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    Results:

    Subject Term: "Erroneous payments"

    34 publications with a total of 111 open recommendations including 28 priority recommendations
    Director: Beryl H. Davis
    Phone: (202) 512-2623

    15 open recommendations
    including 4 priority recommendations
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to annually report improper payment estimates and error rates for the advance PTC program.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS concurred with this recommendation. HHS stated that in FY 2016, it completed a risk assessment of the advance PTC program and reported results in the FY 2016 Agency Financial Report. Currently, HHS is unable to specify the year the rate and amount will be reported due to the complexity and timing of the error rate measurement methodology process, which involves conducting pilot testing, using those pilots to refine the methodology, and then undergoing the rulemaking process before implementing the methodology to ensure accurate and efficient reporting of an improper payment rate.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, and until annual reporting of improper payment estimates and error rates for the advance PTC program is performed, the Secretary of Health and Human Services should direct the Administrator of CMS to disclose significant matters relating to the Improper Payments Information Act (IPIA) estimation, compliance, and reporting objectives for the advance PTC program in the agency financial report, including CMS's progress and timeline for expediting the achievement of those objectives and the basis for any delays in meeting IPIA requirements.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS concurred with this recommendation. HHS stated that it reported information on the status of the advance PTC risk assessment in the FY 2014 to FY 2016 Agency Financial Reports. Now that the program's improper payment risk assessment is completed, HHS will continue to report on its progress in designing and implementing an improper payment estimate for the advance PTC program in future Agency Financial Reports.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to design and implement procedures for verifying the identities of phone and mail applicants to reasonably assure that ineligible individuals are not enrolled in qualified health plans in the marketplaces or provided advance PTC.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS neither agreed nor disagreed with this recommendation. However, regarding verification of filer identity, HHS stated that for individuals starting a new application via phone, the call center representatives use verbal attestations for identity verifications from individuals. HHS stated that for paper applications, individuals must provide names and complete addresses as well as other information. In addition, HHS stated that individuals must attest that the information they provide on all applications is accurate by signing under penalty of perjury. GAO continues to believe that because CMS does not validate the identities of individuals who apply by phone or mail, CMS is vulnerable to enrolling ineligible individuals in qualified health plans with advance PTC.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to assess and document the feasibility and availability of obtaining sufficiently reliable data to verify individuals' residencies and lack of minimum essential coverage from nonfederal employers and, if appropriate, design and implement procedures for using such data in its verification processes.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS concurred with this recommendation. HHS stated that its previous assessments of available electronic data sources did not identify any comprehensive national data source for verifying residency. HHS recently conducted a study to assess the feasibility of developing an employer-sponsored coverage database and determined that development would be costly and highly burdensome given available resources. Additionally, HHS stated that it would impose extra burden on employers to collect the information needed to build a comprehensive employer-sponsored coverage database. HHS will continue to assess and document whether any sufficiently reliable data sources exist and examine the feasibility of implementation.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to design and implement procedures for sending notices to nonfederal employers routinely and terminating advance PTC for individuals who have access to minimum essential coverage from their employers.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS neither agreed nor disagreed with this recommendation. However, regarding sending notices to nonfederal employers, HHS stated that it is evaluating its 2016 employer notice program to determine the best approach for notifying employers in the future. Such an evaluation may provide useful information; however, GAO continues to believe that designing and implementing procedures for sending notices to nonfederal employers and terminating advance PTC to individuals with access to employer-sponsored coverage can reduce the risk of providing advance PTC to issuers on behalf of ineligible individuals.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to assess and document the feasibility of approaches for (1) identifying duplicate government-sponsored coverage for individuals receiving Medicaid and Children's Health Insurance Program coverage in federally facilitated marketplace states outside of the states where they attest to residing and (2) periodically verifying individuals' continued eligibility by working with other government agencies to identify changes in life circumstances that affect advance PTC9 eligibility--such as commencement of duplicate coverage or deaths-- that may occur during the plan year and, if appropriate, design and implement these verification processes.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS concurred with this recommendation. HHS stated that its preliminary analysis indicates that identifying government sponsored coverage for individuals receiving Medicaid and CHIP in Federally-facilitated Exchange states outside of the state where the applicant is enrolled in coverage would add several months to the time needed to execute the process of identifying duplicate enrollees and ending their advance PTC. Such additional time would significantly reduce the timeliness and effectiveness of the process and lead to an increase in burden on the state Medicaid systems used to verify duplicate coverage. HHS stated that it will continue this analysis and document the feasibility of approaches for identifying duplicate government sponsored coverage for individuals receiving Medicaid and CHIP coverage in Federally-facilitated Exchange states outside the application state of the consumer as well as periodically verifying individual's continued eligibility. In addition, HHS stated that it has implemented a Periodic Data Matching process to proactively identify consumers who may be receiving Minimum Essential Coverage through Medicare, and thus are no longer eligible for financial assistance to help pay for Exchange coverage. HHS is also exploring approaches to identifying Exchange enrollees who may be deceased and should thus be disenrolled from coverage.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to assess and document the feasibility of approaches for terminating advance PTC on a timelier basis and, as appropriate, design and implement procedures for improving the timeliness of terminations.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS concurred with this recommendation. HHS stated that it continues to assess the feasibility of terminating advance PTC at various times of the month as a result of consumers not resolving inconsistencies. HHS currently terminates advance PTC between the 1st and 15th of the month following the end of the inconsistency clock in order to accommodate issuer processes. HHS stated that processing in these cohorts also allows for operational and quality efficiencies for HHS since processes can be completed in batches.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to design and implement procedures for verifying compliance with applicable tax filing requirements--including the filing of the federal tax return and the Form 8962, Premium Tax Credit--necessary for individuals to continue to be eligible for advance PTC.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS concurred with this recommendation. HHS stated that the IRS provides information to Exchanges on consumers who received advance PTC in the prior coverage year but have not taken the necessary steps to file a tax return and reconcile advance PTC. Beginning in Open Enrollment for 2018, the Federally-facilitated Exchange will end advance PTC on behalf of the tax filers who have not filed or have not reconciled advance PTC when that information is reported to the Exchange by IRS.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to design and implement procedures for verifying major life changes using documentation submitted by applicants enrolling during special enrollment periods.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS concurred with this recommendation. HHS stated that it is continually monitoring the operations of the Exchange and has taken several steps to analyze and strengthen current rules and procedures to ensure that only those who are eligible enroll through special enrollment periods. While special enrollment periods provide a criticial pathway to coverage for qualified individuals who experience qualifying events, it's equally important that special enrollment periods are not misused or abused. HHS also stated that in April 2017, it issued a final rule on Market Stabilization that promotes program integrity by requiring individuals to submit supporting documentation for special enrollment periods and ensures that only those who are eligible are able to enroll. It will encourage individuals to stay enrolled in coverage all year, reducing gaps in coverage and resulting in fewer individual mandate penalties and help to lower premiums. This process will begin in June 2017.
    Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to design and implement procedures for verifying with IRS (1) household incomes, when attested income amounts significantly exceed income amounts reported by IRS or other third-party sources, and (2) family sizes.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS neither agreed nor disagreed with this recommendation. However, regarding verification of household income and family sizes, HHS stated that as part of its eligibility verification requirements, it verifies consumer-reported income with data from IRS. However, HHS stated that because household incomes may fluctuate year to year, it is difficult for consumers to project income for the year in advance. According to HHS, in instances where applicant-reported income is higher than the IRS data, HHS accepts the consumer attestation. However, HHS stated that it will assess the feasibility and burden on individuals of setting a reasonable threshold for the generation of annual household income inconsistencies that would require additional verification for consumer-attested income that significantly exceeds income amounts reported by IRS or other third party sources. We believe that such an evaluation is a reasonable step to address our recommendation to enhance the effectiveness and efficiency of the program related to verification of household income. In addition, HHS stated that it currently accepts attestation when the family size provided by the individual does not match IRS's records. HHS stated that establishing a process to verify family size with IRS would require significant operational and privacy complexity. While we recognize that there may be certain complexities in the verification of family sizes, it is important that CMS develop policies and procedures to reasonably assure that such verifications are made on a regular basis.
    Recommendation: To comply with improper payments reporting requirements and improve procedures related to processing PTC information on tax returns, the Commissioner of Internal Revenue should direct the appropriate officials to assess the program against applicable IPIA-defined thresholds and conclude on its susceptibility to significant improper payments, and revise the scope of its improper payments susceptibility assessment for the PTC program to include instances in which advance PTC is greater than or equal to the amount of PTC claimed on the tax return. If the program meets the IPIA definition for being susceptible to significant improper payments based on this assessment, estimate and report improper payments associated with the PTC program consistent with IPIA requirements.

