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    Subject Term: "Debt collection"

    13 publications with a total of 48 open recommendations including 5 priority recommendations
    Director: Michael Clements
    Phone: (202) 512-8678

    1 open recommendations
    Recommendation: To promote transparency and accountability of federal spending, the Commissioner of the Fiscal Service should make basic information about Fiscal Service's use of financial agents publicly available in a central location, including compensation paid to each financial agent under its financial agency agreement and a description of the services provided.

    Agency: Department of the Treasury: Bureau of the Fiscal Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Allison Bawden
    Phone: (202) 512-7215

    6 open recommendations
    Recommendation: To preserve the balance between the importance of repaying federal student loan debt and protecting a minimum level of Social Security benefits put in place by the Debt Collection Improvement Act of 1996, Congress should consider modifying Social Security administrative offset provisions, such as by authorizing the Department of the Treasury to annually index the amount of Social Security benefits exempted from administrative offset to reflect changes in the cost of living over time.

    Agency: Congress
    Status: Open

    Comments: As of August 2017, Congress has not yet taken action on this matter.
    Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should inform affected borrowers of the suspension of offset and potential consequences if the borrower does not take action to apply for a TPD discharge. Such information could include notification that interest continues to accrue and that offsets may resume once their disability benefits are converted to retirement benefits.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education does not currently notify borrowers of the suspension of offset, but plans to implement a process to do so in the future using a new mailing sent to affected borrowers by their default servicer. The current budget situation does not allow for this type of enhancement, and it is not clear when that will change. In the interim, the agency is exploring alternative notification approaches that could be put in place prior to the implementation of an automated solution. We will monitor the agency's progress.
    Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should revise forms sent to borrowers already approved for a TPD discharge to clearly and prominently state that failure to provide annual income verification documentation during the 3-year monitoring period will result in loan reinstatement.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education stated that the current Office of Management and Budget (OMB) TPD-Post discharge forms contain the recommended language in the first bullet of the Earned Income Section. In order to more clearly provide this information they recommended that the new OMB form, which is in its public comment period, (1) use a larger font size for the form and (2) use "plain language." GAO will consider closing this recommendation when the agency has completed this effort.
    Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should evaluate the feasibility and benefits of implementing an automated income verification process, including determining whether the agency has the necessary legal authority to implement such a process.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education stated that over the next six months, they are committed to working with SSA to determine the feasibility and benefits of implementing an automated income verification process. The verification will address both the legal authority to implement such a process as well as operational and budgetary feasibility. We will monitor the agency's progress.
    Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should inform borrowers about the financial hardship exemption option and application process on the agency's website, as well as the notice of offset sent to borrowers.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education agrees with the recommendation and said that they will include this change in upcoming revisions to the agency's web content. The agency reported that the Notice of Offset to borrowers is sent by Treasury and that they will share this recommendation with Treasury and discuss possible changes to the notice. We will consider closing this recommendation when the agency has completed this effort.
    Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should implement an annual review process to ensure that only eligible borrowers are exempted from offset for financial hardship on an ongoing basis.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education reported that it plans plan to fully automate their process for tracking hardships and other exceptions from offset. However, due to competing priorities and funding limitations, full implementation of these improvements have not been scheduled. As they fully implement this process, they will review complementary strategies to assist borrowers in complying with annual reporting requirements. We will monitor the agency's progress.
    Director: James McTigue
    Phone: (202) 512-9110

    5 open recommendations
    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and communicate Field Collection program and case selection objectives, including the role of fairness, in clear and measurable terms sufficient for use in internal control.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation and described actions it will take to address it, to include that the Small Business/Self-Employed Division (SB/SE) will develop fiscal year 2017 program objectives that align with the mission of SB/SE and that the Collection program will develop and document specific Field Collection and case selection activities that will support SB/SE objectives. However, it is not clear how these efforts will be fully responsive our recommendation to establish Field Collection (not division-level) program and case selection objectives sufficient for use in internal control. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.
    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and implement performance measures clearly linked to the Field Collection program and case selection objectives.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation and outlined planned actions to address it. However, since it is not clear that IRS's planned actions to implement our first recommendation will result in Field Collection program and case selection objectives sufficient for internal control purposes, IRS's ability to address the related recommendation to establish performance measures may be limited. IRS said it planned to complete actions on this recommendation by August 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.
    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should incorporate program and case selection objectives into existing risk management systems or use other approaches to identify and analyze potential risks to achieving those objectives so that Field Collection can establish risk tolerances and appropriate control procedures to address risks.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation and outlined planned actions to address it. However, since it is not clear that IRS's planned actions to implement our first recommendation will result in Field Collection program and case selection objectives sufficient for internal control purposes, IRS's ability to address the related recommendation to assess program risks may be limited. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.
    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and communicate control procedures guidance for group managers to exercise professional judgment in the Field Collection program case selection process to achieve fairness and other program and collection case selection objectives.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation and described actions it will take to address it, to include review of current procedures and guidance and making changes, if necessary. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.
    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and implement procedures to periodically monitor and assess the design and operational effectiveness of both automated and manual control procedures for collection case selection to assure their continued effectiveness in achieving program objectives.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation and outlined planned actions to address it. However, since it is not clear that IRS's planned actions to implement our first recommendation will result in Field Collection program and case selection objectives sufficient for internal control purposes, IRS's ability to address the related recommendation to monitor control procedures may be limited. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of implementation of the recommendation after we complete review of documents IRS provides on the actions taken.
    Director: Kimberly M. Gianopoulos
    Phone: (202) 512-8612

