Open Recommendations

Office of Programs should Ensure that the other compensating controls for detecting and preventing
unemployment and sickness improper payments are operating effectively.

Bureau of Fiscal Operations should Develop and document compensating controls to determine if employee pay
is calculated using the correct gross pay amount and is supported with source documentation available to the
Bureau of Fiscal Operations. If improper gross pay amounts are identified, determine the root cause, and
take action to resolve the improper pay amounts.

Office of Programs should Reach out to Centers for Medicare & Medicaid Services to discuss how
Railroad Medicare improper payment reporting could be more transparent.

Bureau of Fiscal Operations should work with the Office of Programs to establish one assessable unit for payment integrity. This assessable unit should address payment integrity risks and controls across both organizations. Both the certifying official for Bureau of Fiscal Operations and the Office of Programs should certify their organization’s improper payment controls within the new assessable unit.

Direct USAC to conduct an in-depth root cause analysis for IPs related to missing or insufficient documentation used to support the carriers’ submission of continuing property records and depreciation/amortization information for USF-HC Legacy. USAC should continue to engage with carriers to understand systemic issues contributing to these types of IPs. USAC should develop targeted corrective actions based on the findings.

Enhance oversight of the USF-HC Legacy program by increasing the frequency of monitoring and reviewing carrier-reported data. For example, implement interim random sampling of payments or use AI to identify and detect patterns of non-compliance.

Develop a phased reduction target plan for the USF-HC Legacy program with clear milestones and accountability measures to ensure it is realistic and achievable based on past performance and current challenges.

Implement a more rigorous internal review process for IP reporting to include performing quarterly validation reviews to detect and prevent errors in identified IP amounts before reports are finalized. Further, all quarterly validation reports should be reconciled against the final annual report to identify and resolve discrepancies prior to the data call submission.

Introduce a secondary review or correction window between FCC and USAC before finalizing reports for the OMB data call.

Revise the outstanding categories in the FY 2025 data call submission to reflect the correct recovery audit amounts outstanding.

We recommend that FNS continue to carry out the plan described in its S&EMP in order to publish IP and UP estimates for FNS SFSP in the accompanying materials to future annual financial statements, which includes PaymentAccuracy.gov. In the meantime, we recommend that FNS evaluate if some payments should be considered unknown payments by devising a method to determine the amount of potential IPs and report these as UPs until the above-mentioned methodology has been finalized. If FNS is unable to devise a method to do this, we recommend that this is disclosed in PaymentAccuracy.gov.
For each year of non-compliance…

We recommend FNS continue its efforts to develop an improved estimate that considers meal counting errors in the publication of a complete improper payment rates for the FNS CACFP-FDCH program and update its S&EMP to consider payments that have not been determined as either proper or improper during their analysis, as unknown payments.
For each year of non-compliance:
FNS should provide information for SFSP describing the actions that the agency will take to come into compliance. This information should be published on PaymentAccuracy.gov and serve as the plan for what FNS will submit to the appropriate authorizing and appropriations committees…

We recommend USDA and FSA update its policies and procedures over the reporting of expiring programs to identify and report root causes of improper payments in order to formulate corrective actions that are focused on the core issues that are under the control of the agency.

FSA: We recommend that management take the following actions to ensure compliance with the Payment Integrity Information Act of 2019:
• Maintain a focus on continuous improvement in the development and implementation of new mitigation strategies (e.g., examination of existing controls in place and the implementation of more effective controls) to decrease IP and UP rates to a tolerable rate each year. If a program’s IP and UP rate does not improve or increases, take sufficient steps to identify root causes and implement appropriate corrective action that will reduce the rates year over year until the rate is below 10%…

FNS: We recommend that the agency work with OCFO in taking the following actions to ensure compliance with the Payment Integrity Information Act of 2019:
• Maintain a focus on continuous improvement in the development and implementation of new mitigation strategies (e.g., examination of existing controls in place and the implementation of more effective controls) to decrease IP and UP rates to a tolerable rate each year. If a program’s IP and UP rate does not improve or increases, take sufficient steps to identify root causes and implement appropriate corrective action that will reduce the rates year over year until…

