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Report - Prac Sar 2022 09 Prac Semiannual Report To Congress September 2022

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The Pandemic Response Accountability Committee (PRAC) Semiannual Report to Congress for April 1, 2022 - September 30, 2022. In the Message from the Chair, the PRAC states that this is its fifth Semiannual Report to Congress and that during the reporting period 26 OIGs issued 114 reports related to pandemic relief oversight, with a total of 343 recommendations and $31.2 billion in monetary findings. It states that the extension of the statute of limitations for two pandemic-related small business loan programs gives investigators 10 years rather than 5 years. It also states that, as of September 14, 2022, the DOJ has reported criminal charges against more than 1,500 defendants with alleged losses exceeding $1.1 billion.

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Prac Sar 2022 09 Prac Semiannual Report To Congress September 2022

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“Report - Prac Sar 2022 09 Prac Semiannual Report To Congress September 2022.” Original at www.pandemicoversight.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/prac-sar-2022-09-prac-semiannual-report-to-congress-september-2022/, SHA-256 1b4761be51b6386d936d0ae2be3617d14269babf5997ef4a8e39f4123528e59e.

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PANDEMIC RESPONSE ACCOUNTABILITY COMMITTEE
PANDEMIC RESPONSE ACCOUNTABILITY COMMITTEE
Semiannual Report to Congress
Semiannual Report to Congress
APRIL 1, 2022 - SEPTEMBER 30, 2022

APRIL 1, 2022 - SEPTEMBER 30, 2022
Message from the Chair
I am pleased to present the Pandemic Response
Accountability Committee’s (PRAC) fifth Semiannual                     During the reporting period,
Report to Congress, describing our work between                        26 OIGs issued 114 reports
April 1, 2022, and September 30, 2022. The                             related to pandemic relief
PRAC has now been operational for two and a half                       oversight with a total of 343
years, and this report shows the impact of our                         recommendations and
innovative approaches to overseeing historical levels                  $31.2 billion in monetary
of emergency government spending and fighting
                                                                       findings during the past
pandemic relief fraud.
                                                                       six months.
But fighting fraud can take time. The recent
extension of the statute of limitations for two
pandemic-related small business loan programs             Force now numbers 50 criminal investigators from
gives investigators 10 years rather than 5 years to       15 federal agencies, helping to surge resources
pursue fraud. And we’re doing so by using advanced        where they are needed most.
data analytics to drive investigations with our federal
law enforcement partners.                                 We collaborate and coordinate with our federal
                                                          law enforcement partners to support a whole-of-
During the reporting period, our Pandemic Analytics       government response to fighting pandemic fraud.
Center of Excellence (PACE) completed several             For example, the PRAC and 30 partner agencies are
projects that support the work of our partner             part of the Department of Justice’s COVID-19 Fraud
Inspectors Generals (IGs). For example, PACE data         Enforcement Task Force, which has made significant
scientists developed a fraud risk score for 40 million    progress prosecuting fraudsters who stole PPP or
Paycheck Protection Program (PPP) and Economic            EIDL loans.
Injury Disaster Loans (EIDL). This helps the Small
Business Administration (SBA) Office of Inspector         In August 2022, the U.S. Secret Service worked with
General more effectively target its investigations.       the SBA OIG to return $286 million in fraudulently
                                                          obtained EIDLs to the SBA. These funds were
Our Fraud Task Force worked with the Department           initially claimed through fraudulently submitted
of Justice (DOJ), the National Credit Union               loan applications that used fake or stolen personal
Administration and other law enforcement partners         information. In September 2022, the Inspector
to identify nearly $8.75 million in potentially           General for the Department of Labor (DOL)
fraudulent pandemic relief funds held by credit           announced that his office has charged more than
unions that could be recovered. The Fraud Task            1,000 individuals with Unemployment Insurance (UI)




                                                                                                          ii
fraud since the beginning of the pandemic. These         We also added state-level expertise to our team to
charges have resulted in more than 400 criminal          further advance our strategic goal of collaborating
convictions to date.                                     across all levels of the oversight community.
                                                         We brought on Elaine Howle as Special Advisor
As of September 14, 2022, the DOJ has reported           for State, Local, Tribal, and Territorial Oversight.
criminal charges against more than 1,500                 A nationally recognized expert and the former
defendants with alleged losses exceeding $1.1            California State Auditor, Ms. Howle brings nearly
billion; the seizure of over $1.2 billion in relief      40 years of professional auditing and leadership
funds; and civil investigations into more than 1,800     experience to the PRAC. In a new initiative—the State
individuals and entities for alleged misconduct in       Auditor-in-Residence program—we welcomed two
connection with pandemic relief loans totaling more      auditors from the Tennessee Comptroller’s Office,
than $6 billion. The PRAC and its partner OIGs are       adding more than 30 years’ worth of state and local
involved in many of these cases.                         oversight experience to our team.

We continue to focus on our education and outreach       The PRAC and its partners have the tools, the
goals by adding interactive features to our website,     talent, and the teamwork to effectively oversee
PandemicOversight.gov, to promote transparency           $5 trillion in pandemic relief funds and fight fraud,
over pandemic relief spending. We launched new           waste, and abuse. Our approach to collaborative
agency funding profiles that enable the public to        oversight has been recognized as a successful
see the total amount of pandemic relief money            template to follow. For example, in April 2022, the
that nearly 40 federal agencies received and the         Office of Management and Budget (OMB) issued
specific programs funded. The website also includes      a memorandum directing agencies to oversee
relevant oversight work from federal OIGs, whose         infrastructure spending with the same collaborative
audits and investigations alert the public and           approach used for pandemic spending. This
policymakers to fraud, waste, and abuse involving        approach has led to stronger controls for small
pandemic funds. During the reporting period, 26          business loan programs and improved the sharing of
OIGs issued 114 reports related to pandemic relief       state unemployment insurance data to fight fraud.
oversight with a total of 343 recommendations and
$31.2 billion in monetary findings during the past       I hope you find this Semiannual Report encouraging
six months.                                              and insightful.

We issued new oversight work, including an update
to our foundational Lessons Learned in Oversight
of Pandemic Relief Funds and the first report by
our Identity Fraud Reduction and Redress Working
Group on how agencies can reduce identity fraud          The Honorable Michael E. Horowitz
in pandemic relief programs and help victims             Chair, PRAC
recover. We also issued a joint risk advisory with the   Inspector General, U.S. Department of Justice
Department of Housing and Urban Development
(HUD) OIG and SBA OIG on potential identity fraud
targeting elderly and minors. Together, these
products reflect coordinated, comprehensive
oversight and fraud prevention through leading-edge
data insights and analytic tools.




Pandemic Response Accountability Committee                                                                 iii
Contents
Message from the Chair                                                      ii

Highlights                                                                  1

Background                                                                  2

PRAC Accomplishments                                                        4
     Goal One–Promote Transparency                                          5
     Goal Two–Promote Coordinated, Comprehensive Oversight                  7
     Goal Three–Prevent and Detect Fraud, Waste,
     Abuse, and Mismanagement                                              12
     Goal Four–Ensure Effective and Efficient PRAC Operations              14

Holding Wrongdoers Accountable Through Investigations                      15

Key Insights Through Oversight Reports                                     25
     Key Insight 1: The Pandemic Created Program Monitoring Challenges and
     Increased Program Risks                                               25
     Key Insight 2: Risks with Self-Certification Extend Beyond Pandemic
     Unemployment Assistance, PPP, and EIDL                                27
     Key Insight 3: Failure to Implement or Effectively Modify Critical
     Internal Controls Created Risks in Pandemic Relief Programs           28
     Key Insight 4: Assessing Emergency Planning Procedures Used During
     the Pandemic Can Help Inform and Improve Future Emergency Responses 29
     Key Insight 5: Data Can Help Inform the Design of More
     Equitable Programs                                                    30
Appendix A: Acronyms                                                       31

Appendix B: Pandemic-Related Reports by Office of Inspector General        32

Appendix C: Hotline Data                                                   39




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Highlights




  Highlights        Background           Accomplishments   Accountability        Reports         Appendices


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Background
Established in March 2020 by the CARES Act,                  The PRAC is comprised of 21 IGs (see PRAC
the PRAC is a Committee of the Council of the                membership below). We are staffed by a full-time
Inspectors General on Integrity and Efficiency               Executive Director and 54 employees distributed
(CIGIE). CIGIE is an independent entity established          across three lines of business (Oversight &
within the executive branch by the Inspector General         Accountability, Outreach & Engagement, and
Act of 1978, as amended, whose membership                    Transparency) and four support functions (Chief
includes the 75 statutorily created federal IGs.             Information Officer, Chief Counsel, Chief Data
                                                             Officer, and Chief Management Officer).
The CARES Act identifies IGs from nine agencies
as members of the PRAC. The Chair can designate              The PRAC promotes transparency and provides
additional IGs to serve on the Committee from                Congress and the public with objective, reliable
any agency that receives pandemic funds or is                information about the $5 trillion in pandemic relief
involved in the federal government’s response to             dollars at PandemicOversight.gov. We also work
the COVID-19 pandemic. The IGs serving on the                with IGs to recommend program improvements,
Committee continue to perform their IG duties.               refer matters for criminal investigations, and identify
                                                             misspent funds for recovery.


PRAC Membership
Name                                         Department or Agency OIG
Michael E. Horowitz, Chair                   Department of Justice
Paul K. Martin, Vice Chair                   National Aeronautics and Space Administration
Phyllis K. Fong                              Department of Agriculture
Sean W. O’Donnell                            Department of Defense
Sandra D. Bruce                              Department of Education
Christi A. Grimm                             Department of Health and Human Services
Joseph Cuffari                               Department of Homeland Security
Rae Oliver Davis                             Department of Housing and Urban Development
Mark Lee Greenblatt                          Department of the Interior
Larry D. Turner                              Department of Labor
Eric J. Soskin                               Department of Transportation
Richard Delmar                               Department of the Treasury
Michael J. Missal                            Department of Veterans Affairs
Jay N. Lerner                                Federal Deposit Insurance Corporation
Mark Bialek                                  Federal Reserve Board / Consumer Financial Protection Bureau
Allison C. Lerner                            National Science Foundation
Robert P. Storch                             National Security Agency
Hannibal “Mike” Ware                         Small Business Administration
Brian D. Miller                              Special Inspector General for Pandemic Recovery
J. Russell George                            Treasury Inspector General for Tax Administration
Tammy Whitcomb Hull                          U.S. Postal Service


  Highlights        Background           Accomplishments          Accountability        Reports         Appendices


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The PRAC released its Strategic Plan for 2020 through 2025 in July 2020. The plan identifies four goals
to carry out the PRAC’s mission and vision (see Figure 1). These goals are not mutually exclusive—audits,
investigations, reviews, and other activities may meet more than one goal.


               MISSION
               To serve the American public by promoting transparency and the coordinated oversight
               of the Federal Government’s coronavirus response to prevent and detect fraud, waste,
               abuse, and mismanagement and mitigate major risks that cross program and agency
               boundaries.


               VISION
               Sound stewardship of taxpayer funds and an effective and efficient coronavirus
               response across the Federal Government, the oversight of which will be data-driven,
               risk-focused, and technology-enabled.