    3 open recommendations
    Recommendation: To better manage the AD/CV duty liquidation process, CBP should issue guidance directing the Antidumping and Countervailing Duty Centralization Team to (a) collect and analyze data on a regular basis to identify and address the causes of liquidations that occur contrary to the process or outside the 6-month time frame mandated by statute, (b) track progress on reducing such liquidations, and (c) report on any effects these liquidations may have on revenue.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP concurred with this recommendation and said it would take steps to implement it. CBP has issued guidance requiring the collection, analysis, and reporting of AD/CV data to identify and address the causes of liquidations that occur contrary to the process or outside the 6-month time frame mandated by statute, as GAO recommended in July 2016. CBP is analyzing the results of its fiscal year 2017 self-inspection program to assess its progress on reducing such liquidations and report on the revenue effect. CBP expects to complete its analysis by Fall 2017. Systematically collecting and analyzing liquidation data on a regular basis to identify and address the causes of untimely liquidations and tracking and reporting on progress toward reducing such liquidations could help CBP reduce revenue loss.
    Recommendation: To improve risk management in the collection of AD/CV duties and to identify new or changing risks, CBP should regularly conduct a comprehensive risk analysis that assesses both the likelihood and the significance of risk factors related to AD/CV duty collection. For example, CBP could construct statistical models that explore the associations between potential risk factors and both the probability of nonpayment and the size of nonpayment when it occurs.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP concurred with this recommendation and said it would take steps to implement it. As of September 2017, CBP had not regularly conducted a risk analysis that assesses both the likelihood and significance of risk factors related to AD/CV duty collection, as GAO recommended in July 2016. However, CBP was in the process of developing a model to enable it to conduct such a risk analysis on a regular basis. CBP expects to test the model by Fall 2017; however, CBP officials said that full implementation of the model will not take place until the end of fiscal year 2018 due to the complexity of the project. CBP officials noted that they are working to hire additional staff to dedicate to model development; acquire a dedicated server for processing data to regularly update the models; and identify other CBP programs that would benefit from risk models similar to the ones they are developing for AD/CV duties. Regularly conducting a comprehensive risk analysis of factors related to AD/CV duty non-collection could enhance CBP's capacity to collect additional revenue. For example, it could result in the identification of new factors generating a requirement for an importer to provide additional security in the form of bonds as part of an enhanced bonding requirement.
    Recommendation: To improve risk management in the collection of AD/CV duties, CBP should, consistent with U.S. law and international obligations, take steps to use its data and risk assessment strategically to mitigate AD/CV duty nonpayment, such as by using predictive risk analysis to identify entries that pose heightened risk and taking appropriate action to mitigate the risk.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP concurred with this recommendation and said it would take steps to implement it. As of September 2017, CBP was in the process of developing a risk analysis model to use in mitigating AD/CV duty nonpayment, as GAO recommended in July 2016. The model will use predictive risk analysis to identify entries that pose a heightened risk of nonpayment. CBP has contacted the Customs Surety Association and the Commercial Customs Operations Advisory Committee to discuss bonding options to help mitigate the risk of nonpayment. Developing a risk analysis model to use in mitigating AD/CV duty nonpayment could enhance CBP's capacity to collect additional revenue. For example, it could be used to identify entries from importers requiring additional security in the form of bonds as part of an enhanced bonding requirement.
    Director: Daniel Bertoni
    Phone: (202) 512-7215

    7 open recommendations
    including 1 priority recommendation
    Recommendation: To improve transparency in reporting processing errors, SSA should provide additional information on the margins of error or confidence intervals, and clearly identify any limitations in its findings on overpayment information provided to Congress and the public.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and reported in January 2016 that it would include a discussion about the limitations of error deficiencies data in future reports. To help close this recommendation, SSA will need to report any limitations, such as small sample sizes, that would affect the reliability of its estimates of DI improper payments due to specific types and causes of errors. Although SSA provided recommendation updates on this report in April 2017, it did not comment on this particular recommendation.
    Recommendation: To minimize the potential effect of vulnerabilities in the work reporting process, SSA should take steps to help ensure that work information is entered directly into eWork, the system of record for work information, and issue required receipts. Such steps could include: (a) Improving and issuing guidance and training to field and 800- number staff to help ensure they log information into eWork and issue required receipts. (b) Establishing policies to monitor alerts to help ensure that work information for concurrent beneficiaries is reflected in SSI and DI systems, and take steps to monitor and make enhancements to systems or guidance, as needed.

