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GAO-26-108694: Payment Integrity: Agencies' Estimated Improper Payments Increased to $186 Billion in Fiscal Year 2025

Summary

GAO-26-108694, Payment Integrity: Agencies' Estimated Improper Payments Increased to $186 Billion in Fiscal Year 2025, a Government Accountability Office Q&A report to congressional committees dated April 27, 2026. It states that federal agencies' estimates totaled about $186 billion in reported improper payments in fiscal year 2025, an increase of about $24 billion, largely attributable to programs that reported estimates in fiscal year 2025 but not in the prior year. About $153 billion (approximately 82 percent) of the estimates represent overpayments. In fiscal year 2024, 12 of the 24 CFO Act agencies fully complied with applicable improper payment criteria, according to their inspectors general.

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“GAO-26-108694: Payment Integrity: Agencies' Estimated Improper Payments Increased to $186 Billion in Fiscal Year 2025.” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-26-108694-payment-integrity-agencies-estimated-improper-payments-i-013689ad1c/, SHA-256 978d63b6335ac8ae027d01aea5b6d3df3756f844b3eacbc1e2f641c56a4b38c9.

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                       U.S. Government Accountability Office

Payment Integrity: Agencies’ Estimated Improper
Payments Increased to $186 Billion in Fiscal Year 2025
GAO-26-108694
Q&A Report to Congressional Committees
April 27, 2026




Why This Matters
                          Improper payments—those that should not have been made or were made in
                          incorrect amounts—have consistently been a government-wide issue. Since
                          fiscal year 2003, cumulative improper payment estimates have totaled about $3
                          trillion, and the actual amount of improper payments may be significantly higher.
                          Reducing improper payments is critical to safeguarding federal funds.

                          The Payment Integrity Information Act of 2019 (PIIA) requires agencies to
                          manage improper payments by identifying risks, taking corrective actions, and
                          estimating and reporting on improper payments in programs they administer.
                          PIIA also requires each agency’s inspector general (IG) to issue an annual report
                          on compliance with applicable PIIA criteria.

                          The Secretary of the Treasury, in coordination with the Director of the Office of
                          Management and Budget (OMB), is required to annually submit audited financial
                          statements for the U.S. government to the President and Congress. GAO is
                          required to audit these statements. We have reported on improper payments in
                          our audit reports on the U.S. government’s consolidated financial statements
                          since fiscal year 1997, and we have found that these payments represent a
                          material deficiency or weakness in internal controls. Specifically, we have noted
                          that the federal government is unable to determine the full extent of its improper
                          payments or to reasonably assure that it takes appropriate actions to reduce
                          them.

                          We performed this audit in connection with the statutory requirement for GAO to
                          audit the U.S. government’s consolidated financial statements. This report
                          provides an overview of federal agencies’ improper payment estimates for fiscal
                          year 2025. Additionally, we discuss agencies’ compliance with requirements for
                          reporting and managing improper payments in fiscal year 2024 as well as the
                          recommendations that IGs made to the agencies to improve compliance.


Key Takeaways             •   In fiscal year 2025, federal agencies’ estimates totaled about $186 billion in
                              reported improper payments, an increase of about $24 billion from the prior
                              fiscal year. This increase is largely attributable to programs that reported
                              estimates in fiscal year 2025 but did not report estimates in the prior fiscal
                              year. In addition, the Department of Health and Human Services (HHS) noted
                              an increase in Medicaid improper payments due to increased errors in
                              eligibility redeterminations and provider screening while phasing out COVID-
                              era flexibilities in the Medicaid program. About $153 billion (approximately 82
                              percent) of the estimates represent overpayments.
                          •   The improper payment estimates do not represent the full extent of
                              government-wide improper payments. For example, some programs that
                              agencies have determined are susceptible to significant improper payments,
Page 1                                                                               GAO-26-108694 Improper Payments
                                             such as HHS’s Temporary Assistance for Needy Families (TANF), did not
                                             estimate improper payments. In addition, IGs have reported that agencies’
                                             improper payment estimates are unreliable for some programs.
                                        •    In fiscal year 2024, 12 of the 24 agencies that the Chief Financial Officers Act
                                             of 1990 (CFO Act) covers fully complied with applicable improper payment
                                             criteria, according to their agency IGs.


What are federal        Agencies reported about $186 billion in improper payment estimates for fiscal
agencies’ estimates for year 2025. 1 This amount represents an increase of about $24 billion from the
fiscal year 2025        fiscal year 2024 total (see fig. 1). 2
improper payments?
Figure 1: Total Reported Executive Branch Agency Improper Payment Estimates, Fiscal Years 2003–2025




Note: Prior year improper payment estimates have not been adjusted for inflation.


                                        Our analysis of agency data shows that 15 agencies reported improper payment
                                        estimates across 64 programs. As shown in figure 2, about 73 percent
                                        (approximately $136 billion) of the government-wide total of estimated improper
                                        payments that agencies reported for fiscal year 2025 is concentrated in five
                                        program areas:
                                        •    HHS’s Medicare, comprising three programs ($57 billion); 3
                                        •    HHS’s Medicaid ($37 billion); 4
                                        •    the Department of the Treasury’s Earned Income Tax Credit ($21 billion);
                                        •    the Department of Agriculture’s (USDA) Supplemental Nutrition Assistance
                                             Program ($10 billion); and
                                        •    the Small Business Administration’s (SBA) Shuttered Venue Operators Grant
                                             program ($10 billion).




