2. EEOC should develop an agency-wide Improper Payment risk assessment standard operating procedures (SOP). This SOP should include risk assessment procedures to be performed by each identified significant program. These procedures should be based on OMB A-123 guidance found in Appendix C. For each identified significant program, a responsible program point of contact should be established. The responsible party should report results of their programs risk assessment to the EEOC responsible official (or office);