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.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“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.Full text
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).
Page 20 GAO-26-108694 Improper Payments
File and source
- File
- gao-26-108694.pdf
- Size
- 1,023,653 bytes
- SHA-256
- 978d63b6335ac8ae027d01aea5b6d3df3756f844b3eacbc1e2f641c56a4b38c9
- Our copy
- gao-26-108694.pdf
- Original
- www.gao.gov