Page 2                                                                                                GAO-26-108694 Improper Payments
         Figure 2: Programs Reporting the Largest Percentage of Government-Wide Improper Payments
         Estimates for Fiscal Year 2025




         Note: Improper payment estimates displayed in the figure include unknown payments. Executive branch agency
         estimates of improper payments treat as improper any payments whose propriety cannot be determined due to
         lacking or insufficient documentation. Percentages in the figure do not sum to 100 percent due to rounding.


         As shown in figure 3, most of the total $186 billion in government-wide improper
         payment estimates for fiscal year 2025 consisted of overpayments. The
         remaining improper payments consisted of underpayments, unknown payments,
         and technically improper payments. 5

         Figure 3: Agencies’ Fiscal Year 2025 Reported Estimated Improper Payments by Type




         The fiscal year 2025 improper payment estimates do not include certain
         programs that agencies have determined are susceptible to significant improper
         payments. As a result, the total reported estimates do not represent the full
         extent of government-wide improper payments. For example, the $186 billion
         total does not include estimates of improper payments made under HHS’s TANF
         program, which spent approximately $16.5 billion in fiscal year 2025. HHS
         reported that it does not calculate or report improper payment amounts for this
         program due to statutory limitations. In April 2022, we recommended that

Page 3                                                                               GAO-26-108694 Improper Payments
                        Congress consider providing HHS the authority to require states to report the
                        data it needs to estimate and report on improper payments for TANF. 6 As of April
                        2026, Congress had not yet enacted legislation to address this recommendation.

                        GAO has made numerous recommendations to Congress and agencies to help
                        reduce improper payments government-wide. In March 2022, GAO
                        recommended 10 matters for congressional consideration to enhance
                        transparency and accountability of federal spending. 7 These matters included

                        •   designating all new federal programs making more than $100 million in
                            payments in any one fiscal year as susceptible to improper payments and
                        •   establishing a permanent data analytics center of excellence to aid the
                            oversight community in identifying improper payments and fraud. 8

                        One of the recommended matters was that, to enhance federal payment integrity,
                        Congress should make permanent a pilot program that requires the Social
                        Security Administration to share its Death Master File with the Do Not Pay
                        system that Treasury maintains. In February 2026, the President signed into law
                        the Ending Improper Payments to Deceased People Act. 9 This law makes the
                        pilot program permanent, effective December 27, 2026.

                        As of April 2026, the other nine matters remain open.


How many programs       For fiscal year 2025, eight federal programs reported improper payment
reported improper       estimates of $5 billion or more (see table 1). 10
payment amounts of at
least $5 billion?




Page 4                                                                            GAO-26-108694 Improper Payments
                      Table 1: Federal Programs Reporting Annual Estimated Improper Payment Amounts of at Least $5
                      Billion for Fiscal Year 2025

                                                                                                 Estimated improper         Estimated
                       Agency                       Program name                                    payment amount improper payment
                                                                                                  (dollars in billions) rate (percent)
                       Department of
                       Health and Human             Medicaid                                                          $37.4                   6.1
                       Services
                       Department of
                       Health and Human             Medicare Fee-for-Service                                              28.8                6.6
                       Services
                       Department of
                       Health and Human             Medicare Advantage (Part C)                                           23.7                6.1
                       Services
                       Department of the
                                                    Earned Income Tax Credit                                              21.1               32.7
                       Treasury
                       Department of                Supplemental Nutrition
                                                                                                                          10.2               10.9
                       Agriculture                  Assistance Program
                       Small Business               Shuttered Venue Operators
                                                                                                                          10.1               68.9
                       Administration               Grant
                       Social Security
                                                    Supplemental Security Income                                           7.3               11.6
                       Administration
                       Department of                Federal-State Unemployment
                                                                                                                           5.6               14.9
                       Labor                        Insurance
                      Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-26-108694

                      Note: Improper payment estimates displayed in the table include unknown payments. Executive branch agency
                      estimates of improper payments treat as improper any payments whose propriety cannot be determined due to
                      lacking or insufficient documentation. The estimated improper payment rate is the estimated amount in
                      improper payments divided by the amount in program outlays for a given program in a given fiscal year.



How many programs     For fiscal year 2025, 19 federal programs reported improper payment rate
reported improper     estimates of at least 10 percent, including six programs whose rates exceeded
payment rates of at   25 percent (see table 2). 11
least 10 percent?