    Agency: Social Security Administration
    Status: Open

    Comments: In April 2017, SSA reported that it updated training to Field and Processing Center staff and issued an administrative message to staff to remind them about issues related to overpayments and waivers. SSA also reported that, as part of its implementation of Section 826 of the Bipartisan Budget Act of 2015 (P.L.114-74), it is creating a business process and building an internet work reporting system that will allow both SSDI beneficiaries and SSI recipients to report work and earnings electronically. According to SSA, this system will determine the individual's entitlement and automatically forward the work report to the appropriate staff for processing CDR decisions. To close this recommendation, SSA will need to provide documentation that shows the agency provided training and reminders to staff, and that the agency implemented a mechanism that ensures work information for concurrent beneficiaries is reflected in both SSI and DI systems.
    Recommendation: To further ensure the effective screening of work reports, SSA should monitor its process for handling work reports to determine whether staff are taking action on work reports in accordance with proper procedures, and provide feedback to staff as needed.

    Agency: Social Security Administration
    Status: Open

    Comments: In its April 2017 update, SSA continued to disagree with this recommendation. SSA stated that the outcome of a work continuing disability review (CDR) is not dependent on the accuracy of the work report. However, as we noted in our report, inaccurate work reports may result in overpayments or work receipts (which are required by law) to not be issued. Further, pending work reports may be closed inappropriately without resulting in a work CDR. To help close this recommendation, SSA will need to show how it plans to monitor its process for handling work reports to determine compliance with agency procedures, and how feedback, if any, will be provided to staff.
    Recommendation: To enhance the ease and integrity of the work reporting process, SSA should study the costs and benefits of automated reporting options, including options similar to those currently available for SSI recipients, but that do not go as far as automating the continuing disability review process.

    Agency: Social Security Administration
    Status: Open

    Comments: In April 2017, SSA reported that the agency has made progress on two fronts, which could enhance the ease and integrity of its work reporting process, both pursuant to the Bipartisan Budget Act of 2015 (BBA). In response to Section 826 of BBA, which requires SSA to permit Disability Insurance (DI) beneficiaries to report their earnings via electronic means similar to what is available for SSI recipients, SSA reported that it has drafted a business process to build an Internet and wage reporting system for SSDI beneficiaries. SSA also noted that this business process contains plans for an Internet work reporting system that will allow both SSDI and SSI recipients to report work and earnings electronically and will automatically forward the work report to either SSI or eWork (for DI beneficiaries), and will automatically generate a receipt to the beneficiary. SSA has also completed a business process for Section 824 of the BBA, which allows SSA to contract with third party payroll providers to receive earnings in a monthly file. SSA reported that these data will allow SSI to automate benefit adjustments based on the monthly earnings report, and for DI, the information will be incorporated into the agency's Work Smart process--a new technique that combines several business processes into one unified approach to identify cases in need of a work continuing disability review. To help close this recommendation, SSA will need to provide documentation of its proposed business process for building Internet and telephone wage reporting systems for DI beneficiaries.
    Recommendation: To enhance beneficiary understanding of work reporting requirements, SSA should: (a) Clarify work reporting requirements provided to beneficiaries. (b) Explore options for increasing the frequency of reporting reminders to DI beneficiaries, similar to those currently available to SSI recipients.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and noted in January 2016 that it plans to assess its method of communication and explore options to strengthen its message to Disability Insurance (DI) beneficiaries regarding the importance of consistent wage reporting. The agency also plans to consider whether direct phone outreach, currently being piloted to improve wage reporting for SSI recipients, would be appropriate for the DI program. In its April 2017 update, SSA indicated progress toward: updating policies and procedures related to "treatment of earnings derived from services," implementing a commercial payroll data exchange pursuant to section 824 of the BBA, and implementing electronic reporting of earnings pursuant to section 826 of the BBA. While the agency's actions to implement BBA requirements may improve program administration, SSA did not explain how these actions or its efforts to update to policies and procedures related to "treatment of earnings derived from services" would clarify work reporting requirements for or increase the frequency of reporting reminders to DI beneficiaries. SSA also did not provide an update on its plans to assess communication and explore options, as it reported in January 2016. To help close this recommendation, SSA will need to show how these or other actions taken clarify work reporting requirements for and increase reporting reminders for DI beneficiaries.
    Recommendation: improve compliance with waiver policies, SSA should develop a timetable for implementing updates to its Debt Management System to: (a) Align system controls with SSA policy, so that waivers over $1,000 cannot be administratively waived. (b) Ensure that evidence supporting waiver decisions is sufficiently maintained to allow for subsequent monitoring and oversight.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: According to SSA, in February 2016, the agency implemented an edit to the Debt Management System remarks that amended a deficiency in the system that prevented system remarks from being deleted after a case is closed. The edit locks Debt Management System remarks to prevent technicians from overwriting existing remarks in closed cases. With respect to ensuring that overpayments over $1,000 cannot be administratively waived, SSA reported in November 2016 that it will provide a timeline for and take steps to update the Debt Management System when the agency obtains resources to fund the update. SSA reported in April 2017 that its ability to update system controls to align with SSA policy was dependent on resources. To help close this recommendation, SSA will need to show its plans and time frames for updating system controls to align them with SSA policy.
    Recommendation: To improve compliance with waiver policies, SSA should take steps to regularly assess the accuracy of DI waiver decisions, particularly for administrative waivers and for some waivers under $2,000. This could include periodically reviewing approved and denied DI waivers through its continuous quality initiative.