               GOALS
                                                Promote Transparency




               Ensure Effective
                 and Efficient
               PRAC Operations


                                                                                      Promote Coordinated,
                                                                                         Comprehensive
                                                                                           Oversight




                                           Prevent and Detect Fraud, Waste,
                                             Abuse, and Mismanagement

               Figure 1. PRAC Mission, Vision, and Goals




  Highlights          Background          Accomplishments          Accountability        Reports         Appendices


Pandemic Response Accountability Committee                                                                         3
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PRAC Accomplishments
The PRAC was established to serve the American public by promoting transparency and facilitating
coordinated oversight of the federal government’s COVID-19 pandemic response and associated spending.
Our goals are to detect fraud, waste, abuse, and mismanagement and to identify and mitigate major risks
that cross program and agency boundaries. We aim to serve as the eyes and ears of the American public,
monitoring the government’s pandemic response spending and reporting accessible, timely, accurate, and
comprehensive data that can be translated into actionable insights. The following figure depicts the goals
set out in our Strategic Plan for 2020 through 2025 and key accomplishments we have achieved during this
reporting period, as aligned with the PRAC’s mission and vision.



       Testimony before            Launched State                                       Onboarded 18
       the House Select               Auditor-in-                                      new employees—
                                  Residence Program        Statute of limitations       a 22% increase
     Subcommittee on the                                       extended for
      Coronavirus Crisis                                                                  in new hires
                                                            PPP and EIDL fraud




                                                                     Joint risk advisory memo with HUD
     Coverage in New York                                              and SBA OIGs on identity fraud
   Times, Washington Post,               President Biden cites          targeting elderly and minors
     local news affilitates            PRAC oversight as model
           and more                     for infrastructure funds



Figure 2. PRAC Goals




  Highlights        Background           Accomplishments         Accountability          Reports         Appendices


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Goal One–Promote Transparency
Provide the Public with Timely Data and Information on
Covered Funds and the Coronavirus Response
Transparency is core to the PRAC mission laid out by       programs, stating that, “because of the siloed
Congress in the CARES Act. We continue to explore          nature of government, each benefits program has
ways to engage the public and empower them to              its own redress process, leaving victims lost in a
act as citizen watchdogs. We do this through our           bureaucratic maze that they have to figure out on
oversight reports, public events, Congressional            their own.”
testimony, and our website.

During this reporting period, we updated our
Lessons Learned report with five additional lessons.         On June 8, 2022, we issued an
We originally published a version of this report in          update to our Lessons Learned in
September 2021. This was our first update with               Oversight of Pandemic Relief Funds,
lessons from programs in the American Rescue                 adding five new insights.
Plan Act.

Meanwhile, our Identity Fraud Reduction and                             1. Allocate funding based on need
Redress Working Group released its first report,
providing insights agencies can use to reduce
                                                                        2. New programs need more outreach
identity fraud in pandemic relief programs and help
                                                                           to increase public awareness and
victims recover. The working group found that while                        participation
the government has issued over 241 indictments
and 110 convictions related to identity fraud in
pandemic relief programs, the onus is on victims to                     3. Watchdogs need access to data to
reclaim their stolen identities.                                           find fraud

Identity fraud victims might even have to start two
or more separate processes and navigate multiple                        4. Collaboration is critical to oversee
different benefit systems to regain needed benefits.                       pandemic relief programs
This legwork adds to what the White House has
called a “time tax,” a phenomenon we further
explored in a virtual panel discussion we co-hosted                     5. Better reporting is needed to track
with the National Academy of Public Administration                         pandemic relief spending
on June 15, 2022.

In his June testimony before the House Select
Subcommittee on the Coronavirus Crisis, PRAC
Chair Michael E. Horowitz further emphasized the
need to curtail identity fraud across government


  Highlights        Background           Accomplishments       Accountability        Reports          Appendices


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“[Our] priority is to help identify gaps in victim redress, figure out how to
address them, and help victims move forward—and regain their rightful
benefits.”
                                                 Read more from PRAC Chair Michal Horowitz’s June testimony before the
                                                 House Select Subcommittee on the Coronavirus Crisis



In addition to our reports and public-facing events,        publications to large national newspapers, as well
we remain committed to making publicly available            as radio and podcasts.
data accessible on our website. PandemicOversight.
gov gives the power of insight to the people, allowing      As the public’s interest in pandemic relief spending
them to search through trillions of dollars’ worth of       continues to grow—exemplified in front page stories
relief funding directly from their devices.                 from the New York Times, in the Washington
                                                            Post’s Covid Money Trail series, on National Public
During the reporting period, we launched new                Radio, and Fox Business—this engagement is more
agency funding profiles that show the total amount          important than ever. It speaks to our credibility as
of pandemic relief money that nearly 40 federal             an authoritative source of government information
agencies received, and the specific programs                and analysis. It also supports the impact of our
funded. These profiles also include relevant                strategic goal to promote transparency through
oversight work from their respective OIGs. In               producing and sharing timely updates that answer
addition, we added 13 new data stories, 127 data            questions the public and policymakers are asking.
visualizations, a simpler way to search PPP data, a
live spending tracker, and new dashboards featuring
spending data from the State and Local Fiscal
Recovery Fund, Shuttered Venue Operators Grants,
and the Restaurant Revitalization Fund. We provided
a public demo of our new dashboards at another
virtual roundtable we hosted on June 29 of this year,
on impactful ways local governments are using data
dashboards and websites to shed light on pandemic
relief spending in their own communities.

During this reporting period, 34 reports from state
and local oversight agencies became available on
our website. We will continue to add more as they
are published so the public and policymakers can
see the full inventory of what federal, state, and
local agencies are finding in their oversight of the
pandemic response.

Finally, this reporting period was another strong one
for media engagement. The PRAC has continued to
build relationships with journalists from small local


  Highlights        Background           Accomplishments         Accountability           Reports          Appendices


Pandemic Response Accountability Committee                                                                               6
                                                                       Trends, Insights, and
                                                                       Observations across the
                                                                       Oversight Community
Goal Two–                                                  Our coordination efforts with federal, state, and local


Promote
                                                           auditors uniquely position us to identify common trends
                                                           in pandemic relief oversight, innovative methodologies,
                                                           and work that can be replicated across the oversight

Coordinated,                                               community.

                                                                     Data visualization tools make critical

Comprehensive                                                        information more accessible to both decision
                                                                     makers and the public. For example, USDA

Oversight
                                                                     OIG developed a data tool for USDA’s Farmers
                                                                     to Families Food Box Program that allows
                                                                     users to explore the program’s distributors
                                                                     and recipients across the country.
Facilitate Exceptional                                               Many states lacked the infrastructure to
Coordination and                                                     efficiently collect and release data at the
                                                                     beginning of the pandemic. A multi-state
Collaboration to Ensure                                              COVID-19 Data Quality Task Force created a
                                                                     data quality template to assess the collection,
High-Impact Results                                                  reporting, and monitoring of COVID-19 cases
                                                                     across states.
During this reporting period, President Biden signed
                                                                     How federal agencies institutionalize
the COVID–19 EIDL Fraud Statute of Limitations Act
                                                                     anti-fraud mechanisms, or fail to do so,
of 2022 and the PPP and Bank Fraud Enforcement
                                                                     can impact future programs. SBA waived
Harmonization Act of 2022 into law, extending                        collections on purchased PPP loans with an
the statute of limitations for PPP and EIDL fraud                    outstanding balance of $100,000 or less—a
from 5 years to 10 years. The 10-year statute of                     total of $1.1 billion in loans—because the cost
limitations is consistent with that for bank fraud, the              to collect on these loans would likely be more
charge in most of these cases.                                       than the recovery amount. However, SBA OIG
                                                                     expressed concern that the decision could
PRAC Chair Michael Horowitz and SBA IG Hannibal                      set a dangerous precedent by incentivizing
“Mike” Ware championed these bills. At the time                      ineligible borrowers to request loans below
of signing on August 5, there were more than 650                     this amount.
active investigations into PPP and EIDL fraud.
Further, OIG investigations had already resulted                     Listening to recipients of federal funds can
                                                                     provide critical information on program
in more than 700 indictments with total charged
                                                                     effectiveness and inform future programs.
losses of more than $1.2 billion. Signage of these
                                                                     Of note, HUD OIG surveyed recipients of
bills into law represent a monumental achievement
                                                                     Community Development Block Grants and
for the PRAC and our partners, giving investigators                  Emergency Solution Grants to understand
more time to pursue those who defrauded programs                     the challenges they faced. In both programs,
intended to assist small business owners and their                   grantees lacked the staffing capacity to
employees during a national crisis.                                  administer funds, expressed challenges with
                                                                     coordinating and managing other pandemic
               Statue of limitations extended                        funding sources, and struggled to spend their
               from 5 to 10 years.                                   funds before the program’s deadline.



  Highlights         Background          Accomplishments   Accountability        Reports          Appendices


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Another key aspect of our mission is identifying major risks that cut across program and agency boundaries.
One of the ways we accomplish this mission is by working closely with the federal IG community and
oversight partners like the U.S. Government Accountability Office, as well as state and local auditors.

During this reporting period, we launched two new initiatives to deepen these relationships.

 • First, we brought on Elaine Howle as Special Advisor for State, Local, Tribal, and Territorial Oversight.
   As a nationally recognized expert and former California State Auditor, Ms. Howle brings nearly 40 years
   of professional auditing and leadership experience to the PRAC.
 • Second, we rolled out the State Auditor-in-Residence program, welcoming two auditors from the
   Tennessee Comptroller’s Office with a combined 30 years’ worth of experience in state and local
   oversight.

Foster Sound Stewardship of Covered Funds and Programs
The PRAC has learned that efficient and effective implementation of large-scale spending like the
coronavirus relief programs requires coordinated government oversight. In April 2022, the Office of
Management and Budget (OMB) issued guidance to federal agencies recommending they follow the PRAC’s
successful model of pandemic relief oversight for infrastructure funds.




                                                                                                                                   (AP Photo/Susan Walsh)




President Joe Biden, left, sitting with Office of Management and Budget Director Shalanda Young, right, and Michael
Horowitz, Inspector General for the Department of Justice and chair of the PRAC.


  Highlights          Background            Accomplishments               Accountability           Reports            Appendices


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On April 29, 2022, Chair Michael Horowitz and                and Jobs Act. The White House meeting coincided
other PRAC leadership met with President Biden,              with the issuance of OMB Memorandum M-22-
the Director of OMB, federal IGs, and other senior           12 that directs agencies to oversee infrastructure
officials to discuss the importance of ensuring              spending with the same collaborative approach that
robust oversight of the Infrastructure Investment            has been used for pandemic spending.


Ensure Efficient Sharing of Data, Analytics, and Other
Information
With the funding Congress provided in the American           Here are a few case studies to illustrate how the
Rescue Plan Act of 2021, we launched the PACE to             PACE is delivering data-driven, technology-enabled
deliver analytic, audit, and investigative support to        tools to support pandemic oversight.
the oversight community. We’ve acquired dozens of
public and non-public federal datasets and shared            The PACE created a dashboard to provide details on
them with IGs to help investigators find fraud across        transactions and entities that received pandemic
relief programs. We’ve brought in the best and               assistance from two SBA programs, PPP and EIDL.
brightest data science talent and have assigned 14
data science fellows to member IGs to help analyze           To develop this dashboard, the PACE ingested data
pandemic relief data.                                        from about 12.5 million PPP applications and about
                                                             27.8 million EIDL loan applications. Together, these
                                                             applications account for more than $1.2 trillion in
                                                             pandemic relief money.