Page 5                                                                                                             GAO-26-108694 Improper Payments
         Table 2: Federal Programs Reporting Annual Estimated Improper Payment Rates Greater Than 10
         Percent for Fiscal Year 2025

                                                                                                                        Estimated
         Agency                         Program name                                                            improper payment
                                                                                                                    rate (percent)
         Small Business
                                        Shuttered Venue Operators Grant Program                                                  68.9
         Administration
         Department of
                                        Emergency Conservation Program                                                           55.5
         Agriculture
         Department of the
                                        Earned Income Tax Credit                                                                 32.7
         Treasury
         Department of the
                                        Refundable Premium Assistance Tax Credit                                                 31.6
         Treasury
         Department of the
                                        American Opportunity Tax Credit                                                          30.7
         Treasury
         Department of
                                        Rental Housing Assistance Program Sections 8, 236, &
         Housing and Urban                                                                                                       26.4
                                        811
         Development
         Corporation for
         National and                   The Foster Grandparent Program                                                           23.6
         Community Service
         Small Business
                                        Paycheck Protection Program (PPP) Loan Forgiveness                                       19.2
         Administration
         Department of Labor Federal-State Unemployment Insurance                                                                14.9
         Department of the
                                        Additional Child Tax Credit                                                              13.6
         Treasury
         Small Business
                                        PPP Loan Guaranty Purchases                                                              13.3
         Administration
         Department of                  Travel Pay Other Defense Organization - Integrated
                                                                                                                                 13.1
         Defense                        Automated Travel System
         Social Security
                                        Supplemental Security Income                                                             11.6
         Administration
         Department of
                                        Travel Pay Army - Defense Travel System                                                  11.2
         Defense
         Department of                  Travel Pay Other Defense Organization - Defense Travel
                                                                                                                                 11.0
         Defense                        System
         Department of
                                        Supplemental Nutrition Assistance Program                                                10.9
         Agriculture
         Department of
                                        Noninsured Crop Disaster Assistance Program                                              10.6
         Agriculture
         Department of
                                        Child and Adult Care Food Program                                                        10.5
         Agriculture
         Department of
         Health and Human               Head Start                                                                               10.3
         Services
         Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data. | GAO-26-108694

         Note: Improper payment rates displayed in the table include unknown payments. Executive branch agency
         estimates of improper payments treat as improper any payments whose propriety cannot be determined due to
         lacking or insufficient documentation. The estimated improper payment rate is the estimated amount in
         improper payments divided by the amount in program outlays for a given program in a given fiscal year.




Page 6                                                                                                  GAO-26-108694 Improper Payments
How many programs      Our analysis of PaymentAccuracy.gov data found that three programs reported
reported substantial   substantial declines in estimated improper payments for fiscal year 2025
declines in improper   compared with the prior year (see table 3). 12 One agency attributed its decline to
payments?              improved internal controls, while the other agencies did not provide a reason for
                       their declines. Specifically, HHS noted that it had enhanced its internal controls
                       related to prior authorizations, which are used to verify compliance with
                       coverage, coding, and payment rules before services are rendered and claims
                       are paid. In addition, variability arising from the improper payment estimation
                       process could potentially explain a portion of the reported decreases, given that
                       all improper payment estimates have a margin of error.

                       Table 3: Federal Programs with Substantial Declines in Estimated Improper Payments from Fiscal Year
                       2024 to Fiscal Year 2025
                                                        Estimated                   Decrease
                                                                       Decrease
                                                        fiscal year                    in rate
                                                                      in amount
                                                                2025              from fiscal
                                                                     from fiscal               Reason for decrease from
                       Agency/program                     improper                 year 2024
                                                                       year 2024               agency financial report
                                                         payments                         (net
                                                                      (dollars in
                                                        (dollars in               percentage
                                                                        billions)
                                                           billions)                  points)
                       Department of                            $28.8               $2.9                1.1 Improved internal controls.
                       Health and Human
                       Services –
                       Medicare Fee-for-
                       Service
                       Small Business                              0.2                1.5              11.4 No reason provided.
                       Administration –
                       Paycheck
                       Protection
                       Program Loan
                       Guaranty
                       Purchases
                       Department of                               0.3                1.3               2.6 No reason provided.
                       Homeland Security
                       – Federal
                       Emergency
                       Management
                       Agency Public
                       Assistance –
                       Validate As You
                       Go
                       Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data and agency financial reports. | GAO-26-108694

                       Note: Improper payment estimates and rates displayed in the table include unknown payments. Executive
                       branch agency estimates of improper payments treat as improper any payments whose propriety cannot be
                       determined due to lacking or insufficient documentation. The estimated improper payment rate is the estimated
                       amount in improper payments divided by the amount in program outlays for a given program in a given fiscal
                       year. For the purposes of this report, we considered a decline to be substantial if estimated improper payments
                       decreased by over $1 billion and the improper payment rate decreased more than the reported margin of error.


                       In addition, one agency that reported an estimate of over $1 billion for fiscal year
                       2024 did not report an estimate for fiscal year 2025. Specifically, SBA’s
                       Restaurant Revitalization Fund, which provided emergency assistance to eligible
                       restaurants, bars, and other qualifying businesses affected by COVID-19, did not
                       expend any funds in fiscal year 2025. Because this program did not expend
                       funds, SBA was not required to estimate improper payments for the Restaurant
                       Revitalization Fund in fiscal year 2025. Therefore, the decline in estimated
                       improper payments for this program from fiscal year 2024 to fiscal year 2025 is
                       100 percent.


Page 7                                                                                                                  GAO-26-108694 Improper Payments
How many programs       According to the PaymentAccuracy.gov data that we analyzed, eight programs
reported substantial    reported substantial increases in estimated improper payments for fiscal year
increases in improper   2025 (see table 4). For four of these programs, the increases occurred because
payments?               the agencies did not report improper payments estimates for the prior fiscal year.
                        For example, SBA reported improper payments estimates for the Shuttered
                        Venue Operators Grant program for the first time in fiscal year 2025. In addition,
                        variability arising from the improper payment estimation process could potentially
                        explain a portion of the reported increases.