    Agency: Social Security Administration
    Status: Open

    Comments: In August 2016, the agency reported that it had taken several actions, including producing a comprehensive training series on overpayment and waiver policy and procedures, building a policy cluster to serve as a "one-stop resource shop" of policy references and tools for technicians, and clarifying agency policies including the Administrative Tolerance Decision Tree to assist technicians with making appropriate low-dollar overpayment waiver decisions. The agency also reported that its Continuous Quality work group continues to review the accuracy of waivers under Title II of the Social Security Act. Based on these efforts, in November 2016, SSA reported that it has closed this recommendation. However, as of April 2017, SSA did not specifically report that its review of Title II waivers will target DI waivers, including administrative waivers and waivers less than $2,000, or that such review will be an ongoing effort. To close this recommendation, SSA will need to show its plans for periodically assessing the accuracy of DI waiver decisions--particularly for administrative waivers and waivers under $2,000--through its continuous quality initiative or other means.
    Director: James R. McTigue, Jr.
    Phone: (202) 512-9110

    2 open recommendations
    Recommendation: To further encourage whistleblowers to provide information to IRS about serious tax noncompliance and to protect whistleblowers, Congress should consider legislation that would provide protections for tax whistleblowers against retaliation from their employers.

    Agency: Congress
    Status: Open

    Comments: On March 29, 2017, the Senate Finance Committee introduced the IRS Whistleblower Improvements Act of 2017, which would provide anti-retaliation protections for whistleblowers who bring information on tax noncompliance to IRS. The act would provide protections for employees from discharge, demotion, suspension, threats, harassment, or any other discrimination in reprisal for lawful actions to provide information to the IRS or to participate in a judicial action taken by the IRS relating to an alleged underpayment of tax or violation of tax laws. On April 20, 2016, the Senate Finance Committee approved provisions to improve the IRS's whistleblower program and protect tax whistleblowers from retaliation from their employers. The provision extends anti-retaliation provisions to IRS whistleblowers that are presently afforded to whistleblowers under the False Claims Act and Sarbanes-Oxley. However, no action passed on this Senate bill in the 114th congress. We will continue to monitor legislative action in this area.
    Recommendation: The Commissioner of Internal Revenue should direct the Whistleblower Office Director to establish a process to ensure whistleblower addresses are being properly updated in E-TRAK to ensure the WO does not send whistleblower mail to outdated or incorrect addresses. This process could include developing a change of address form specific to whistleblowers and including a blank copy of it in every correspondence with whistleblowers or referencing the importance of updating the WO with any address change in every correspondence with whistleblowers.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: In a January 29, 2016 letter, the IRS Deputy Commissioner for Services and Enforcement said that the Whistleblower Office will emphasize in education materials, fact sheets, and other communications with whistleblowers the importance of whistleblowers providing updates to the IRS of any address changes, along with reminders of how to submit address changes to the Whistleblower Office. In August and September of 2016, IRS revised templates for standard letters sent to whistleblowers reminding them of the importance of updating their addresses with the Whistleblower Office and providing direction for how to do so. IRS also published a fact sheet for whistleblowers, which is available on www.irs.gov, that also provides information on how whistleblowers should notify the Whistleblower Office of any address change. As of February 2017, IRS had not taken action to establish a process to ensure that address changes are being properly updated in E-TRAK and that mail is being sent only to the correct address. We will continue to follow-up with IRS on this recommendation.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    8 open recommendations
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should improve program management by expanding monitoring of available information on overpayment debts and collections. This could include regularly tracking the number and amount of overpayments created and the effectiveness of collection efforts.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA reported in March 2017 that the Veterans Benefits Administration and the Debt Management Center had recently developed a plan to track, analyze, and report on new measures of overpayments. This will include the number and amount of new overpayments, average debt per student, and the amount of uncollected debts outstanding. VA plans to include this information in a bi-annual report and use the data to identify trends and determine root causes of student and school debts. We will consider closing this recommendation once VA has produced the new reports and we have had an opportunity to review them.
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should address overpayments resulting from enrollment changes by providing guidance to educate student veterans about their benefits and consequences of changing their enrollment.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA officials reported in June 2017 that the agency has drafted revisions to the initial and subsequent award letters issued to students. The draft letters that we reviewed included more detailed information on education benefits and the consequences of changes in enrollment and a link to a website with additional helpful information about student overpayment debts. VA officials said these revisions are pending approval and the new award letters should be implemented by December 2017 once the necessary IT resources are available. We will close this recommendation when we receive confirmation that these changes have been incorporated into the letters that are sent to beneficiaries.
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should address overpayments resulting from enrollment changes by providing guidance to schools about the benefits of using a dual certification process where schools wait to certify the actual tuition and fee amounts until after the school's deadline for adding and dropping classes.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA reported in March 2017 that the agency sent school administrators an official letter in March 2017 asking them to use the dual certification process and to wait to certify actual tuition and fee amounts until after the school's deadline for adding and dropping classes. In addition, VA reported that it had discussed the dual certification method during a webinar with school administrators in June 2016. While these communications are helpful, we believe that VA should also update its guidance, such as its School Certifying Official Handbook, to include this information so that specific guidance on how dual certification can reduce tuition and fee overpayments is available on a continuing basis for current and future school certifying officials.
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should address overpayments resulting from enrollment changes by identifying and implementing a cost-effective way to allow Post-9/11 GI Bill beneficiaries to verify their enrollment status each month, and require monthly reporting.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA officials reported in March 2017 that the agency is developing a plan to add functionality for monthly verifications of student enrollment to its information technology systems, as GAO recommended in its 2015 report. Officials said they expect to complete these upgrades by December 2017once the necessary IT resources requested by the Veterans Benefits Administration are provided.
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should improve efforts to notify veterans and schools about overpayment debts by identifying and implementing other methods of notifying veterans and schools about debts to supplement the agency's mailed notices (e.g., email, eBenefits).