Figure 3. The PACE ranked more than 40 million transactions and entities into a Fraud Risk Scale


  Highlights        Background           Accomplishments          Accountability        Reports         Appendices


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          What’s the difference                                    Created indicators of pandemic
          between a transaction                                    spending abuse among federal
              and an entity?
      A transaction refers to a single event or
                                                                   contractors.
  instance, in this case the submission of a PPP                   The PACE partnered with the DOJ’s Procurement
             or EIDL loan application.
                                                                   Collusion Strike Force team on a project to surface
  An entity, on the other hand, can include multiple               suspicious actors that have potential relationships
transactions or similarities across transactions—like              with suspicious entities. That is, relationships with
    nearly identical company names with slightly                   entities that have a history of colluding or engaging
                  different spellings.
                                                                   in other activities to limit competition.
      Entity analytics allows data analysts to
      decipher relationships among people,                         These indicators can be used to:
       transactions, and events, and rate
               the likelihood of risk.                              • see connections between defendants accused
                                                                      of pandemic-related fraud with recipients of
                                                                      recent government contracts;
The PACE then ran this data through 17 behavioral                   • identify and connect pandemic-related loan
risk indicators and six statistical risk indicators.                  recipients to government contractors that were
From this analysis, they were able to assign each                     awarded large contracts within 6 months of
transaction and entity a risk score value between 0                   pandemic loan actions;
and 100.
                                                                    • and identify and connect pandemic-related loan
The data generated from this dashboard can now                        recipients to contractors that were awarded
help the IG community:                                                more government contracts from 2020-2021,
                                                                      in comparison to 2018-2019.
  • target transactions and entities with the highest
    fraud risk score;                                              Ultimately, the aim of this project is to identify
                                                                   contractors who received pandemic assistance but
  • provide quantitative insights on how much
                                                                   might not have needed it—and to find contractors
    fraud existed across both programs; and
                                                                   who misused the proceeds they received.
  • identify gaps in internal controls that could have
    been addressed at the program level.




  Highlights           Background                Accomplishments        Accountability        Reports         Appendices


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Enhanced investigators’ ability                               Helping to identify federal
to query pandemic spending                                    employees’ misuse of PPP
data.                                                         and EIDL funds.
The PACE built an Investigative Support Tool to               The PACE is engaging in a series of joint projects
fully scan SBA pandemic program data. This                    with federal OIGs and law enforcement agencies
tool empowers investigators to conduct complex                to identify active employees that applied for PPP or
Structured Query Language analysis, or SQL, even if           EIDL, which they are ineligible to receive. Here are
they don’t have coding skills.                                the steps involved:

Among the Investigative Support Tool’s features:               1. Determine which employees applied for
                                                                  pandemic related loans and grants.
 • a flexible form to capture as much nuanced
   detail as possible from an agent’s request;                 2. Compare and connect pandemic-related loan
                                                                  recipients against federal employee information
 • the ability to process a subject’s information                 to identify matches that require further review.
   into specially designed SQL queries across all
   PPP and EIDL data; and                                      3. Prioritize the quality of the data matches
                                                                  for investigative review on the likelihood of
 • pre-formatted output—that is, an easy-to-                      matches between PPP and EIDL applicants and
   read Excel document delivered straight to the                  federal employees.
   requesting agent.
                                                               4. So far, this analysis has helped six agency OIGs
                                                                  match tens of thousands of employees with
                                                                  SBA loans for which they were not eligible.
                      What is
                 Structured Query
                 Language (SQL)
                     analysis?
                  SQL is a programming
                language that helps data
               analysts read, manipulate,
                  and interact with data




  Highlights         Background             Accomplishments       Accountability        Reports         Appendices


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Goal Three–Prevent and Detect Fraud,
Waste, Abuse, and Mismanagement
Hold Wrongdoers Accountable
The PRAC’s Fraud Task Force serves as a resource            the Task Force, flagging anomalies or potential leads
for the IG community by surging investigative               in pandemic relief data.
resources into areas with the greatest need. We
have 50 agents across 15 OIGs detailed to work              Working collaboratively with DOJ, the National Credit
on Task Force cases. These agents are located               Union Administration, and our law enforcement
around the country and are working cases that               partners, the PRAC collected information about
would otherwise go unaddressed due to the scale of          pandemic funds being held by credit unions due
pandemic fraud.                                             to suspected fraud. This data collection effort
                                                            identified nearly $8.75 million that may be subject
The idea behind our Task Force is to harness the            to recovery. The money comes from a variety of
expertise of the oversight community and attack             sources, including the Paycheck Protection Program,
this problem with every tool we have—criminal, civil,       Economic Injury Disaster Loan program, and
forfeitures of money and property, and suspensions          Pandemic Unemployment Assistance.
and debarments. Our PRAC Fraud Task Force works
closely with other entities to combat pandemic fraud
such as DOJ’s COVID-19 Fraud Enforcement Task
Force. The PACE provides investigative support to




Figure 4. PRAC’s Fraud Task Force Agents are located across the United States


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Mitigate Major Risks That
Cut Across Program and
Agency Boundaries
The PRAC works with our OIG members and state
and local partners to identify emerging fraud
risks created by the pandemic. For instance,
on September 1, 2022, the PRAC entered into
a Memorandum of Understanding with the
Massachusetts Office of the Inspector General to
assist with investigative support. Both agencies
share an interest in pandemic relief investigations
and entered into this agreement to fully promote
interagency collaboration.

In addition, we issued a joint risk advisory with the
HUD OIG and SBA OIG on potential identity fraud            Task Force Indictment
targeting elderly and minors. Through advanced
                                                           On September 9, 2022, a Louisiana woman was
data analytics, we identified possible identity
                                                           indicted for preparing more than 110 fraudulent PPP
or other fraud in SBA programs involving 945               applications totaling $1.1 million.
minors and 231 elderly individuals. These minors
                                                           Our investigators uncovered her scheme after finding
and elderly individuals were listed as household
                                                           that more than 100 sole proprietor loan applications
members in HUD’s Low Rent and/or Housing Choice
                                                           had been submitted in and around Thibodaux,
Voucher Program, which helps low and very low-
                                                           Louisiana, all with the same invoices and federal tax
income families, the elderly, and the disabled afford      forms, listing the same business name and amount.
decent, safe, and sanitary housing in the private
market.                                                    An agent detailed from the Department of Veterans
                                                           Affairs OIG worked the case. Learn more.
And we continue to work closely with OMB, the
American Rescue Plan implementation team,
and partner IGs to address issues with pandemic
relief data and opportunities to enhance payment
integrity.




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Goal Four–Ensure Effective and
Efficient PRAC Operations
Fulfill Statutory                                          Build a Diverse Team of
Responsibilities                                           Innovative Thought Leaders
As previously mentioned, PRAC Chair Michael                What started in March 2020 as a Committee within
Horowitz testified before the House Select                 CIGIE with few employees has grown to a nationally
Subcommittee on the Coronavirus Crisis this past           distributed workforce of 54 staff members spread
June about the PRAC’s ongoing oversight work,              across five time zones. Congress gave the PRAC
achievements over the past two years, and the              direct hiring authority in the CARES Act to expedite
collaborative model we are building to provide             our recruiting process, enabling us to continue
a legacy for effective, coordinated government             recruiting from a deep pool of candidates in the
oversight during and after the pandemic.                   private sector, academia, and government. With our
                                                           partners, tools, staff, and ethos of teamwork, the
In his testimony, Chair Horowitz also highlighted          PRAC is well positioned to effectively oversee $5
results the PRAC achieved though discussions               trillion in pandemic relief funds.
with the Biden Administration and reiterated
the imperative that executive departments and
agencies do more to incorporate lessons learned            Supporting the Independent
from previous rounds of COVID-19 stimulus—such
as those discussed in our recently updated Lessons
                                                           Oversight of Inspectors
Learned in Oversight of Pandemic Relief Funds.             General
Further, Chair Horowitz testified that the PRAC’s          The PRAC is mindful of the complexity of the federal
efforts could be enhanced by the reforms outlined in       programs involved in the pandemic response and
the Administrative False Claims Act of 2021, which         the need for deep programmatic expertise in these
would raise the jurisdictional limit for administrative    programs to ensure efficient and effective auditing
recoveries of ‘smaller’ false or fraudulent claims         and review. Inspectors General have specialized
against the government from $150,000 to $1 million.        expertise and institutional knowledge regarding the
This change would extend the PRAC’s and the IG             programs of their respective agencies and the most
community’s ability to use this fraud-fighting tool to     effective oversight methods for those programs. This
recover pandemic-related funds for taxpayers.              expertise, experience, credibility, and institutional
                                                           knowledge is critical to fulfilling the PRAC’s mission.
                                                           Accordingly, the PRAC relies on the existing expertise
                                                           and experience of individual agency IGs while
                                                           respecting their autonomy to conduct their own
                                                           audits or investigations.




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Holding Wrongdoers Accountable
Through Investigations
A key role of OIGs is to support law enforcement in pursuing fraud investigations and criminal enforcement.
A total of 17 OIGs publicly reported 740 indictments and arrests, and 450 convictions from April 1, 2022,
through September 30, 2022, related to the federal government’s COVID-19 pandemic response. The
following section provides the total number of accountability actions organized by agency and highlights
cases categorized by criminal activity.




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                                           Percentage of Cases by Program
                                 (April 1, 2022, through September 30, 2022)
          Program Area                                           Percentage of Cases by Program
          Paycheck Protection Program                                         50%
          Pandemic Unemployment                                               32%
          Economic Injury Disaster Loans                                      24%
          Health & Safety (Vaccination, Testing, PPE)                          3%
          Other (Coronavirus Food Assistance Program, Price
                                                                               4%
          Gouging, Economic Impact Payments)
          Source: Assembled by the PRAC from DOJ RSS feed.
          Note: The percentages above credit all programs included in one case, and therefore, the total percentages exceeds 100
          percent.



Table 1. Percentage of Cases by Program


                                                     Investigative Results
                                 (April 1, 2022, through September 30, 2022)
          Office of Inspector General                          Arrests/Indictments                               Convictions
          Amtrak                                                                            2                        2
          Defense Criminal Investigative Service                                            26                       7
          Department of Health and Human Services                                           48                      32
          Department of Homeland Security                                                   70                      12
          Department of Housing and Urban Development                                        0                       1
          Department of Justice                                                              2                          0
          Department of Labor                                                              255                        157
          Department of the Treasury                                                        2                          0
          Department of Veterans Affairs                                                    0                          3
          Federal Deposit Insurance Corporation                                             70                        33
          Federal Housing Finance Agency                                                    10                         8
          Federal Reserve Board                                                             38                         28
          Small Business Administration                                                    129                        100
          Social Security Administration                                                     7                          2
          Special Inspector General for Pandemic Recovery                                   1                          1
          Treasury Inspector General for Tax Administration                                 68                         52
          U.S. Postal Service                                                               12                         12
          Source: Assembled by the PRAC from Department of Justice RSS feed
          Note: Investigative work often involves several law enforcement agencies working on the same case. OIGs may conduct
          cases with other OIGs, other federal law enforcement agencies, and state and local law enforcement entities. The counts
          above credit all OIGs involved in the case and do not represent unique cases.



