improper Payments
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