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA officials reported in March 2017 that the agency is developing a plan to update its IT systems so veterans could be notified of overpayment debts through eBenefits or by email. VA plans to complete this action by December 2017 once the necessary IT resources are available.
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should improve efforts to notify veterans and schools about overpayment debts by including information on both the cause of the debt and how to repay it in debt letters.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA agreed with our recommendation and reported in March 2017 that it is working on a plan to include school term dates on debt notification letters sent to schools. VA also plans to review and modify the initial debt letters sent to students and schools to include information on both the cause of the debt and how to repay the debt. VA plans to complete these actions by December 2017 once the necessary IT resources are available.
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should revise policy for calculating overpayments to increase collections by prorating tuition overpayments when veterans reduce their enrollment during the term based on the actual date of the enrollment change rather than paying additional benefits through the end of the month during which the reduction occurred.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA officials reported in March 2017 that the agency is revising its tuition overpayment regulations, as GAO recommended in its 2015 report. VA officials said these proposed regulatory revisions are going through the internal approval process, which is expected to be completed by October 2017.
    Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should ensure it is recovering the full amount of tuition and fee payments if a school does not charge a veteran for any tuition or fees after dropping a class or withdrawing from school. For example, VA could adjust its overpayment calculation to account for these situations or provide schools with guidance on how to account for school refund policies when reporting enrollment and tuition changes.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA officials reported in March 2017 that the agency plans to amend its procedures to account for school refund policies when calculating veterans' overpayment debts, as GAO recommended in its 2015 report. VA officials said they plan to publish this information in the School Certifying Official Handbook and notify schools and student veterans about the change. However, officials also reported that the agency needs to address several issues with its information technology systems before these changes can be made. Officials said they expect to complete these upgrades by December 2017 once the necessary IT resources requested by the Veterans Benefits Administration are provided.
    Director: James R. McTigue, Jr.
    Phone: (202) 512-9110

    1 open recommendations
    Recommendation: To help ensure the IRS collection program meets its mission and selects cases fairly, the Commissioner of Internal Revenue should establish, document, and implement objectives for the collection program and ACS, and define the key term of "fairness" as it applies to collection activities, which can be communicated to IRS staff.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: In January 2017, IRS supplied documentation on how it had established a fairness policy statement, which is incorporated into the Internal Revenue Manual, communicated to staff in email, and provided via a powerpoint presentation to staff. IRS also established and documented collection program objectives as part of its FY2017 Collection Program Letter. In October 2017, IRS shared additional draft documentation with GAO that would align SB/SE objectives with objectives from its FY2017 Collection Program Letter as well as other information such as performance measures. GAO continues to monitor IRS activity to create a process where key areas of focus may change from year to year, but the alignment to goals, objectives, and fairness remains consistent.
    Director: King, Kathleen M
    Phone: (202) 512-7114

    3 open recommendations
    including 3 priority recommendations
    Recommendation: As CMS prepares to solicit the next RAC contract(s), to improve the agency's RAC program operations and contractor oversight, the Administrator of CMS should ensure that work statements included in solicitations for contract proposals and the executed contract(s) set clear expectations about the work CMS intends the RAC to perform and that time frames are established that reflect the time needed to reach milestones.

    Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
    Status: Open
    Priority recommendation

    Comments: HHS agreed with our recommendation. As of March 2017, HHS stated that the agency was evaluating its strategy for the Medicare Part D RAC. Once HHS has completed its evaluation, we will update the status of these recommendations. As of May 2017, GAO considers this recommendation open.
    Recommendation: As CMS prepares to solicit the next RAC contract(s), to improve the agency's RAC program operations and contractor oversight, the Administrator of CMS should conduct annual evaluations of the RAC's performance against measurable performance standards to provide a clear basis on which CMS and the RAC can assess RAC performance in identifying improper payments.

    Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
    Status: Open
    Priority recommendation

    Comments: HHS agreed with our recommendations. As of March 2017, HHS stated that the agency was evaluating its strategy for the Medicare Part D RAC. Once HHS has completed its evaluation, we will update the status of these recommendations. As of May 2017, GAO considers this recommendation open.
    Recommendation: As CMS prepares to solicit the next RAC contract(s), to improve the agency's RAC program operations and contractor oversight, the Administrator of CMS should review the agency's process for identifying, reviewing, and approving new audit issues to identify process improvements that will help ensure the efficient development of appropriate audit issues (i.e., reduce audit issue denials and increase audit issue approvals) and thereby maximize the collection of improper payments.

    Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
    Status: Open
    Priority recommendation

    Comments: HHS agreed with our recommendations. As of March 2017, HHS stated that the agency was evaluating its strategy for the Medicare Part D RAC. Once HHS has completed its evaluation, we will update the status of these recommendations. As of May 2017, GAO considers this recommendation open.
    Director: Mctigue Jr, James R
    Phone: (202) 512-9110

    5 open recommendations
    Recommendation: To help ensure the IRS collection program meets its mission and selects cases fairly, the Commissioner of Internal Revenue should establish, document, and implement clear objectives for the collection program and enterprise-wide case categorization and routing processes, and define key terms, such as "fairness" and "risk."

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation. In March 2017, IRS provided a document intended define the objectives and "fairness," but it did not clearly define objectives for the collection program and enterprise-wide case categorization and routing processes, but instead identified division-level objectives and fiscal year 2017 collection strategies. The document also did not clearly define and communicate objectives--to include fairness--to staff in measurable terms that would be easily understood. Further, the objectives definitions were not were not clear and sufficient to support the design of internal control for related risks, the development of performance measures to determine whether objectives were achieved, and control assessments to assure case selections effectively support the collection program mission over time, including fairness. In August 2017, we shared this assessment with IRS and asked whether or when Collection plans to develop or provide additional documents.
    Recommendation: To help ensure the IRS collection program meets its mission and selects cases fairly, the Commissioner of Internal Revenue should build upon existing Enterprise Risk Management (ERM) guidance to help managers identify internal and external risks to collection program objectives, and better understand how long-standing risk processes integrate with new ERM approaches; incorporate this guidance into existing or future ERM or collection program risk assessment processes.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation and said it would continue to build upon existing risk management guidance by finalizing and making available training for managers, which would assist them in understanding their responsibilities for identifying internal and external risks to Collection program objectives. In November 2016, IRS provided documentation of risk management training for managers. However, since objectives for the collection program, enterprise-wide case categorization and routing processes, and fairness were not yet clearly defined, such guidance cannot be effectively incorporated into risk assessment processes to identify internal and external risks to collection program objectives. In August 2017, we shared this assessment with IRS and asked whether or when Collection plans to develop or provide additional documents.
    Recommendation: To help ensure the IRS collection program meets its mission and selects cases fairly, the Commissioner of Internal Revenue should clearly establish, document, and implement case categorization and routing procedures--such as those for IDS, high priority case selection, and any other important processes--to support collection program objectives and IRS goals.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed with the recommendation and said it would review its case prioritization and selection processes and implement and communicate clear guidance and documentation to appropriate IRS staff. In November 2016, IRS provided documents on collection processes, but the information was either technical or covered Automated Collection System (ACS) or Field Collection processes rather than enterprise-wide processes to support collection program objectives and IRS goals. More specifically, the documents did not provide corrected guidance on the role of the Inventory Delivery System and modeling in shelving or routing cases to either ACS or the Field, or provide guidance on how management is to select priority area cases. In August 2017, we shared this assessment with IRS and asked whether or when Collection plans to develop or provide additional documents.
    Recommendation: To help ensure the IRS collection program meets its mission and selects cases fairly, the Commissioner of Internal Revenue should establish, document, and implement procedures for the periodic evaluation of the efficiency and effectiveness of collection-wide case categorization, routing rules, and case selection processes.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS said agreed that continually improving its performance is important and said that Collection would review and, if needed, update its internal management documents. In July 2017, IRS provided documents that identified and established responsibilities for periodic, regular review procedures to potentially update dollar thresholds used in routing collection inventory for potential selection, including IDS and its decision rules to route cases to one collections function instead of another (i.e., the Automated Collection System versus Field Collection. In August 2017, we asked IRS when it plans to conduct the first such evaluations and requested that it provide documentation of results of those implemented evaluations when available.
    Recommendation: To help ensure the IRS collection program meets its mission and selects cases fairly, the Commissioner of Internal Revenue should establish, document, and implement procedures for periodic updates of dollar thresholds for categorizing case selection, including those identified as "high risk."

