Open Recommendations

Ensure that program officials periodically provide all FSM CORs and staff involved in the monitoring process uniform property inspection training.

Update review procedures to ensure accurate responses to Office of Management and Budget (OMB) payment integrity data call prompts, compliance with the Payment Integrity Information Act of 2019, and that information is complete, accurate, and consistent before the final submission of the OMB payment integrity data call; and further refine reviews of published information on PaymentAccuracy.gov.

Maintain the Employment and Training Administration’s current focus on increasing technical assistance and funding to states to improve improper payment reduction strategies to reduce the improper payments estimate rate below the 10 percent threshold.

Update the Employment and Training Administration’s policies and procedures over the reporting of Federal Pandemic unemployment Compensation, Pandemic Emergency Unemployment Compensation, and Pandemic Unemployment Assistance information to include outlays after the expiration of the programs, until such time as the outlays are no longer greater than the statutory threshold.

District leaders and the Evanston, La Crosse, and Milwaukee Vet Center Directors collaborate with the support VA medical facility to determine reasons for noncompliance with staff participation on the mental health executive council, take action as indicated, and monitor compliance.

District leaders and the Evanston, Gary Area, La Crosse, and Milwaukee Vet Center Directors determine reasons for noncompliance with completing four hours of external clinical
consultation for clinically complex cases per month, ensure a process is implemented, and monitor compliance.

District leaders and the Gary Area Vet Center Director determine reasons for noncompliance with Vet Center Director review of 10 percent of active client records monthly for each counselors caseload, ensure completion, and monitor compliance.

District leaders and the Gary Area, La Crosse, and Milwaukee Vet Center Directors determine reasons for noncompliance with employees completing select trainings in the required time frame, ensure completion, and monitor compliance.

District leaders and the Evanston, Gary Area, and Milwaukee Vet Center Directors determine reasons for noncompliance with completion of an outreach plan with all required strategic
components, ensure completion, and monitor compliance.

District leaders and the La Crosse Vet Center Director determine reasons for noncompliance with monthly automated external defibrillator inspections, ensure completion, and monitor compliance.

District leaders determine reasons why the closing of the Milwaukee Vet Center resulted in multiple communication failures, and ensure all clients are notified of the new location, the Vet Center Call Center has accurate information, and websites include correct location and phone number information.

The Readjustment Counseling Service Chief Officer considers developing written guidance for vet center closure and temporary relocation processes including oversight responsibilities.

Office of Programs should Document its consideration of potential risks of not performing the quarterly
Railroad Unemployment Insurance Act quality assurance review procedures. This documentation should
include both quantitative and qualitative risks.

Office of Programs should Document the compensating controls or alternative procedures which will be performed
timely to mitigate the risks of not performing the quarterly assurance review procedures, as designed.

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.

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…