Table 2. Investigative Results


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Paycheck Protection                                        Department of Defense OIG
Program (PPP) and                                          Fort Stewart Soldier Admits Guilt in Prolific
                                                           Fraud Scheme Targeting COVID-19 Relief
Economic Injury Disaster                                   Programs and Student Loans
Loan (EIDL) Case Highlights                                An Army soldier stationed at Fort Stewart admitted
                                                           that she led a “prolific fraud scheme” in which
Amtrak OIG                                                 she and others illegally raked in millions of dollars
                                                           from COVID-19 relief programs and federal student
Former Employee Sentenced for Defrauding                   loan forgiveness. The defendant led a conspiracy
Paycheck Protection Program and                            to fraudulently obtain PPP loans and to secure the
Unemployment Fraud                                         fraudulent discharge of federal student loans using
                                                           falsified disability claims. The soldier admitted
A former Amtrak train attendant based in New               submitting more than 150 fraudulent PPP loan
Orleans was sentenced in the Eastern District              applications in all, resulting in more than $3.5
of Louisiana to three years of probation and               million in fraudulent disbursements.
12 months of home confinement for stealing
government funds and making false statements.
He was also ordered to pay the SBA and the                 Department of Labor OIG
Louisiana Workforce Commission nearly $65,000
                                                           Man Pleads Guilty to Role in Stealing More
and $23,000 in restitution, respectively. The
                                                           than $2.2 Million in Pandemic Assistance
investigation found that the former employee
                                                           Benefits
made false statements to the SBA and fraudulently
obtained almost $90,000 in PPP loans. He also              The defendant plead guilty to conspiracy to
fraudulently applied for and received unemployment         commit wire fraud and mail fraud in connection
benefits through the Louisiana Workforce                   with schemes to defraud multiple state workforce
Commission despite being fully employed by Amtrak.         agencies, the SBA, and U.S. Postal Service. The
                                                           defendant and his co-conspirators submitted more
Florida Man Pleads Guilty to Wire Fraud                    than 240 fraudulent unemployment insurance
                                                           claims to more than 20 states and territories,
A Florida man pleaded guilty in U.S. District
                                                           obtaining more than $2.2 million in benefits. He
Court, Southern District of Florida, to one count
                                                           also successfully obtained a fraudulent PPP loan for
of wire fraud in relation to his application for a
                                                           more than $20,000.
PPP loan and in obtaining an EIDL in the amount
of $149,900. The PPP loan, in the amount of
$150,000, was denied. Investigators found that the
defendant used an invalid social security number
and included other false information on his PPP and
EIDL applications.




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Federal Deposit Insurance                                  On the fraudulent PPP applications, the defendant
                                                           falsified the number of employees at his company,
Corporation OIG                                            and faked federal tax returns and payroll
                                                           documentation. He obtained over $4.5 million in
California Man Sentenced to Over 11 Years for
                                                           PPP funds and then misused the loan proceeds,
$27 Million PPP Fraud Scheme
                                                           including losing approximately $3 million in
                                                           unsuccessful stock trades.
The defendant submitted 27 PPP loan applications
to four banks on behalf of eight companies. In the
                                                           Philadelphia Man Sentenced for Fraudulently
applications, the defendant sought a total of $27
                                                           Obtaining Nearly $1 Million in PPP Funds
million in forgivable PPP loans. In his fraudulent
applications, the defendant represented that each
                                                           A business owner was sentenced to 78 months in
of his companies had 100 employees and average
                                                           prison, five years supervised release, and ordered
monthly payroll of $400,000, even though he knew
                                                           to pay $939,350 in restitution and $937,500 in
the companies did not have any employees or
                                                           forfeiture in connection with a scheme to unlawfully
payroll expenses.
                                                           obtain and misuse PPP loans. The defendant
                                                           previously pleaded guilty to bank fraud, attempted
The evidence further showed that the defendant
                                                           bank fraud, and money laundering.
submitted fake Internal Revenue Service (IRS)
documents. Although the defendant represented
                                                           According to court records, the defendant
that the funds would be used for payroll and other
                                                           fraudulently obtained approximately $937,500 in
business expenses, evidence showed that he used
                                                           PPP loans by making multiple false representations
the money for personal expenses, including cash
                                                           about his business, including the number of
withdrawals, payments on his personal credit cards,
                                                           employees, wages paid, and payroll taxes paid on
transfers to other personal and business accounts
                                                           those wages. The defendant then used the PPP
he controlled, and renting an oceanfront apartment
                                                           loan proceeds for personal purchases including a
in Santa Monica.
                                                           new residential property in Florida, a motorcycle, an
                                                           all-terrain vehicle, a luxury automobile, and diamond
The defendant was sentenced to more than 11
                                                           jewelry.
years in prison.
                                                           Texas Woman Sentenced to Over Five Years for
Federal Housing Finance                                    COVID Relief Fraud Scheme
Agency OIG                                                 A business owner was sentenced to 70 months in
New York and Florida Resident Sentenced to                 prison, five years supervised release, and ordered
51 Months in Prison for $6.8 Million Paycheck              to pay over $2 million in restitution for defrauding
Protection Program Fraud Scheme                            PPP of over $1.9 million in forgivable loans. The
                                                           defendant was previously convicted by a federal
A business owner was sentenced to 51 months in             jury of bank fraud and making false statements to a
prison, two years supervised release, and ordered          financial institution.
to pay over $4.5 million in restitution and forfeiture
for his role in a scheme to fraudulently obtain over
$6.8 million in PPP loans. The defendant previously
pleaded guilty to wire fraud and money laundering.


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Federal Reserve Board &                                    The defendant also submitted fraudulent IRS tax
                                                           forms to support his applications. The evidence at
Consumer Financial Protection                              trial showed that his company was a startup with
Bureau OIG                                                 no U.S.-based payroll and no U.S.-based employees.
                                                           As a result of his scheme, the defendant obtained
Florida Man to Plead Guilty to $2.5 Million                a $2 million PPP loan. The government recovered
COVID Relief Fraud                                         approximately $1.97 million of the loan funds.

The defendant owned Complete Home Care, LLC                The defendant was sentenced to 39 months
(CHC), a painting company in Massachusetts. In             incarceration and three years of supervised
April 2020, the defendant submitted four different         release, ordered to pay restitution of $2 million, and
PPP loan applications on behalf of CHC. The first          forfeiture of $2 million.
three applications, in which the defendant allegedly
listed five employees and an average monthly payroll
of between $10,000 and $18,000, were denied. In
                                                           Small Business
the fourth application for CHC, it is alleged that the     Administration OIG
defendant falsely claimed to have 154 employees
and an average monthly payroll of $1 million. On           Chinese National Sentenced To 52 Months For
May 11, 2020, a bank issued the defendant’s                $20 Million Covid-19 Pandemic Loan Fraud
company a $2,500,000 loan based on the allegedly           Scheme
false representations in the fourth application.
                                                           The defendant was sentenced to 52 months in
After receiving the funds, it is alleged that the          prison in connection with a fraudulent scheme to
defendant misused the loan proceeds to buy real            obtain over $20 million in government-guaranteed
estate and cars and to invest in cryptocurrency.           loans designed to provide relief to small businesses
                                                           during the COVID-19 pandemic. Over the course
Owner of Tech Services Company Sentenced to                of two months in 2020, the defendant applied to
More than Three Years in Prison for $13 Million            the SBA and at least six banks for a business he
COVID-Relief Fraud Scheme                                  claimed had hundreds of employees. However,
                                                           the defendant was, in fact, the only employee.
The defendant was sentenced in federal court in            To support the false representations on his
Boston in connection with filing fraudulent loan           applications, the defendant submitted fake bank,
applications seeking more than $13 million in PPP          tax, insurance, and payroll records to six different
loans. The defendant devised a scheme to obtain            banks. He also used the name and identity of
PPP funds by repeatedly filing false and fraudulent        another person in connection with the scheme.
loan applications in which he systematically used
fake tax documents and payroll processing records
until he was ultimately awarded a loan.

The defendant submitted six fraudulent PPP loan
applications on behalf of his company to four
different SBA-approved lenders. In each loan
application, the defendant misrepresented the
number of employees he had and payroll expenses.


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Special Inspector General for                              Social Security
Pandemic Recovery                                          Administration OIG
Naples Felon Pleads Guilty to $2.6 Million                 Fairhope Man Pleads Guilty to Over $1.2
COVID Relief Fraud Scheme                                  Million in PPP Fraud

The defendant, a previously convicted felon,               The defendant pleaded guilty to two counts of
submitted false and fraudulent EIDL, Main Street           wire fraud and one count of money laundering for
Lending Program (MSLP), and PPP applications               fraudulently obtaining two PPP loans on behalf of
to the SBA, as well as PPP and MSLP approved               two companies. The defendant used false tax forms,
lenders. The loan applications contained numerous          altered checks, and falsified loan documents to
false representations, including the criminal history,     obtain the loans. After successfully securing over
average monthly payroll, number of employees, and          $1.2 million in PPP loan funds, the defendant spent
gross revenues of the applicant.                           the money on luxury goods and real estate, among
                                                           other things.
To support the fraudulent applications, the
defendant submitted fake payroll and tax                   Florida Man Charged with $1.6 Million CARES
documents, as well as a fake commercial lease.             Act Loan Fraud Scheme
The defendant received more than $2 million
and used the money to buy residences in Naples,            The defendant engaged in a scheme to illegally
Florida, stocks and investment securities, a 2019          obtain over $1.6 million in PPP and EIDL loans
Tiara 34LS boat, a 4.02 carat engagement ring, and         through numerous misrepresentations to lenders.
ammunition. (As a convicted felon, the defendant           He submitted fraudulent loan applications
was prohibited from possessing ammunition.)                that fabricated numbers of employees and
                                                           misrepresented company information. The
The defendant pled guilty to wire fraud, bank fraud,       defendant also submitted falsified tax documents to
illegal monetary transaction, and possession of            support the applications.
ammunition by a convicted felon. As part of his
guilty plea, the defendant agreed to forfeit the boat,     The defendant transferred the loan proceeds among
real estate, and engagement ring.                          various bank accounts he controlled, withdrawing
                                                           significant amounts in cash, and transferring at
                                                           least $760,000 out of the country via wire transfers
                                                           to banks in Egypt. The defendant was charged with
                                                           two counts of wire fraud.




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Treasury Inspector General for                             To date, two of the co-conspirators have been
                                                           sentenced for their involvement in the scheme.
Tax Administration                                         Collectively, the two subjects received 17 months’
                                                           imprisonment and were ordered to pay the SBA over
Riverside County Man Pleads Guilty to Federal
                                                           $218,000 in restitution.
Criminal Charges for Fraudulently Obtaining
$6.6 Million in COVID-Relief Business Loans
                                                           Pandemic Unemployment
The defendant submitted 11 fraudulent PPP loan
applications for seven of his shell companies. The         Case Highlights
fraudulent PPP loan applications misrepresented
the number of employees and the average monthly
payroll expenses of the defendant’s companies, and
                                                           Amtrak OIG
falsely certified he would use the loan proceeds for       Former Amtrak Employee Indicted for
permissible business purposes. The defendant also          Fraudulently Obtaining Emergency Pandemic
submitted false tax and payroll documentation to           Relief Funding
support his loan applications. In total, the defendant
received more than $6.6 million in loan proceeds           The indictment alleges that a former Amtrak
even though none of his companies were legitimate          employee fraudulently applied for and received
recipients of relief funds at that time. The defendant     Pandemic Unemployment Assistance while she
then laundered loan proceeds to bank accounts in           was a full-time employee of Amtrak. Further, the
the United States and Pakistan.                            defendant applied for and received a PPP loan for
                                                           what she claimed was a small catering business.
Twenty-two People Charged in Connection with               She was terminated from employment with Amtrak
a Multi-Million Dollar PPP Fraud Scheme                    after the crimes alleged in the indictment occurred.