                        Table 4: Federal Programs with Substantial Increases in Estimated Improper Payments from Fiscal Year
                        2024 to Fiscal Year 2025

                                                    Estimated
                                                                                     Increase in
                                                    fiscal year      Increase in
                                                                                        rate from
                                                            2025   amount from                    Reason for increase
                                                                                      fiscal year
                         Agency/program               improper        fiscal year                 from agency financial
                                                                                        2024 (net
                                                     payments      2024 (dollars                  report
                                                                                     percentage
                                                    (dollars in       in billions)
                                                                                          points)
                                                       billions)
                         Small Business                  $10.1             $10.1            68.9 Fiscal year 2025 was first
                         Administration –                                                        year reporting.
                         Shuttered Venue
                         Operators Grant
                         Program
                         Department of                     37.4               6.3            1.0 Increased errors in
                         Health and Human                                                        eligibility
                         Services – Medicaid                                                     redeterminations and
                                                                                                 provider screening while
                                                                                                 phasing out COVID-19
                                                                                                 enrollment flexibilities.
                         Department of the                 21.1               5.2            5.4 No reason provided.
                         Treasury – Earned
                         Income Tax Credit
                         Department of                      1.4               1.3            0.6 No reason provided.
                         Defense –
                         Commercial Pay –
                         Mechanization of
                         Contract
                         Administration
                         Services
                         Department of                      4.3               4.3           26.1 Revised estimation
                         Housing and Urban                                                       methodology.
                         Development –
                         Rental Housing
                         Assistance Program
                         – Project Based
                         Rental Assistance –
                         Project Based
                         Section 8 – Rental
                         Housing Assistance
                         Program - Section
                         236 – Housing for
                         Persons with
                         Disability – Section
                         811




Page 8                                                                                         GAO-26-108694 Improper Payments
                                                             Estimated
                                                                                                        Increase in
                                                             fiscal year          Increase in
                                                                                                           rate from
                                                                     2025       amount from                          Reason for increase
                                                                                                         fiscal year
                         Agency/program                        improper            fiscal year                       from agency financial
                                                                                                           2024 (net
                                                              payments          2024 (dollars                        report
                                                                                                        percentage
                                                             (dollars in           in billions)
                                                                                                             points)
                                                                billions)
                         Department of                          1.5                            1.5                   4.4 Did not report estimates
                         Housing and Urban                                                                               in fiscal year 2024.a
                         Development –
                         Public and Indian
                         Housing – Rental
                         Housing Assistance
                         Program – Tenant-
                         Based Rental
                         Assistance Section 8
                         – Housing Certificate
                         Fund and Tenant-
                         Based Rental
                         Assistance
                         Department of                                 2.3                     2.3                   1.5 Did not report estimates
                         Veterans Affairs –                                                                              in fiscal year 2024.a
                         Compensation
                         Social Security                               2.3                     2.3                   1.6 Fiscal year 2025 was first
                         Administration –                                                                                year reporting as a
                         Disability Insurance                                                                            separate program.
                                                                                                                         Previously, the Social
                                                                                                                         Security Administration
                                                                                                                         combined Disability
                                                                                                                         Insurance with the Old-
                                                                                                                         Age and Survivors
                                                                                                                         Insurance program.
                        Source: GAO analysis of Office of Management and Budget PaymentAccuracy.gov data and agency financial reports. | GAO-26-108694

                        Note: Improper payment estimates and rates displayed in the table include unknown payments. Executive
                        branch agency estimates of improper payments treat as improper any payments whose propriety cannot be
                        determined due to lacking or insufficient documentation. The estimated improper payment rate is the estimated
                        amount in improper payments divided by the amount in program outlays for a given program in a given fiscal
                        year. Programs that reported estimated improper payments in fiscal year 2025 but not in fiscal year 2024 were
                        counted as an increase is estimated improper payments.
                        a
                         These programs did not report estimates in fiscal year 2024 but did report estimates in years prior to that as
                        well as in fiscal year 2025.



What are the            PIIA requires executive branch agencies to, among other things, (1) review all
requirements for        programs and activities and identify those that may be susceptible to significant
agencies’ management    improper payments (commonly referred to as conducting a risk assessment), (2)
of improper payments?   publish improper payment estimates for those programs and activities, (3)
                        implement corrective actions to reduce improper payments and set reduction
                        targets, and (4) report on the results of addressing the foregoing requirements. 13
                        In addition, PIIA requires the IG at each executive branch agency to issue an
                        annual report on the agency’s compliance with applicable PIIA criteria. 14

                        OMB plays a key role in developing guidance for executive branch agencies on
                        estimating and reporting on improper payments. OMB Circular No. A-123,
                        appendix C, includes guidance for IGs on how to determine agency compliance
                        with applicable PIIA criteria. 15 It also includes guidance for executive branch
                        agencies on the corrective actions that PIIA requires them to take if IGs find them
                        noncompliant.

                        As shown in figure 4, PIIA and OMB Memorandum M-21-19 (OMB M-21-19)
                        include criteria for determining compliance.