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed that continually improving its performance is important and said that Collection would review and, if needed, update its internal management documents. In July 2017, IRS provided documents that identified and established responsibilities for periodic, regular review procedures to potentially update dollar thresholds used in systems that use a dollar threshold to prioritize Collection cases. In August 2017, we asked IRS when it plans to conduct the first such evaluations and requested that it provide documentation of results of those implemented evaluations when available.
    Director: Maurer, Diana C
    Phone: (202) 512-9627

    3 open recommendations
    Recommendation: To help ensure the efficient use of resources for the Three Percent Fund, the Attorney General should develop a policy and implement procedures to regularly analyze unobligated balances and develop collection estimates in order to determine an appropriate reserve amount and inform estimates of future funding needs.

    Agency: Department of Justice
    Status: Open

    Comments: In February 2015, we found that the Department of Justice (DOJ) Collection Resource Allocation Board (CRAB) had taken steps to manage the Three Percent Fund, but it had not conducted analyses that would help DOJ better manage the fund, such as developing reserve estimates aligned with DOJ priorities or projecting future collections. GAO has identified leading practices among federal agencies when evaluating balances in federal accounts. Such practices emphasize the importance of regularly analyzing balances by, for example, estimating collections and determining reserve needs. Doing so helps agencies more effectively anticipate program needs and ensure the most efficient use of resources. As a result, we recommended that DOJ develop a policy and implement procedures to regularly analyze unobligated balances collection estimates in the Three Percent Fund. DOJ partially concurred with this recommendation. In response, DOJ provided us with a policy it began implementing in January 2016 to help them analyze the Three Percent Fund's unobligated balance and develop an appropriate reserve amount. For example, DOJ's policy for developing the reserve estimate now relies on more robust requests for information of DOJ debt collection activities, including government personnel, contract support, and automated litigation service requirements. By developing and implementing this policy, DOJ is better positioned to ensure the continuity of operations funded through the Three Percent Fund and to make future resource allocations. However, DOJ stated in its response to the report that it does not believe it is appropriate to estimate incoming collections for the following year. For example, DOJ does not ask litigating components for the number of cases that will be settled because the agency does not want to be perceived as inappropriately encouraging larger government civil collections. Additionally, DOJ does not calculate such estimates due to the high level of variability in the civil debt litigation cases that make it difficult to use historical information to estimate reserves. We noted in our report DOJ's concerns for developing collection estimates. However, we continue to believe that developing a policy for considering collection estimates is important. The Three Percent Fund is self-sustaining and does not receive annual appropriations. Therefore, any volatility should be managed with the best information and estimates the department can provide. Without developing collection estimates, DOJ is at risk of committing too much or too few budgetary resources from the Three Percent Fund. A lack of such a policy may lead to Three Percent balances either falling too low to efficiently manage operations or rise to unnecessarily high levels. As we have previously reported, one method DOJ could consider instead of a specific dollar estimate is to develop a range between the potential lowest and highest collection amounts based on historical trends and current collection activities. By estimating future collections, DOJ could better ensure it is able to efficiently fund as many programs as possible and best support the fund's priorities. Therefore, we consider this recommendation only partially implemented and will keep it open until DOJ develops collection estimates to aid managing the Three Percent Fund.
    Recommendation: To improve transparency and ensure the effective use of automation fees for the CJIS fingerprint checks fees, the Director of the Federal Bureau of Investigation should publish in the Federal Register, or other documents such as annual reports, how much is assessed for automation and cost recovery in each transaction to better communicate the cost of the service to customers and stakeholders.

    Agency: Department of Justice: Federal Bureau of Investigation
    Status: Open

    Comments: In fiscal year 2015, we found that the Federal Bureau of Investigation (FBI) sets its Criminal Justice Information Services (CJIS) fingerprint checks fees to collect two parts--the cost recovery portion and the automation portion, but does not provide transparency in how much is assessed for each portion of the fee. As a result, we recommended that FBI publish in the Federal Register, or other documents such as annual reports, how much is assessed for automation and cost recovery in each transaction to better communicate the cost of the service to customers and stakeholders. In July 2016, FBI published a notice in the Federal Register announcing a CJIS fingerprint checks fees rate change effective on October 1, 2016. However, the notice did not include an explanation of how much is assessed for the cost recovery or the automation portion of the fee. According to a Department of Justice (DOJ) liaison, FBI included a breakout of the revised rates in its CJIS Information Letter, which services as written notification of a rate change to state and federal stakeholders. GAO requested a copy of the CJIS Information Letter, but as of February 2017, DOJ has not provided the letter. Further, while the CJIS Information Letter might provide transparency to stakeholders on how much FBI assesses for each portion of the fee, FBI has not relayed how it intends to be transparent with customers. To fully address this recommendation, FBI needs to demonstrate that it is being transparent with stakeholders and with customers. Until it does so, this recommendation will remain open.
    Recommendation: To improve transparency and ensure the effective use of automation fees for the CJIS fingerprint checks fees, the Director of the Federal Bureau of Investigation should develop a policy to analyze the unobligated balances coming from the automation portion of the fee to inform program needs, including improving methods for anticipating automation collections, and establishing a range of appropriate carryover amounts to support program needs.