Twenty-two individuals across the United States
were charged with wire fraud conspiracy and other
                                                           Department of Defense OIG
related charges in connection with a scheme to             (Defense Criminal Investigative
obtain nearly $4 million in PPP loans.
                                                           Services)
The conspirators allegedly submitted, or assisted          Sandown Man Pleads Guilty to Wire Fraud
in the submission of, PPP loan applications on             Related to the COVID-19 Pandemic
behalf of twenty-two businesses. In connection
with the scheme, one defendant allegedly directed          The defendant executed two schemes to defraud
a co-conspirator to fabricate documents on behalf          government programs intended to provide economic
of individuals that the defendant identified so            assistance related to the COVID-19 pandemic.
they could apply for and receive PPP loans. The            New Hampshire Employment Security administers
co-conspirator allegedly communicated with the             the unemployment insurance program in New
purported business owners about the loan amount            Hampshire. The defendant was the Chief Financial
they wanted to receive, and then fabricated tax            Officer of several companies located in Plaistow,
documents and other supporting documents to                including Environment and KSC Industrial (a
submit with the PPP loan application to support that       Department of Defense contractor), that were
amount.                                                    controlled by his co-defendant. In late-March 2020,


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the defendant and his co-defendant directed                the conspirators obtained approximately $1 million
company employees to file for unemployment                 in PUA and Unemployment Insurance benefits.
benefits with New Hampshire Employment
Security while continuing to work. This resulted in        Couple Charged with Using Fake Employer
the unemployment system effectively paying the             Accounts and Stolen Identities to Obtain More
employees’ salaries. The defendant also made false         than $1.5 Million in Unemployment Insurance
representations to lenders to fraudulently obtain a        Benefits
PPP and EIDL loan for KSC Industrial. For example,
he certified that KSC Industrial was not engaged           The defendants were indicted for allegedly using
in illegal activity. However, when making that             stolen identities to fraudulently claim unemployment
certification, he knew that he and his co-defendant        insurance under fictitious employer accounts
were fraudulently using the unemployment benefits          registered with the Georgia Department of Labor.
system to pay their employees’ salaries.                   The scheme resulted in the fraudulent payment of
                                                           more than $1.5 million in unemployment insurance
Through this scheme, the defendant fraudulently            benefits, including Pandemic Unemployment
obtained more than $135,000 in loans.                      Assistance and Lost Wage Assistance—programs
                                                           that were created and expanded to assist
                                                           individuals experiencing unemployment due to the
Department of Homeland                                     COVID-19 pandemic.
Security OIG
                                                           Starting in June 2020, the defendants allegedly
Midlothian Woman Sentenced for $1.8 Million                created several fictitious employer accounts with
COVID-19 Fraud Using Information Obtained                  the Georgia Department of Labor. Through these
from Her State Employment                                  accounts, they submitted false information that
                                                           was used to determine whether persons associated
A Midlothian, VA woman was sentenced to 70                 with the employer were entitled to receive benefits.
months in prison for defrauding PUA, PPP, and              This information included the names and personally
EIDL, using victims’ personal identifying information      identifiable information for purported employees,
that she obtained from her state government                which were stolen identities of individuals who had
employment.                                                no knowledge of the scheme and did not consent
                                                           to the use of their information. The defendants
In one scheme, the defendant and a co-conspirator
                                                           allegedly used some of the same stolen identities
defrauded the Virginia Employment Commission
                                                           to submit fraudulent claims for unemployment
by filing at least 20 fraudulent unemployment
                                                           insurance benefits in California.
applications using the personal identifying
information of inmates. The conspirators further
defrauded the Virginia Employment Commission               Department of Labor OIG
by filing at least 30 fraudulent applications in
                                                           State Employee Charged in Over $1 million
the names of other individuals whose personal
                                                           Unemployment Fraud Scheme
identifying information was obtained, in part, by the
defendant querying a government database she
                                                           Three women have been charged in a criminal
had access to as an employee of the Virginia Motor
                                                           complaint for their alleged role in a $1.6 million
Vehicle Dealer Board. Through this fraud scheme,
                                                           dollar unemployment insurance fraud scheme
                                                           aimed at defrauding the State of Michigan and


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federal government of funds earmarked for                  the pandemic and reaffirmed this unemployment
unemployment assistance during the COVID-19                status on a weekly basis, ultimately receiving
pandemic.                                                  $37,555 in benefits. The employee resigned from
                                                           the agency and was charged with wire fraud.
The defendant was employed by the State of
Michigan as an Unemployment Insurance Examiner             This was a joint investigation with the U.S.
in the Benefit Payment Control Unit. Her duties            Department of Labor OIG.
included reviewing, approving, and adjudicating
various PUA and unemployment insurance claims.
Starting in March 2020, the defendant and her              Health Care/Medicare Fraud
co-conspirators fraudulently filed and accessed
over 123 PUA claims, resulting in the disbursement
                                                           Case Highlights
of approximately $1.6 million in federal funds
earmarked for PUA and unemployment insurance               Department of Health and
agency benefit payments. The defendant acted               Human Services (HHS) OIG
outside the scope of her authority by electronically
accessing, altering, and approving approximately           MorseLife Nursing Home Health System
101 of the fraudulent claims, which were all               Agrees to Pay $1.75 Million to Settle False
associated with the co-conspirators residences.            Claims Act Allegations for Facilitating
They are alleged to have received money from third         COVID-19 Vaccinations of Ineligible Donors and
parties to assist them with the claims and paid            Prospective Donors
the defendant for her assistance in processing the
fraudulent claims.                                         MorseLife Health System Inc. has agreed to pay
                                                           the United States $1.75 million to resolve its
                                                           potential liability under the False Claims Act for
U.S. Department of                                         facilitating COVID-19 vaccinations for hundreds of
Agriculture OIG                                            individuals ineligible to participate in the Centers for
                                                           Disease Control and Prevention’s (CDC) Pharmacy
Former USDA Employee Sentenced to 10                       Partnership for Long-Term Care Program, a program
Months in Prison for Fraud in Connection with              specifically designed to vaccinate long-term care
Pandemic Assistance Funds                                  facility residents and staff when doses of COVID-19
                                                           vaccine were in limited supply at the beginning of
A former Food Safety and Inspection Service
                                                           the CDC’s COVID-19 Vaccination Program. MorseLife
employee was sentenced to 10 months in prison
                                                           is a not-for-profit corporation located in West Palm
and 24 months of supervised release and was
                                                           Beach, Florida, that oversees health care facilities
ordered to pay restitution in the amount of $37,555
                                                           on its campus.
and a $100 special assessment.

USDA OIG initiated this investigation to determine
whether the employee applied for and received
Pennsylvania Pandemic Unemployment Assistance
while being gainfully employed as a Consumer
Safety Inspector. The investigation determined the
employee falsely claimed to be unemployed due to


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Other Case Highlights                                      U.S. Postal Service OIG
                                                           Queens Postal Workers Charged with Bribery
U.S. Department of Housing                                 and Theft of Mail Linked to Covid-19 Benefits
and Urban Development OIG                                  Fraud

Wife of Former West Haven City Employee                    While employed as letter carriers with the U.S.
Admits Role in Scheme to Steal COVID Relief                Postal Service and working in Queens, New York, the
Funds                                                      defendants accepted cash bribes to intercept and
                                                           steal mail sent by the New York State Department of
According to court documents and statements                Labor to addresses on their assigned postal routes.
made in court, the defendant conspired with her
husband, who at the time was a Connecticut State           The stolen mail was linked to a scheme to obtain
Representative and West Haven city employee,               COVID-19 unemployment benefits through the
to steal money that was provided to West Haven             fraudulent filing and verification of benefit claims
to alleviate the economic impact of the COVID-19           using the names and social security numbers of
pandemic. The defendant’s husband submitted                hundreds of other individuals. Law enforcement
fraudulent invoices to West Haven for services             agencies were first alerted to the scheme after
related to a Youth Violence Prevention Program.            a pair of other conspirators fled a hotel, leaving
These invoices listed charges for in-home                  behind over 700 pieces of New York State
counseling, cleaning supplies, special needs hourly        Department of Labor mail, containing, among other
service, wifi assistance for low- and moderate-            items, benefit debit cards. The stash was tied to over
income families, counseling services, license fees,        500 unemployment benefit claims seeking in excess
a fall youth clinic, meals, support group supplies,        of $16 million in benefits, approximately $3 million
equipment rental, and youth clinic support group.          of which had already been disbursed.
The payment vouchers requested that checks be
made out to directly to the defendant.

The City of West Haven made 16 payments totaling
$147,776 to the defendant, who never provided any
services to the City of West Haven. The defendant
and her husband used the proceeds for their own
benefit. The defendant pled guilty to a conspiracy
and wire fraud charges stemming from her role in
the scheme.




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Key Insights Through Oversight
Reports
From April 1, 2022, through September 30, 2022,
26 Offices of Inspectors General issued 114                                Key Insight 1: The Pandemic
oversight reports related to the Federal
Government’s COVID-19 pandemic response, and
                                                                           Created Program Monitoring
these reports identified $31.2 billion in monetary                         Challenges and Increased
findings (e.g., questioned costs or funds put to
better use).1 OIGs also made 343 recommendations                           Program Risks
to improve the government’s response to the
pandemic, such as improving internal controls and                          With significant increases in federal funding
providing more oversight of recipients . See table 3                       provided to recipients, monitoring the money to see
for more information about the reports issued by                           if it helped achieve intended goals and objectives
our OIG partners. For a complete list of all oversight                     was critical. Oversight reports issued during this
reports issued, see “Appendix B” on page 32.                               reporting period identified several challenges
                                                                           recipients experienced implementing pandemic
As we will discuss in the following pages, these                           response activities. For example, travel restrictions
federal oversight products provide key insights on:                        delayed inspections and large increases in funding
                                                                           made it difficult to monitor subrecipients. These
    1. Ways the pandemic created program monitoring                        difficulties show that federal agencies need to adapt
       challenges and increased program risk.                              during the pandemic to effectively monitor funds.

    2. Risks with self-certification that extend beyond                    In one example, the Environmental Protection
       the Pandemic Unemployment Assistance, the                           Agency (EPA) OIG found that travel restrictions
       Paycheck Protection Program, and Economic                           caused inspection delays at Superfund sites (a
       Injury Disaster Loan programs.                                      contaminated area that has not been cleaned
                                                                           up). Specifically, 147 sites (31%) had a delayed
    3. How failure to implement or effectively modify
                                                                           inspection of more than one month due to travel
       critical pandemic-related internal controls
                                                                           restrictions. The delays caused prolonged human
       created risks for agency programs.
                                                                           health and environmental exposure to pollutants
    4. Why assessing emergency planning procedures                         and/or hazardous chemicals at 31 sites.
       used during the pandemic can help inform and
       improve future emergency responses.                                 EPA changed its guidance and protocols to increase
                                                                           oversight and monitoring of these sites, including an
    5. Ways data can help inform the design of more                        increase in virtual communication. This increased
       equitable programs.                                                 participation and clean-up activities. However,
                                                                           virtual communication increased inspection costs at
                                                                           some sites and complicated participation and clean-
                                                                           up at other sites with unreliable internet access.
1    These oversight reports include all reports, memorandums, and advisories issued by the OIGs related to the COVID-19 response funding and
     programs.


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                   Oversight Reports from April 1, 2022, through September 30, 2022
                                                                           Total             Total                   Total Monetary
      Office of Inspector General                                         Reports       Recommendations                 Findingsa
      Architect of the Capitol                                                1                     0
      Department of Agriculture                                               5                     7                      $5,928,922
      Department of Defense                                                   5                     3                   $26,630,773
      Department of Education                                                 5                    21                       $652,720
      Department of Health and Human Services                                17                    45
      Department of Homeland Security                                        11                    53                   $45,000,000
      Department of Housing and Urban Development                            3                      6
      Department of the Interior                                             2                     6                        $466,044
      Department of Justice                                                  1                     6
      Department of Labor                                                     4                    12              $29,607,092,604b
      Department of State                                                     1                     0
      Department of Transportation                                            1                     7                  $360,352,764
      Department of the Treasury                                              4                     8                      $1,105,256
      Department of Veterans Affairs                                          4                     4                      $2,336,381
      Election Assistance Commission                                          6                    25                       $914,835
      Environmental Protection Agency                                         1                     3
      General Services Administration                                         2                     2
      Federal Reserve Board & Consumer Financial
                                                                              2                     0
      Protection Bureau
      National Security Agency                                                1                     4                   $16,400,000
      Pandemic Response Accountability Committee                              2                     0
      U.S. Postal Service                                                     2                     3                    $2,336,381
      Railroad Retirement Board                                               1                     1                   $28,575,000
      Small Business Administration                                           8                    27                   $18,559,541
      Social Security Administration                                          3                    18
      Special Inspector General for Pandemic Recovery                         8                     2
      U.S. Treasury Inspector General for Tax
                                                                             14                    80                $1,130,882,934
      Administration
      Totals                                                                114                   343               $31,247,234,155
      a
          “Monetary findings” include all questioned costs and funds put to better use identified by each
      OIG. b One recommendation was $29,600,000,000.