Page 9                                                                                                                  GAO-26-108694 Improper Payments
          Figure 4: Executive Branch Agency Compliance Criteria Under the Payment Integrity Information Act of
          2019 and Federal Guidance




          a
           OMB Memorandum M-21-19 provided guidance for PIIA. The updated guidance was first effective for fiscal
          year 2021.

          b
           All agencies are required to report payment integrity information with their annual financial report published on
          their website. Separately, if agencies determine a program to be susceptible to risk of improper payments, they
          must also publish an improper payment estimate for that program.



          Specifically, OMB instructs IGs to report on whether their agencies

          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 in the last 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),

          3. publish improper payment and unknown payment estimates for programs
          susceptible to significant improper payments and unknown payments in the
          accompanying materials to the annual financial statements,


Page 10                                                                                     GAO-26-108694 Improper Payments
                            4. publish corrective action plans for each program for which an estimate above
                            the statutory threshold was published in the accompanying materials to the
                            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 the annual financial statements,

                            5b. demonstrate improvements to payment integrity or reach a tolerable improper
                            payment and unknown payment rate,

                            5c. develop a plan to meet their improper payment and unknown payment
                            reduction targets, 16 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.

                            If an IG concludes that any of the agency’s programs or activities fail to meet any
                            of the applicable criteria, the agency is considered noncompliant under PIIA for
                            that fiscal year and is required to take additional actions for each year it is
                            noncompliant, such as providing OMB with a description of the actions that the
                            agency will take to come into compliance.


                            According to their IGs, in fiscal year 2024, the most recent year for which
How many CFO Act
                            information was available, 12 of the 24 CFO Act agencies fully complied with
agencies complied with      PIIA criteria and related OMB requirements. 17 This was a decrease from fiscal
applicable legal criteria   year 2023, when IGs reported that 13 of these agencies were compliant. The
and guidance for            decrease in compliance is attributable to two previously compliant agencies
management of               becoming noncompliant (the U.S. Agency for International Development and the
improper payments in        Environmental Protection Agency) and one previously noncompliant agency
fiscal year 2024?           becoming compliant (the Department of Homeland Security).

                            Figure 5 provides a 13-year comparison of agency compliance rates, as reported
                            by agencies’ IGs. 18




Page 11                                                                                GAO-26-108694 Improper Payments
Figure 5: CFO Act Agencies’ Compliance with PIIA or IPERA Criteria for Fiscal Years 2012 Through 2024, as Reported by Their Inspectors
General




                                    Note: The National Science Foundation’s (NSF) Office of Inspector General did not report on NSF’s compliance
                                    for fiscal year 2013.


                                    While the IGs for 12 of the CFO Act agencies determined that their respective
                                    agencies were compliant with PIIA criteria in fiscal year 2024, the IGs for two of
                                    these agencies issued recommendations regarding improper payments. The
                                    recommendations were related to the reliability of estimates and identifying root
                                    causes of improper payments, among other findings.

                                    As shown in figure 6, each of the 10 criteria had at least one noncompliant
                                    agency in fiscal year 2024, and a few criteria had relatively high noncompliance
                                    rates. For example, IGs found that nine of the 14 agencies for which criterion 6
                                    was applicable had at least one program reporting an improper payment estimate
                                    of over 10 percent.




Page 12                                                                                                          GAO-26-108694 Improper Payments
          Figure 6: CFO Act Agencies’ Compliance with PIIA and OMB Criteria for Fiscal Year 2024, as Reported
          by Their Inspectors General




          Note: The U.S. Agency for International Development’s (USAID) IG’s office stated that it was unable to report
          on USAID’s compliance with PIIA and OMB criteria for fiscal year 2024 because USAID did not have staff
          available to respond to its IG's information requests. In addition, the Department of Health and Human Service
          (HHS) IG reported that HHS was unable to publish corrective action plans and reduction targets for the
          Temporary Assistance for Needy Families program, which did not publish an estimate. Because of this, HHS IG
          did not report on whether this program was compliant with criteria 4 and 5a above.


          Twelve agencies were noncompliant with at least one criterion in fiscal year
          2024, as reported by their IGs (see fig. 7).




Page 13                                                                                 GAO-26-108694 Improper Payments
Figure 7: Chief Financial Officers Act of 1990 Agencies Noncompliant with Payment Integrity Information Act of 2019 and Office of
Management and Budget Criteria for Fiscal Year 2024, as Reported by Their Inspectors General




                                     a
                                      “Develop reduction targets” criterion contains three requirements: (a) publish reduction targets, (b) demonstrate
                                     improvements, and (c) develop improper payments reduction plan. For this figure, if an agency was
                                     noncompliant with any of these three requirements, we considered it noncompliant with this criterion.


What recommendations For fiscal year 2024, 13 of the 24 CFO Act agencies received a total of 61
did CFO Act agency IGs recommendations from their IGs in their PIIA compliance reports. Twenty of
make to improve        these recommendations were repeated from prior years, while 41 were new
compliance with        based on fiscal year 2024 data. Figure 8 shows the number of recommendations
improper payment laws each agency received. For example, the Department of Defense received eight
and guidance?          total recommendations in its PIIA compliance report, with four of those being new
                                     recommendations for fiscal year 2024.




