We recommend AOC management develop a process that will assess and monitor payment accuracy in its program and activities: 1. The process should include procedures to identify and assess all programs and activities that are susceptible to significant improper payments annually (max triennially). 2. For programs and activities identified as susceptible to significant improper payments, the AOC should consider the following procedures using the Office of Management and Budget guidance: i. Perform testing to estimate the cost of improper payments in the program; ii. Implement a plan to reduce erroneous payments; iii. Report estimates of the annual amount of improper payments in programs and activities and progress toward reducing them within the Performance and Accountability Report.