FSA: We recommend that the agency work with OCFO in taking the following actions to ensure compliance with the Payment Integrity Information Act of 2019:
• Improve processes and efforts to evaluate the effectiveness of corrective actions to assist in the reduction of the improper payments estimate rate below the 10% threshold
• Develop and monitor agency-level corrective actions corresponding to the identified root causes of improper payments
• Conduct ongoing monitoring of the state-level corrective actions and ensure that these corrective actions are being implemented
• Continue working with states to identify state-specific corrective action plans and ensure that…

FNS: We recommend that the agency work with OCFO in taking the following actions to ensure compliance with the Payment Integrity Information Act of 2019:
• Improve processes and efforts to evaluate the effectiveness of corrective actions to assist in the reduction of the improper payments estimate rate below the 10% threshold
• Develop and monitor agency-level corrective actions corresponding to the identified root causes of improper payments
• Conduct ongoing monitoring of the state-level corrective actions and ensure that these corrective actions are being implemented
• Continue working with states to identify state-specific corrective action plans and ensure that…

We recommend that the Chief Financial Officer for the Department, in conjunction with the acting Chief Financial Officer for FSA, develop sampling and estimation plans for the Pell and Direct Loan programs that will produce reliable estimates. Specifically, the plan should (a) produce appropriate and accurate confidence intervals around a statistically valid point estimate; (b) consistent with 31 U.S.C. section 3352(c)(1)(A), produce an estimate that is otherwise appropriate using a methodology approved by the Director of OMB; or (c) consistent with OMB Circular A-123 Appendix C Part II B(2), include a detailed explanation as to why it is not possible…

Rec. 1.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, develop and implement a tool to improve the Office of the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoDs oversight of the programs that includes a method for establishing new programs, including how it determines the date of establishment.

Rec. 1.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, determine whether payments associated with disaster emergency funds should be considered as a high?risk payment type identified within the DoDs Payment Integrity portfolio. If so, develop a methodology to publicly report the improper payments associated with the DoDs use of disaster emergency funds.

Rec. 1.c: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, submit for the Military Health Benefits"TRICARE East Region Program; Military Health Benefits"TRICARE West Region Program; Military Health Benefits"TRICARE Medicare Eligible Program; Military Pay Army"National Guard, Civilian Pay"Army, Civilian Pay"Other Defense Organization, DoD Travel Pay Army"Defense Travel System, DoD Travel Pay Navy"Defense Travel System, DoD Travel Pay Department of the Air Force"Defense Travel System, and Commercial Pay"Mechanization of Contract Administration Services programs to the Office of Management and Budget, the planned actions that the DoD will take to come into compliance, including actions to: Develop…

Rec. 2: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with DoD Components, develop and implement a methodology to: Identify all DoD outlays and the programs with which they are associated. Verify that the programs universes of payment transactions include all outlays related to each respective program.

Rec. 3: The DoD OIG recommended that the Assistant Secretary of the Navy (Financial Management and Comptroller) reevaluate the DoD Travel Pay Navy"Defense Travel System program and report the programs estimates in the appropriate Payment IntegrityInformation Act reporting phase.

Rec. 4.a: The DoD OIG recommended that the Director of the Defense Health Agency, in future risk assessment methodologies reassess the Military Health Benefits"TRICARE East Region Program, Military Health Benefits"TRICARE West Region Program, and Military Health Benefits"TRICARE Medicare Eligible Program to fully document and support the specific information it relied on, including the internal controls.

Rec. 4.b: The DoD OIG recommended that the Director of the Defense Health Agency, in future risk assessment methodologies: reassess the risk of the TRICARE programs if the Government Accountability Office requires public reporting of the results of the medical records reviews to close its recommendation.