Page 14                                                                                                               GAO-26-108694 Improper Payments
          Figure 8: Number of IG Recommendations Agencies Received in Their Payment Integrity Information
          Act of 2019 (PIIA) Compliance Reports for Fiscal Year (FY) 2024




          Note: Two agencies that were compliant with PIIA and Office of Management and Budget requirements, the
          Departments of Energy and Education, received recommendations from their respective IGs related to
          reporting, estimation methodology, and root causes. The U.S. Agency for International Development, which
          announced it had ceased implementing foreign assistance in July 2025, was deemed noncompliant but did not
          receive any IG recommendations in its PIIA compliance report.


          Table 5 shows the number of recommendations by category from the compliance
          reports of the 24 CFO Act agencies. The IG reports with open recommendations
          can be found in appendix I.

          Table 5: Number of Open Recommendations by Category Reported by Inspectors General (IG) to CFO
          Act Agencies in their PIIA Compliance Reports for Fiscal Year 2024
           Category                    Number of open Example of recommendation
                                     recommendations
           Root Causes                                 24
                                                            The Department of Health and Human Services
                                                            IG recommended that agency officials
                                                            responsible for the Head Start program (1)
                                                            focus on the root causes of improper payments
                                                            and (2) evaluate critical and feasible actions to
                                                            help recipients comply with program
                                                            requirements.
           Methodologies                               14
                                                            The Environmental Protection Agency IG
                                                            recommended that agency officials develop
                                                            and document internal processes to ensure
                                                            that the agency’s sampling methodology
                                                            produces valid improper payments estimates.
           Reporting                                   13
                                                            The Department of Labor IG recommended
                                                            that agency officials update review procedures
                                                            to (1) ensure accurate responses to Office of
                                                            Management and Budget (OMB) payment
                                                            integrity data call prompts; compliance with
                                                            PIIA; and that information is complete,
                                                            accurate, and consistent before the final
                                                            submission of the OMB payment integrity data
                                                            call and (2) further refine reviews of published
                                                            information on PaymentAccuracy.gov.



Page 15                                                                              GAO-26-108694 Improper Payments
                     Estimates                                                 7
                                                                                    The Department of Housing and Urban
                                                                                    Development IG recommended that agency
                                                                                    officials develop and implement a detailed plan
                                                                                    for testing and reporting estimated improper
                                                                                    payments for the Office of Public and Indian
                                                                                    Housing Tenant-Based Rental Assistance and
                                                                                    Project-Based Rental Assistance programs.
                     Risk Assessments                                          7
                                                                                    The Department of Defense IG recommended
                                                                                    that the Assistant Secretary of the Navy
                                                                                    (Financial Management and Comptroller)
                                                                                    reevaluate the agency’s Travel Pay Navy–
                                                                                    Defense Travel System program and report the
                                                                                    program’s estimates in the appropriate PIIA
                                                                                    reporting phase.
                     Reducing Improper                                         6
                     Payments                                                       The Department of Veterans Affairs IG
                                                                                    recommended that the Under Secretaries for
                                                                                    Benefits and Health reduce improper and
                                                                                    unknown payments to below 10 percent for the
                                                                                    pension program and Purchased Long-Term
                                                                                    Services and Supports program, respectively.
                     Recovery Audits                                           3
                                                                                    The Office of Personnel Management IG
                                                                                    recommended that Retirement Services
                                                                                    officials develop internal controls to monitor all
                                                                                    activity involving replacement payments, retain
                                                                                    all documentation, and ensure collection of all
                                                                                    overpayments.

                   Legend: CFO Act = Chief Financial Officers Act of 1990; PIIA = Payment Integrity Information Act of 2019.
                   Source: GAO analysis of IG compliance reports. | GAO-26-108694

                   Note: Some recommendations were counted in more than one category. For example, one open
                   recommendation may be counted in the total number of open recommendations for both the “Reporting” and
                   “Methodologies” categories.



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


How GAO Did This   To conduct this work, we compiled improper payment estimates from OMB’s
Study              PaymentAccuracy.gov website. We summarized and compared the improper
                   payment estimates to identify any substantial changes from fiscal year 2024 to
                   fiscal year 2025. A substantial change in improper payments is one in which the
                   estimated improper payment amount changed by at least $1 billion, and the
                   improper payment rate changed more than the reported margin of error for the
                   agency estimate of improper payments. We reviewed the agencies’ respective
                   agency financial reports or performance and accountability reports and the
                   PaymentAccuracy.gov website to determine what factors agencies identified as
                   the causes for these changes. In addition, we reviewed the PIIA criteria
                   compliance reports each agency’s IG issued for fiscal year 2024, the most recent
                   available year.

                   We conducted this performance audit from August 2025 to April 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


Page 16                                                                                                    GAO-26-108694 Improper Payments
                          obtained provides a reasonable basis for our findings and conclusions based on
                          our audit objectives.


List of Addressees        The Honorable Rand Paul, M.D.
                          Chairman
                          The Honorable Gary C. Peters
                          Ranking Member
                          Committee on Homeland Security and Governmental Affairs
                          United States Senate

                          The Honorable James Comer
                          Chairman
                          The Honorable Robert Garcia
                          Ranking Member
                          Committee on Oversight and Government Reform
                          House of Representatives

                          We are sending copies of this report to the appropriate congressional committees
                          and the Director of the Office of Management and Budget. In addition, the report
                          is available at no charge on the GAO website at https://www.gao.gov.
.




GAO Contact               For more information, contact: Kristen Kociolek, Managing Director, Financial
Information               Management and Assurance, KociolekK@gao.gov.

