We recommend that the Chief Financial Officer for the Department, in conjunction with the Chief Financial Officer for FSA—Develop and implement procedures to ensure that the Department’s improper payment estimates for the Pell and Direct Loan programs are based on, and represent, quality information. Specifically, evaluate the data used to determine whether it is relevant (for example, estimates are based on sustained questioned costs rather than questioned costs identified in compliance audits); reliable (for example, the quality of any supplemental data, if used for the estimates, has been evaluated); and appropriate (for example, estimates are based on randomly selected student-level samples from compliance audits).