    Agency: Department of Justice: Federal Bureau of Investigation
    Status: Open

    Comments: In fiscal year 2015, we found that the Federal Bureau of Investigation (FBI) had a growing unobligated balance from the automation portion of its Criminal Justice Information Services (CJIS) fingerprint checks fees but did not evaluate the appropriate range of its carryover amounts, nor had it developed a policy to do so. As a result, we recommended that FBI develop a policy to analyze the unobligated balances coming from the automation portion of the fee to inform program needs, including improving methods for anticipating automation collections, and establishing a range of appropriate carryover amounts to support program needs. In September 2016, the Department of Justice (DOJ) reported that FBI is taking steps to develop and implement a multi-year investment plan that will be reviewed and updated annually, and that will address key questions from the GAO report titled "Budget Issues: Key Questions to Consider When Evaluating Balances in Federal Accounts." Additionally, the multi-year investment plan will include both an annual analysis of current and projected revenue from the automation portion of the fee, and the evaluation of the resource requirements needed to support the development of technological enhancement of fingerprint identification and criminal justice services. According to DOJ officials, the 2017 plan will be the first to include this information; however GAO has not yet received a copy of the 2017 plan. We will continue to monitor FBI's progress on this recommendation.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    2 open recommendations
    including 1 priority recommendation
    Recommendation: To strengthen Education's oversight of the loan rehabilitation process, the Secretary of Education should direct the Office of Federal Student Aid's Chief Operating Officer to take steps to ensure that the final monitoring plan for the new defaulted loan information system contract identifies risks presented by the contractor or contract work and the oversight activities planned to address those risks.

    Agency: Department of Education
    Status: Open
    Priority recommendation

    Comments: Education concurred with this recommendation and reported that it has developed a contract monitoring plan that tracks explicit deliverables related to key risk areas. Education also reported that the new vendor for the defaulted loan information system is using a methodology, referred to as Lifecycle Management Methodology, that includes risk monitoring and mitigation strategies, and is using an independent verification and validation service to work with the new vendor to ensure that all appropriate processes and controls are in place. With the contract's base period end date of July 31, 2016, GAO will close this recommendation when Education provides documentation of its monitoring reviews that show its contractor is receiving appropriate levels of oversight.
    Recommendation: To strengthen Education's oversight of the loan rehabilitation process, the Secretary of Education should direct the Office of Federal Student Aid's Chief Operating Officer to take steps to improve its collection agency call review process. For example, Education could take steps to ensure that quarterly rehabilitation call reviews are completed, establish procedures for monitoring collection agency corrective actions, and utilize call review results to inform its oversight of collection agencies activities.

    Agency: Department of Education
    Status: Open

    Comments: Education concurred and reported that it has taken a number of steps to strengthen its call review process. Education reported it conducted a review of rehabilitation calls with a specific focus on the Fair Debt Collection Practices Act and unfair, deceptive, or abusive acts or practices. The results of the review indicated certain collection agencies were not consistently acting in the best interest of borrowers, taxpayers, and the government. As a result five collection agency task orders were allowed to wind down in April 2015. Education also reported that as of April 2015, the Office of Federal Student Aid (FSA) increased call monitoring on rehabilitation calls from 20 a quarter per collection agency to at least 20 per month per collection agency. FSA secured a third party vendor in September 2015 to assist with its call monitoring efforts with the expectation that the vendor would be responsible for reviewing an additional 2,500 calls per month. Education also committed to conducting on-site reviews of each collection agency at least annually beginning in December 2015. GAO will close this recommendation when Education provides monthly data on call reviews conducted by FSA and its third-party vendor from April 2015 to the most recent month available and documentation of the on-site reviews of collection agencies that FSA has conducted since December 2015. Although Education provided an update for this report in FY17, it did not include an update for this particular recommendation.
    Director: White, James R
    Phone: (202) 512-9039

    2 open recommendations
    Recommendation: To better ensure the notice phase is achieving desired results at the lowest costs, the Commissioner of Internal Revenue should provide IRS collection managers and executives accessible, reliable information on what the business rules are.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS said in January 2016, that it planned to review current business rules and communicate clear guidance and documentation on business rules to appropriate IRS staff by July 2016. In October 2016, IRS provided documentation of some actions taken and planned, and noted it expects to provide additional business rules information in evaluations planned by June 2017. IRS confirmed this status in March 2017.
    Recommendation: To better ensure the notice phase is achieving desired results at the lowest costs, the Commissioner of Internal Revenue should periodically and regularly evaluate the business rules in terms of efficiency and effectiveness or other results and ensure the results are available to managers so the data and methodologies can be used or considered in future evaluations.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS said in January 2016, that it would conduct periodic reviews, update business rules if needed, and ensure follow-up for ad hoc evaluations by June 2017. In October 2016, IRS provided documentation of planned actions to periodically evaluate the business rules and communicate evaluation results and business rules information to appropriate IRS staff by June 2017. IRS confirmed this status in March 2017.