                          Media Relations: Sarah Kaczmarek, Managing Director, Media@gao.gov.

                          Congressional Relations: David A. Powner, Acting Managing Director,
                          CongRel@gao.gov.

                          Staff Acknowledgments: Matt Valenta (Assistant Director), Laura Pacheco
                          (Analyst in Charge), Seth Brewington, Marcia Carlsen, Victoria Cline, Giovanna
                          Cruz, Joshua Edelman, Megan Jones, Ian Kendrick, Sarah Lisk, and Diana Vu.

                          Connect with GAO on Facebook, X, LinkedIn, Instagram, and YouTube.
                          Subscribe to our Email Updates. Listen to our Podcasts.

                          Visit GAO on the web at https://www.gao.gov.

                          This is a work of the U.S. government but may include copyrighted material. For
                          details, see https://www.gao.gov/copyright.


Appendix I: Fiscal Year   Thirteen of the 24 Chief Financial Officers (CFO) Act agencies had open
2024 PIIA Compliance      recommendations in their fiscal year 2024 Payment Integrity Information Act
Reports with Open         (PIIA) compliance reports.
Recommendations
                          1. Department of Agriculture: Department of Agriculture, Office of Inspector
                             General, USDA’s Compliance with Improper Payment Requirements for
                             Fiscal Year 2024, 50024-0016-11 (May 2025).
                          2. Department of Defense: Department of Defense, Office of Inspector
                             General, Audit of the Department of Defense’s FY 2024 Compliance with
                             Payment Integrity Information Act Requirements, DODIG-2025-105 (May 27,
                             2025).
                          3. Department of Education: Department of Education, Office of Inspector
                             General, U.S. Department of Education’s Compliance with Payment Integrity
Page 17                                                                            GAO-26-108694 Improper Payments
               Information Reporting Requirements for Fiscal Year 2024, ED-
               OIG/A25DC0225 (May 27, 2025).
           4. Department of Energy: Department of Energy, Office of Inspector General,
               The Department of Energy’s Payment Integrity Reporting in the Fiscal Year
               2024 Agency Financial Report, DOE-OIG-25-20 (May 27, 2025).
           5. Department of Health and Human Services: Department of Health and
               Human Services, Office of Inspector General, Department of Health and
               Human Services Met Many Requirements, but Did Not Fully Comply With the
               Payment Integrity Information Act of 2019 and Applicable Improper Payment
               Guidance for Fiscal Year 2024, OAS-25-17-042 (May 2025).
           6. Department of Housing and Urban Development: Department of Housing
               and Urban Development, Office of Inspector General, HUD Did Not Comply
               with the Payment Integrity Information Act of 2019, 2025-FO-0006 (May 13,
               2025).
           7. Department of Labor: Department of Labor, Office of Inspector General,
               The U.S. Department of Labor Did Not Meet the Requirements for
               Compliance with the Payment Integrity Information Act for FY 2024, 22-25-
               007-13-001 (May 27, 2025).
           8. Department of the Treasury: Department of the Treasury, Office of
               Inspector General, Financial Management: Audit of Treasury’s Compliance
               with the PIIA Requirements for Fiscal Year 2024, OIG-25-027 (May 27,
               2025).
           9. Department of Veterans Affairs: Department of Veterans Affairs, Office of
               Inspector General, Review of VA’s Compliance with the Payment Integrity
               Information Act for Fiscal Year 2024, 24-03777-113 (May 21, 2025).
           10. Environmental Protection Agency: Environmental Protection Agency,
               Office of Inspector General, Audit of the EPA’s Fiscal Year 2024 Compliance
               with the Payment Integrity Information Act of 2019, 25-P-0033 (May 27,
               2025).
           11. Office of Personnel Management: Office of Personnel Management, Office
               of Inspector General, Audit of the U.S. Office of Personnel Management’s
               Compliance with the Payment Integrity Information Act of 2019 for Fiscal
               Year 2024, 2025-IAG-003 (May 23, 2025).
           12. Small Business Administration: Small Business Administration, Office of
               Inspector General, Independent Auditors’ Report on SBA’s Fiscal Year 2024
               Compliance with the Payment Integrity Information Act of 2019, 25-15 (May
               15, 2025).
           13. Social Security Administration: Social Security Administration, Office of
               Inspector General, The Social Security Administration’s Compliance with the
               Payment Integrity Information Act of 2019 in Fiscal Year 2024, 152415 (May
               2025).


Endnotes
           1An improper payment is defined by law as any payment that should not have been made or that

           was made in an incorrect amount (including overpayments and underpayments) under statutory,
           contractual, administrative, or other legally applicable requirements. It includes any payment to an
           ineligible recipient, any payment for an ineligible good or service, any duplicate payment, any
           payment for a good or service not received (except for such payments where authorized by law),
           and any payment that does not account for credit for applicable discounts. 31 U.S.C. § 3351(4).
           When an executive branch 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).
           2GAO, Improper Payments: Information on Agencies’ Fiscal Year 2024 Estimates, GAO-25-107753

           (Washington, D.C.: Mar. 11, 2025).
           3The Medicare improper payment estimate is composed of the Medicare Fee-For-Service,

           Medicare Advantage (Part C), and Medicare Prescription Drug (Part D) programs.