      Table 3. Oversight Reports from April 1, 2022, through September 30, 2022




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In another example, a survey by HUD OIG found
it was difficult for prime recipients of Emergency                   Insights through Single Audits
Solutions Grants to monitor their subrecipients.
This may increase the risk of misuse of the funds                      Under federal regulations, any recipient
and delay spending. These monitoring challenges                        (or subrecipient) that receives more than
were driven by a large increase in federal funding         $750,000 in federal funding during its fiscal year
and the expectation that funds be used quickly             is subject to a single audit. This can include state
to address the impact of the pandemic. HUD                 governments, local governments, and non-profit
                                                           organizations. Single audits assess a recipient’s
OIG recommended that the agency consider
                                                           controls over compliance for federal assistance and
incorporating this challenge into the program’s risk
                                                           identify possible areas of improvements and questioned
assessment.                                                costs. If a finding or concern is identified, the recipient
                                                           must prepare a corrective action plan to address those
Key Insight 2: Risks                                       concerns. As of September 30, 2022, 36 fiscal year
                                                           2021 statewide single audits had been issued. These
with Self-Certification                                    audits include:
                                                            • 114 findings related to the Coronavirus Relief
Extend Beyond Pandemic                                        Fund (CRF)

Unemployment Assistance,                                    • 140 findings related to unemployment insurance

PPP, and EIDL                                              For example, the single audit for Washington state
                                                           found the state spent $17.6 billion in federal pandemic
The PRAC and its partner OIGs have issued reports          funding between July 1, 2020, and June 30, 2021.
highlighting the challenges associated with                The Washington State Auditor looked at 17 pandemic
                                                           relief funds, including $9.3 billion in unemployment
using self-certification to approve federal funds
                                                           insurance funds and $3.4 billion in Medicaid funds
or benefits. The use of self-certification in small
                                                           related to the pandemic. The single audit identified
business assistance programs and unemployment
                                                           several issues with reporting requirements and
insurance programs sought to distribute funds              subrecipient monitoring, including not evaluating
quickly to meet the needs of the public. However, it       subrecipient risk, resulting in $4.1 million in question
led to an increase in fraud and improper payments.         costs, and $6.4 million in likely improper payments for
For example, in a September 2022 report, SBA OIG           the Coronavirus Relief Fund. See the report summary
found $8.5 billion in EIDL payments were disbursed         for more information.
before SBA began using tax information to verify
eligibility. SBA OIG found more than $92 million           The Tennessee single audit showed a dramatic increase
was disbursed to businesses with suspect taxpayer          in federal assistance from $14 billion in 2019 to $24
identification numbers.                                    billion in 2021. The report questioned approximately
                                                           $1.8 million of UI benefits that were not properly paid.
Additional reports issued during this reporting            The audit also questioned nearly $500,000 of duplicate
                                                           expenditures charged to the CRF program and reported
period identified issues with self-certification in
                                                           that two departments receiving CRF funds did not
other programs. For example, the Department of
                                                           monitor subrecipients. See Tennessee’s single audit
Homeland Security (DHS) OIG reported that FEMA’s
                                                           report for more information.
Lost Wages Assistance Program—implemented by
state workforce agencies—provided $3.7 billion
in improper payments ($3.3 billion of which was


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fraudulent) in 21 states reviewed. The DHS OIG
previously identified the use of self-certification by
                                                           Key Insight 3: Failure to
FEMA as a decades-long problem.                            Implement or Effectively
The Department of Transportation (DOT) OIG found           Modify Critical Internal
that within two weeks of the CARES Act passage—
which gave the Federal Aviation Administration (FAA)       Controls Created Risks in
$10 billion—FAA had announced awards to more
3,000 airports through their Airport Improvement
                                                           Pandemic Relief Programs
Program. DOT OIG found that FAA did not provide            The pandemic created unique challenges that
clear guidance on documenting information and              required distinct controls to mitigate fraud or
data the grant application needed to provide               improper payments. It was also critical for agencies
prior to award approval. As a result, FAA had to           to adapt or modify initial controls as needs shifted
rely on airport self-certification, which was often        during the pandemic, but this did not always occur.
inconsistent, to assess grant compliance and               Examples included failing to institutionalize proper
monitor recipient activity effectively.                    procedures or effectively train program personnel.
                                                           In some cases, these controls were legislatively
State oversight offices have also found risks related      required to improve programs and reduce fraud.
to self-certification within pandemic programs. The
Wisconsin State Auditor found that the controls            For example, Department of Defense (DoD) OIG
of their state’s Emergency Rental Assistance               found that the North American Aerospace Defense
program, funded by the Department of the Treasury          Command and U.S. Northern Command used
(Treasury), did not comply with Treasury’s guidance        $19.2 million of its CARES Act funds for purposes
that required documentation to verify eligibility.         that did not contribute to the overall federal and
Instead, Wisconsin’s Rental Assistance Program             agency priorities for the pandemic response. This
allowed individuals to provide a rental attestation        occurred because those commands did not have
form, signed by an individual and a landlord, and          sufficient controls in place to review and approve
an income attestation form in place of Treasury’s          expenditures related to the pandemic—instead they
required documentation to prove eligibility. In a          relied on existing controls, which did not require
random sample of 40 individuals who received               adequate support that goods and services aligned
benefits, 29 provided signed rental attestation forms      with guidance.
but not housing documentation, and 8 individuals
did not provide a signed rental attestation form or        HHS also did not update its controls to account
housing documentation at all, which may indicate           for new roles and responsibilities for public health
the applications were not compliant with federal or        services. HHS historically has been the primary
state guidance.                                            coordinator for emergency support functions
                                                           related to the public health and medical services,
                                                           but FEMA was assigned as the federal response
                                                           lead for COVID-19 instead of HHS. However, given
                                                           this difference, HHS did not update its controls to
                                                           properly identify the roles and responsibilities for
                                                           ventilator contracts. Therefore, HHS does not have
                                                           documentation to support decisions made by FEMA
                                                           that directly impact its procurement process.

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Alternatively, SBA OIG found that SBA updated               • Proper coordination among all stakeholders
its controls for verifying eligibility once Congress          during evacuations.
allowed the agency to use tax information. However,
SBA took four months to implement the new                   • Improved coordination and communication
controls. During that time, nearly $8.5 billion in EIDL       when changing policies that impact other
funds were disbursed, including $92 million issued            federal offices; and
to businesses with suspect Taxpayer Identification          • Proper assessment or re-evaluation of needed
Numbers.                                                      supplies or services.

Issues with modifying pandemic-related controls            For example, the Department of State OIG identified
also existed at the state level. For example, the          several good practices used by the Department
Alaska Legislative Auditor, which assessed their           of State to repatriate more than 800 Americans
state’s Small Business Relief Program, found               back to the United States from Wuhan, China at
that the eligibility requirements for the program          the beginning of the COVID-19 outbreak. These
changed multiple times over the course of the              practices include coordination with interagency
program. Program staff received directives to              partners, the development of a Wuhan Evacuation
speed up the approval process, since the program           Task Force, and compliance with existing crisis
design and the number of incomplete and/or                 response and planning policies and guidance.
inaccurate applications slowed disbursement. To            However, the Department of State OIG also
increase speed, several program requirements were          identified areas of improvement where coordination
inconsistently considered or enforced by program           between the Department of State and HHS deviated
operators. As a result, the Alaska State Auditor           from established practices—which resulted in
identified at least one error for 39 percent of the        challenges coordinating with state and local
grants it tested (155 grants), such as grant awards        partners that would be receiving the repatriated
exceeding amounts requested and grants being               Americans.
provided to unlicensed businesses.
                                                           A report by HHS OIG also highlighted the need
Key Insight 4: Assessing                                   to improve communication among government
                                                           agencies. The CDC did not comply with best
Emergency Planning                                         practices for coordinating overlapping programs
                                                           and initiatives and did not coordinate with the Office
Procedures Used During                                     of Refugee Resettlement to implement a public
the Pandemic Can Help                                      health order that significantly affected one of their
                                                           programs. When CDC issued a federal order that
Inform and Improve Future                                  required most non-citizen children entering the
                                                           United States without a parent be expelled to their
Emergency Responses                                        home country, the CDC did not notify the required
                                                           stakeholders in advance of the order. As a result,
During this reporting period, OIGs assessed some of        the Office of Refugee Resettlement was unable to
their agencies’ emergency planning and response            plan for how much care they may be required to
processes and identified good practices and areas          provide. HHS OIG recommended the agency take
for improvement or consideration for agencies’             steps to improve its internal communication and
overall emergency planning processes. These                coordination regarding unaccompanied children
include:                                                   and that HHS ensure that CDC coordinates with the

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Office of Refugee Resettlement when making future          A significant public health initiative during the
decisions that may affect unaccompanied children           pandemic was to ensure equitable access to
placed in the office’s care.                               vaccines. A recent DHS OIG report highlighted the
                                                           efforts by the Federal Emergency Management
In another example, the Department of Veterans             Agency to work with other federal agencies to use
Affairs (VA) Veterans Health Administration                the CDC Social Vulnerability Index to identify and
purchased 10,000 iPhones and more than 80,900              address inequalities in under-served communities’
iPads to help veterans experiencing homelessness           access to vaccination centers. The report also
or enrolled in supportive housing programs connect         showed how FEMA is modifying its strategic
to telehealth services. The VA OIG found that while        plan and plans to collect demographic data on
the program was laudable, VA OIG noted areas for           applicants to help target resources to under-served
improvement. Specifically, the agency paid $1.8            communities.
million in data plans for iPhones and $2.3 million
in data plans for iPads and iPhones while they were        Work by HHS OIG shows another example of
not in use or in storage. VA OIG recommended that          obtaining and using data to assess equity in federal
the program implementation could be improved by            programs. They completed a quantitative analysis to
turning on a data plan when there is an immediate          identify which communities used telehealth during
need.                                                      the first year of the pandemic. HHS OIG found that
                                                           beneficiaries in urban areas were more likely to
                                                           use this virtual service. Additionally, beneficiaries
Key Insight 5: Data Can                                    eligible for both Medicare and Medicaid, Hispanic
Help Inform the Design of                                  beneficiaries, younger beneficiaries, and female
                                                           beneficiaries were more likely than others to use
More Equitable Programs                                    telehealth. The findings could inform broader
                                                           expansion or design of future Medicare telehealth
Although the pandemic affected everyone, minority          services, and inform discussions on issues of health
and socioeconomically disadvantaged communities            care access, quality of care, cost, health equity, and
faced additional and unique challenges related to          program integrity.
public health risks, accessing medical expertise,
and obtaining federal benefits.                            The pandemic also had significant economic
                                                           impacts on different professional sectors and
During this reporting period, both agencies and            communities. The Oregon Audits Division found
oversight entities have used data to provide more          that disparities in processing UI claims could have
equitable services and inform program design,              occurred because communities of color were
respectively. In January 2021, President Biden             overrepresented in leisure and hospitality jobs
issued an Executive Order focused on advancing             which were significantly affected by the pandemic.
racial equity and support for under-served                 The state received a federal grant of more than
communities through government programs. The               $4.5 million to increase outreach and develop more
insights from the following reports can help program       robust data analysis to identify disparities and
managers implement more equitable federal                  provide more equitable services to under-served
emergency response programs.                               communities.




