To ensure improper payment reporting is consistent with OMB A-123 Appendix C, we recommend that management include language in the IP risk assessment to expressly address both IPs and UPs and whether either may have occurred above or below the statutory threshold. We recognize that the agency did not expressly reference UPs because none were identified. However, doing so would better align with OMB’s standard language, which provides that the agency adequately concluded whether the program is not likely to make IPs and UPs above or below the statutory threshold.