Page 18                                                                            GAO-26-108694 Improper Payments
          4Medicaid is a federal-state program that provides health coverage assistance for certain

          individuals who qualify due to low income or other criteria. HHS annually computes Medicaid
          improper payments as a weighted average of states’ improper payment estimates for three
          component parts: fee-for-service, managed care, and beneficiary eligibility determinations.
          5OMB’s PaymentAccuracy.gov data call for fiscal year 2025 included guidance for agencies to use

          when reporting the types of their estimated improper payments. This guidance was in addition to
          that provided in OMB M-21-19 on reporting estimates for programs or activities that are identified
          as susceptible to improper payments. According to OMB M-21-19, “overpayments” are payments
          exceeding the amount due, and are payments that, in theory, should or could be recovered.
          “Underpayments” are those in which recipients did not receive the funds to which they were
          entitled. “Unknown payments” are those that a program cannot determine were either proper or
          improper. “Technically improper payments” are those in which recipients received funds they were
          entitled to, but the payment failed to follow all applicable statutes or regulations.

          6GAO, COVID-19: Current and Future Federal Preparedness Requires Fixes to Improve Health

          Data and Address Improper Payments, GAO-22-105397 (Washington, D.C.: Apr. 27, 2022).

          7GAO, 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).
          8Congress partially addressed this matter by extending the sunset date of the Pandemic Response

          Accountability Committee (PRAC), which includes the PRAC’s data analytics platform, to 2034 and
          expanding its jurisdiction. However, the PRAC and its analytics center are neither permanent nor
          government-wide. Pub. L. No. 119-21, § 90102, 139 Stat. 72, 363 (2025).
          9 Pub. L. No. 119-77, 140 Stat. 745.


          10The $5 billion threshold was selected because the programs that met this threshold combine to

          cover over 75 percent of all government-wide reported improper payment estimates.
          11As described later in this report, agencies must report an improper payment rate of less than 10

          percent for each program for which they publish an estimate if they are to be considered in
          “compliance” under PIIA. 31 U.S.C. § 3351(2)(F).
          12PaymentAccuracy.gov is an official U.S. government website managed by OMB. It contains,

          among other things, information about current and historical rates (i.e., agency-reported amounts
          as a percentage of outlays) and amounts of improper payments, root causes of monetary loss and
          improper payments, monetary-loss recovery efforts, and high-priority program scorecards. In
          addition, for purposes of this report, a program that has experienced a substantial decline or
          increase in improper payments is one in which the estimated improper payments amount
          decreased or increased by at least $1 billion, and the improper payment rate decreased or
          increased more than the reported margin of error for the agency estimate of improper payments.
          This latter condition reduces but does not eliminate the possibility that the observed declines or
          increases are due to variability arising from the improper payment estimation process.
          1331 U.S.C. § 3352.


          1431 U.S.C. § 3353(a).


          15OMB M-21-19, issued on March 5, 2021, became effective starting in fiscal year 2021.


          16OMB M-21-19’s criteria 5a, 5b, and 5c relate to 31 U.S.C. § 3351(2)(E), which states that

          compliance means that the executive branch agency “publishes improper payment reductions
          targets prepared under [31 U.S.C. § 3352(d)] that the executive branch agency may have in the
          accompanying materials to the annual financial statement for each program or activity assessed to
          be at risk, and has demonstrated improvements and developed a plan to meet the reduction
          targets.”

          17The CFO Act, Pub. L. No. 101-576, 104 Stat. 2838 (Nov. 15, 1990) (codified as amended in

          scattered sections of 31 U.S.C.), among other things, established chief financial officers to oversee
          financial management activities at 23 major executive branch departments and agencies. The list
          now includes 24 entities, which are often referred to collectively as CFO Act agencies, and is
          codified as amended at 31 U.S.C. § 901(b). We focused on the 24 CFO Act agencies because the
          improper payment estimates for those agencies accounted for over 99 percent of the federal
          government’s reported estimated improper payments for fiscal year 2025. However, PIIA applies to
          both CFO Act and non-CFO Act executive branch agencies. According to PaymentAccuracy.gov,
Page 19                                                                           GAO-26-108694 Improper Payments
          48 out of the 63 executive branch agencies reporting in fiscal year 2024 were determined by their
          respective IGs to be compliant with PIIA criteria. Per OMB M-21-19, the compliance reports are due
          within 180 days following the publishing of agencies’ annual financial statements and
          accompanying materials, which typically occurs in mid-November. The most recent IG compliance
          reports available were issued in 2025 for agencies’ fiscal year 2024 compliance with PIIA criteria.

          18This comparison includes Improper Payments Elimination and Recovery Act of 2010 (IPERA)

          (Pub. L. No. 111-204, 124 Stat. 2224) requirements for fiscal years prior to 2020 and PIIA
          requirements for fiscal year 2020 onward. IPERA established a requirement for agency IGs to
          report annually on their respective agencies’ compliance. In March 2020, Congress and the
          President enacted PIIA, which repealed IPERA and the other improper payments reporting-related
          statutes and enacted substantially similar provisions, including those related to IGs’ reporting on
          agency compliance with criteria and the compliance criteria themselves. Pub. L. No. 116-117, 134
          Stat. 113 (codified at 31 U.S.C. §§ 3351-58).




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