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Appendix A: Acronyms
CARES Act      Coronavirus Aid, Relief, and                MSLP              Main Street Lending Program
               Economic Security Act
                                                           OIG               Office of Inspector General
CDC            Centers for Disease Control and
               Prevention                                  OMB               Office of Management and Budget

CIGIE          Council of the Inspectors General           PACE              Pandemic Analytics Center of
               on Integrity and Efficiency                                   Excellence

COVID-19       novel coronavirus disease 2019              PPP               Paycheck Protection Program

DHS            Department of Homeland Security             PRAC              Pandemic Response Accountability
                                                                             Committee
DoD            Department of Defense
                                                           PUA               Pandemic Unemployment
DOJ            Department of Justice                                         Assistance

EIDL           Economic Injury Disaster Loan               SBA               Small Business Administration

EPA            Environmental Protection Agency             SQL               Structured Query Language

FAA            Federal Aviation Administration             Treasury          Department of the Treasury

FEMA           Federal Emergency Management                UI                Unemployment Insurance
               Agency
                                                           VA                Department of Veterans Affairs
HHS            Department of Health and Human
               Services

HUD            Department of Housing and Urban
               Development

IG             Inspector General

IRS            Internal Revenue Service




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Appendix B: Pandemic-Related
Reports by Office of Inspector General
Offices of Inspectors General (OIGs) issued a total of     COVID-19—Farmers to Families Food Box Program
114 reports between April 1, 2022, and September           Administration—Interim Report, 01801-0001-22(1),
30, 2022, related to the COVID-19 pandemic                 June 24, 2022
response. The following information provides a list
and summary of each of those reports.                      USDA Farmers to Families Food Box Program, 22-
                                                           001-01, June 22, 2022
U.S. Architect of the Capitol OIG
                                                           U.S. Department of Defense OIG
Architect of the Capitol’s COVID-19 Emergency
Supplemental Spending, OIG-AUD-2022-06,                    Audit of the DoD Certification Process for
July 25, 2022                                              Coronavirus Aid, Relief, and Economic Security
                                                           Act Section 4003 Loans Provided to Businesses
U.S. Board of Governors for the Federal Reserve            Designated as Critical to Maintaining National
System & Consumer Financial Protection                     Security, DODIG-2022-131, September 20, 2022
Bureau OIG
                                                           Audit of DoD Cooperative Agreements with
The CFPB Implemented Safety Measures in                    Coronavirus Aid, Relief, and Economic Security Act
Accordance with Its Reentry Plan, 2022-MO-C-011,           Obligations, DODIG-2022-102, June 8, 2022
September 21, 2022
                                                           Audit of North American Aerospace Defense
The Board Implemented Safety Measures in a                 Command and U.S. Northern Command Use of
Manner Consistent with Its Return-to-Office Plan,          Coronavirus Aid, Relief, and Economic Security Act
2022-MO-B-010, September 7, 2022                           Funding, DODIG-2022-098, May 17, 2022

U.S. Department of Agriculture OIG                         Audit of U.S. Indo-Pacific Command’s Execution of
                                                           Coronavirus Aid, Relief, and Economic Security Act
COVID-19—Oversight of the Emergency Food                   Funding, DODIG-2022-091, May 5, 2022
Assistance Program—Final Report, 27801-0001-21,
August 18, 2022                                            Evaluation of Department of Defense Military
                                                           Medical Treatment Facility Challenges During the
COVID-19 – Food Safety and Inspection Service              Coronavirus Disease-2019 (COVID-19) Pandemic in
Pandemic Response at Establishment, 24801-                 Fiscal Year 2021, DODIG-2022-081, April 5, 2022
0001-23, July 26, 2022
                                                           U.S. Department of Education OIG
COVID-19―Food and Nutrition Service’s Pandemic
Electronic Benefits Transfer―Interim Report, 27801-        The Department’s Use of Pandemic Assistance
0001-23(1), June 24, 2022                                  Program Administration Funds, F22DC0059,
                                                           September 27, 2022



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Allocation of ESSER I Funds at Selected Local              Certain Life Care Nursing Homes May Not
Educational Agencies, F20IT0049,                           Have Complied With Federal Requirements for
September 26, 2022                                         Infection Prevention and Control and Emergency
                                                           Preparedness, A-01-20-00004,
Michigan’s Administration of the Governor’s                September 19, 2022
Emergency Education Relief Fund, A20GA0039,
September 14, 2022                                         The IHS Telehealth System Was Deployed Without
                                                           Some Required Cybersecurity Controls, A-18-21-
Oklahoma’s Administration of the Governor’s                03100, September 9, 2022
Emergency Education Relief Fund, A20GA0011,
July 18, 2022                                              Certain Medicare Beneficiaries, Such as Urban
                                                           and Hispanic Beneficiaries, Were More Likely Than
The Office of Postsecondary Education’s Oversight          Others to Use Telehealth During the First Year of the
of Higher Education Emergency Relief Grant Funds,          COVID-19 Pandemic, OEI-02-20-00522,
A20CA0029, June 1, 2022                                    September 7, 2022

U.S. Department of Health and Human                        Medicare Telehealth Services During the First Year
Services OIG                                               of the Pandemic: Program Integrity Risks, OEI-02-
                                                           20-00720, September 7, 2022
HHS’s and HRSA’s Controls Related to Selected
Provider Relief Fund Program Requirements Could            HHS Did Not Fully Comply with Federal
Be Improved, A-09-21-06001, September 29, 2022             Requirements and HHS Policies and Procedures
                                                           When Awarding and Monitoring Contracts for
End-Stage Renal Disease Network Organizations’             Ventilators, A-02-20-02002, September 2, 2022
Reported Actions Taken in Response to the
COVID-19 Pandemic, A-05-20-00051,                          Certain Nursing Homes May Not Have Complied
September 23, 2022                                         With Federal Requirements for Infection Prevention
                                                           and Control and Emergency Preparedness, A-01-20-
FDA Repeatedly Adapted Emergency Use                       00005, July 26, 2022
Authorization Policies to Address the Need for
COVID-19 Testing, OEI-01-20-00380,                         CDC Found Ways to Use Data To Understand and
September 21, 2022                                         Address COVID-19 Health Disparities, Despite
                                                           Challenges With Existing Data, OEI-05-20-00540,
FDA’s Work with the Tri-Agency Task Force for              July 15, 2022
Emergency Diagnostics Helped Labs Implement
COVID-19 Tests, OEI-01-20-00381,                           An Estimated 91 Percent of Nursing Home Staff
September 21, 2022                                         Nationwide Received the Required COVID-19
                                                           Vaccine Doses, and an Estimated 56 Percent of
IHS’s National Supply Service Center Was Generally         Staff Nationwide Received a Booster Dose, A-09-22-
Effective in Providing Supplies to Facilities During the   02003, June 27, 2022
COVID-19 Pandemic, but Its Internal Controls Could
Be Improved, A-07-20-04124, September 20, 2022




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Office of Refugee Resettlement’s Influx Care Facility      FEMA Needs to Improve Its Oversight of the
and Emergency Intake Sites Did Not Adequately              Emergency Food and Shelter Program, OIG-22-56,
Safeguard Unaccompanied Children From                      August 10, 2022
COVID-19, A-06-21-07002, June 23, 2022
                                                           Violations of ICE Detention Standards at Folkston
Selected Dialysis Companies Implemented                    ICE Processing Center and Folkston Annex, OIG-22-
Additional Infection Control Policies and Procedures       47, June 30, 2022
to Protect Beneficiaries and Employees During the
COVID-19 Pandemic, A-05-20-00052, May 26 2022              ICE Did Not Follow Policies, Guidance, or
                                                           Recommendations to Ensure Migrants Were
HHS Should Improve Internal Coordination                   Tested for COVID-19 before Transport on Domestic
Regarding Unaccompanied Children, OEI-                     Commercial Flights, OIG-22-44, May 18, 2022
BL-20-00670, May 2, 2022
                                                           Lessons Learned from DHS’ Employee COVID-19
National Snapshot of Trends in the National                Vaccination Initiative, OIG-22-42, May 10, 2022
Domestic Violence Hotline’s Contact Data Before
and During the COVID-19 Pandemic, A-09-21-                 Management Alert - FEMA’s COVID-19 Funeral
06000, April 27, 2022                                      Assistance Operating Procedures Are Inconsistent
                                                           with Previous Interpretation of Long-Standing
U.S. Department of Homeland Security OIG                   Regulations for Eligible Funeral Expenses, OIG-22-
                                                           36, April 13, 2022
FEMA’s Management of Mission Assignments to
Other Federal Agencies Needs Improvement, OIG-             ICE Spent Funds on Unused Beds, Missed COVID-19
22-76, September 30, 2022                                  Protocols and Detention Standards while Housing
                                                           Migrant Families in Hotels, OIG-22-37,
FEMA Made Efforts to Address Inequities in                 April 12, 2022
Disadvantaged Communities Related to COVID-19
Community Vaccination Center Locations and Also            U.S Department of Housing and Urban
Plans to Address Inequity in Future Operations, OIG-       Development OIG
22-74, September 29, 2022
                                                           Fraud Risk Inventory for the Tenant- and Project-
More than $2.6 Million in Potentially Fraudulent           Based Rental Assistance, HOME, and Operating
LWA Payments Were Linked to DHS Employees’                 Fund Programs’ CARES and ARP Act Funds, 2022-
Identities, OIG-22-79, September 28, 2022                  FO-0007, September 29

A Review of FEMA Funding for Coronavirus Disease           Community Development Block Grant CARES
2019 (COVID-19) Response and Relief, OIG-22-72,            Act Implementation Challenges, 2022-LA-0003,
September 16, 2022                                         September 28, 2022

FEMA Did Not Implement Controls to Prevent                 Emergency Solutions Grants CARES Act
More than $3.7 Billion in Improper Payments from           Implementation Challenges, 2022-LA-0002,
the Lost Wages Assistance Program, OIG-22-69,              August 17, 2022
September 16, 2022



  Highlights        Background           Accomplishments       Accountability        Reports         Appendices


Pandemic Response Accountability Committee                                                                     34
                                                                                   Semiannual Report to Congress
                                                                                 APRIL 1, 2022 - SEPTEMBER 30, 2022




U.S. Department of the Interior OIG                        U.S. Department of Transportation OIG

The Three Affiliated Tribes Did Not Account for            FAA Quickly Awarded CARES Act Funds but Can
CARES Act Funds Appropriately, 2021–FIN–032–C,             Enhance Its Oversight Approach to Promote
September 28, 2022                                         Effective Stewardship, AV2022032, July 18, 2022

The Lower Brule Sioux Tribe Did Not Account for            U.S. Department of the Treasury OIG
CARES Act Funds Appropriately, 2021–FIN–032–A,
September 19, 2022                                         CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
                                                           PROGRAMS Audit of Air Carrier Worker Support
U.S. Department of Justice OIG                             Certifications - XOJET Aviation, LLC, OIG-22-041,
                                                           September 28, 2022
Audit of the Management and Coordination of
Pandemic-Related Fraud Allegations and Referrals           CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
Between the Criminal Division and Executive Office         PROGRAMS Audit of Air Carrier Worker Support
for U.S. Attorneys, 22-109, September 21, 2022             Certifications – Alpine Aviation, Inc., OIG-22-043,
                                                           September 28, 2022
U.S. Department of Labor OIG
                                                           CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
COVID-19: ETA and States Did Not Protect                   PROGRAMS: Audit of Air Carrier Worker Support
Pandemic-Related UI Funds from Improper                    Certifications - Pegasus Elite Aviation, Inc.,
Payments Including Fraud or from Payment Delays,           OIG-22-043, September 28, 2022
19-22-006-03-315, September 30, 2022
                                                           Inquiry on Use of Pandemic Relief Funds for
Alert Memorandum: Potentially Fraudulent                   Increased Broadband Access to Unserved
Unemployment Insurance Payments in High-Risk               Communities, OIG-CA-22-020, August 30, 2022
Areas Increased to $45.6 Billion, 19-22-005-03-
315, September 21, 2022                                    U.S. Department of Veteran Affairs OIG

Alert Memorandum: Employment and Training                  Comprehensive Healthcare Inspection Summary
Administration Needs to Ensure State Workforce             Report: Evaluation of Medication Management in
Agencies Report Activities Related to CARES Act            Veterans Health Administration Facilities, Fiscal
Unemployment Insurance Programs, 19-22-004-03-             Year 2021, 22-00814-230, September 1, 2022
315, August 2, 2022
                                                           The Veterans Health Administration Needs to Do
The U.S. Department of Labor Did Not Meet the              More to Promote Emotional Well-Being Supports
Requirements for Compliance, 22-22-007-13-001,             Amid the COVID-19 Pandemic, 21-00533-15,
July 1, 2022                                               May 10, 2022

U.S. Department of State OIG                               Purchases of Smartphones and Tablets for
                                                           Veterans’ Use during the COVID-19 Pandemic,
Review of Department of State Evacuations                  21-02125-132, May 4, 2022
from Wuhan, China in Response to COVID-19,
ISP-I-22-19, May 10, 2022


  Highlights        Background           Accomplishments        Accountability        Reports         Appendices


Pandemic Response Accountability Committee                                                                       35
                                                                                   Semiannual Report to Congress
                                                                                 APRIL 1, 2022 - SEPTEMBER 30, 2022




Comprehensive Healthcare Inspection of Facilities’         Alert Memorandum: PBS Did Not Test Water Prior to
COVID-19 Pandemic Readiness and Response in                Reopening GSA Child Care Centers Closed During
Veterans Integrated Service Networks 2, 5, and 6,          the COVID-19 Pandemic, A201018-8,
21-03917-123, April 7, 2022                                September 6, 2022

U.S. Election Assistance Commission OIG                    U.S. National Security Agency OIG

Audit of the Help America Vote Act Grants                  Audit of the Implementation of the Coronavirus Aid,
Awarded to the Commonwealth of Pennsylvania,               Relief, and Economic Security (CARES) Act, Section
G22PA0014-22-07, September 22, 2022                        3610, AU-20-0008, May 26, 2022

Audit of the Help America Vote Act Grants Awarded          Pandemic Response Accountability Committee
to the State of Delaware, G22DE0010-22-06,
September 21, 2022                                         Risk Advisory – Potential Identity or Other Fraud in
                                                           SBA Pandemic Relief Programs, PRAC-2022-08,
Audit of the Help America Vote Act Grants Awarded          September 20, 2022
to the State of Washington, G22WA0015-22-04,
September 6, 2022                                          Key Insights: Identity Fraud Reduction and Redress
                                                           in Pandemic Response Programs, PRAC-2022-07,
Audit of the Help America Vote Act Grants Awarded          June 13, 2022
to the State of Indiana, G22IN0011-22-03,
September 2, 2022                                          U.S. Postal Service OIG

Audit of the Help America Vote Act Grants Awarded          COVID-19 Test Kit Distribution, 22-076-R22,
to the State of Arizona, G22AZ0008-22-01,                  September 28, 2022
August 9, 2022
                                                           Coronavirus Aid, Relief, and Economic Security
Audit of the Help America Vote Act Grants Awarded          (CARES) Act Funding, 21-234-R22, July 7, 2022
to the State of Ohio, G22OH0013-22-02,
August 9, 2022                                             U.S. Railroad Retirement Board OIG

U.S. Environmental Protection Agency OIG                   The RRB Did Not Have Detailed Project Plans to
                                                           Expend Information Technology Modernization
The Coronavirus Pandemic Caused Schedule                   Funds, 22-10, June 29, 2022
Delays, Human Health Impacts, and Limited
Oversight at Superfund National Priorities List Sites,     U.S. Small Business Administration OIG
22-E-0049, June 23, 2022
                                                           SBA’s Guaranty Purchases for Paycheck Protection
U.S. General Services Administration OIG                   Program Loans, 22-25, September 30, 2022

COVID-19: PBS Faces Challenges in Its Efforts to           Follow-up Inspection of SBA’s Internal Controls to
Improve Air Filtration in GSA-Controlled Facilities,       Prevent COVID-19 EIDLs to Ineligible Applicants,
A201018P4R22008, September 30, 2022                        22-22, September 29, 2022




  Highlights        Background           Accomplishments        Accountability        Reports         Appendices


Pandemic Response Accountability Committee                                                                      36
                                                                                  Semiannual Report to Congress
                                                                                APRIL 1, 2022 - SEPTEMBER 30, 2022




COVID-19 and Disaster Assistance Information               Independent Review of 4003(b) Loan Recipient’s
Systems Security Controls, 22-19,                          Validation Memo – Mesa Airlines, Inc.,
September 27, 2022                                         SIGPR-A-22-003-9 August 2, 2022

Paycheck Protection Program Eligibility for Nonprofit      Independent Review of 4003(b) Loan
Organizations, 22-21. September 26, 2022                   Recipient’s Validation Memo – Map Large, Inc.,
                                                           SIGPR-A-22-003-8, July 11, 2022
COVID-19 Economic Injury Disaster Loan
Applications Submitted from Foreign IP Addresses,          Independent Review of 4003(b) Loan
22-17, September 12, 2022                                  Recipient’s Validation Memo – United Airlines,
                                                           SIGPR-A-22-003-7, June 22, 2022
SBA’s Award and Payment Practices in the Shuttered
Venue Operators Grant Program, 22-15, July 5,              Independent Review of 4003(b) Loan Recipient’s
2022                                                       Validation Memo – SkyWest Airlines, Inc.,
                                                           SIGPR-A-22-003-6, June 2, 2022
SBA’s Handling of Potentially Fraudulent Paycheck
Protection Program Loans, 22-13, May 26, 2022              Alert Memorandum: Delays in the Quarterly
                                                           Monitoring of Borrowers’ Compliance with Loan
Evaluation of SBA’s Disaster Assistance Loan               Requirements, SIGPR-A-22-002-1, May 24, 2022
Recommendation Services, 22-10, April 14, 2022
                                                           Independent Review of 4003(b) Loan Recipient’s
U.S. Social Security Administration OIG                    Validation Memo – Hawaiian Airlines, Inc.,
                                                           SIGPR-A-22-003-5, May 19, 2022
Summary of the Audit of the Social Security
Administration’s Information Security Program and          Independent Review of 4003(b) Loan Recipient’s
Practices for Fiscal Year 2022, A-14-22-51179,             Validation Memo – JetBlue Airways Corporation,
September 30, 2022                                         SIGPR-A-22-003-4, April 28, 2022

The Social Security Administration’s Enumeration           Independent Review of 4003(b) Loan
Services During the COVID-19 Pandemic, A-15-21-            Recipient’s Validation Memo – SpinLaunch, Inc.,
51015, September 30, 2022                                  SIGPR-A-22-003-12, September 27, 2022

The Social Security Administration’s Mail Processing       Independent Review of 4003(b) Loan Recipient’s
During the COVID-19 Pandemic, A-08-21-51115,               Validation Memo – Republic Airways, Inc.,
May 13, 2022                                               SIGPR-A-22-003-11, September 14, 2022

U.S. Special Inspector General for Pandemic                U.S. Treasury Inspector General for Tax
Recovery                                                   Administration

Independent Review of 4003(b) Loan Recipient’s             Mainframe Platform Configuration Compliance
Validation Memo – Meridian Rapid Defense Group,            Controls Need Improvement, 2022-20-050,
LLC, SIGPR-A-22-003-10, August 4, 2022                     September 30, 2022




  Highlights        Background           Accomplishments       Accountability        Reports         Appendices


Pandemic Response Accountability Committee                                                                     37
                                                                                  Semiannual Report to Congress
                                                                                APRIL 1, 2022 - SEPTEMBER 30, 2022




Reporting on the Use of Coronavirus Response               Final Report – The IRS Leveraged Its Telework
Funding Could Be Enhanced, 202110624,                      Program to Continue Operations During the
September 22, 2022                                         COVID-19 Pandemic, 2022-IE-R003, May 23, 2022

American Rescue Plan Act: Accuracy of Advance              Processing of Recovery Rebate Credit Claims During
Child Tax Credit Periodic Payments, 2022-47-070,           the 2021 Filing Season, 2022-46-032,
September 21, 2022                                         May 19, 2022

Delays in Management Actions Contribute to the             The Child Tax Credit Update Portal Was Successfully
Continued Tax Processing Center Backlogs, 2022-            Deployed, but Security and Process Improvements
46-057, September 16, 2022                                 Are Needed, 2022-27-028, May 18, 2022

The IRS’s Inability to Keep Pace with Non-Corporate        American Rescue Plan Act: Implementation of
Applications for Refund of Net Operating Losses            Premium Tax Credit Provisions, 2022-47-034,
Under the CARES Act Has Cost Taxpayers Millions            May 2, 2022
of Dollars in Additional Interest, 2022-36-048,
September 7, 2022

The IRS Effectively Planned to Use and Provide
Oversight of the American Rescue Plan Act Funds;
However, Subsequent Reallocation of Modernization
Funds Resulted in Significant Replanning,
2022-27-045, September 2, 2022

Compliance Efforts Are Needed to Address Refund
Claims Reported on Form 1139 That Are Based
on the CARES Act Net Operating Loss Carryback
Provisions, 2022-35-049, August 31, 2022

Delays Continue to Result in Businesses Not
Receiving Pandemic Relief Benefits, 2022-46-059,
August 31, 2022

American Rescue Plan Act: Assessment of the Child
Tax Credit Update Portal’s Capabilities and Related
Processes, 2022-47-02, July 25, 2022

Fingerprinting and Employment Eligibility
Verification Delays Due to the COVID-19 Pandemic
May Increase Taxpayer Data Exposure Risks,
2022-16-039, July 7, 2022




  Highlights        Background           Accomplishments       Accountability        Reports         Appendices


Pandemic Response Accountability Committee                                                                     38
Appedix C: Hotline Data
Since inception, the PRAC received most of its hotline complaints through its electronic complaint form.
The PRAC’s hotline provides an avenue for concerned citizens to report potential fraud, waste, abuse, and
mismanagement related to the pandemic response, including the CARES Act and other related legislation.

During the reporting period, we received 1,705 hotline communications, of which 500 were filed for
information or not actionable. The remaining 1,205 were deemed potentially actionable for fraud, waste,
abuse, or mismanagement. From these, the PRAC forwarded 1,241 allegations to 16 different OIGs for review
and appropriate action. Referrals might be sent to more than one OIG based on the allegation(s) referenced,
resulting in the slightly higher number reported here.




  Highlights        Background           Accomplishments    Accountability       Reports        Appendices


Pandemic Response Accountability Committee                                                                  39
             For more information:
                        Lisa Reijula
  Associate Director of Outreach and Engagement, PRAC
                  Lisa.Reijula@cigie.gov


                      Visit us at:
                 PandemicOversight.gov


                    Follow us at:
                      @COVID_Oversight


Report Fraud, Waste, Abuse, or Misconduct:
     To report allegations of fraud, waste, abuse, or
 misconduct regarding pandemic relief funds or programs
            please go to the PRAC website at
                 PandemicOversight.gov.




                     A Committee of the
               Council of the Inspectors General
                  on Integrity and Efficiency


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