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

    Comments: The IRS partially agreed with this recommendation. IRS stated that instances in which the advance payment of the PTC is greater than or equal to the amount of the PTC claimed on the tax return do not result in the IRS increasing the outlay related to PTC, and so by definition these occurrences are not subject to IPIA, as amended. The IRS understands and shares the concern about the misreporting of items on tax returns, including cases where the taxpayer misreports excess advance PTC, but the IRS has many compliance programs that operate outside the scope of IPIA and that address taxpayer error and noncompliance. The IRS conducted its fiscal year 2016 PTC improper payment risk assessment consistent with guidance from the Office of Management and Budget (OMB), which concurred with our methodology. However, the IRS is committed to discussing with OMB a future change to the agreed-upon procedures to assessing PTC improper payments as part of our larger and ongoing discussions with OMB about the administration of refundable tax credits and the challenges of reporting those credits through the framework of improper payments legislation and guidance.
    Recommendation: To comply with improper payments reporting requirements and improve procedures related to processing PTC information on tax returns, the Commissioner of Internal Revenue should direct the appropriate officials to assess and document the feasibility of approaches for incorporating information from the marketplaces on individuals who did not demonstrate that they met the eligibility requirements for citizenship or lawful presence in the tax compliance process. If determined feasible, IRS should work with Treasury to require marketplaces to periodically provide such information on individuals and use such information to recover advance PTC made for those individuals.

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

    Comments: The IRS agreed with this recommendation. IRS stated that it will evaluate the feasibility of receiving information from the marketplaces, and the value of using that information in its processes. If IRS determines that obtaining the data would be feasible and using it would be cost-effective, IRS will consult with Treasury on regulations or other guidance needed to obtain the information. Although eligibility determinations for the advance PTC are made outside the IRS's purview, the IRS has taken steps to ensure that the PTC is administered fairly and properly. For example, IRS has updated guidance in Publication 974, Premium Tax Credit, to clarify that any advance payment of the PTC made on behalf of individuals who did not meet the citizenship or lawful presence requirements must be repaid in full. Taxpayers are required to report the excess advance PTC on their tax returns. If they do not, IRS will address it through post-filing compliance. We will request and review supporting documentation for IRS's reported actions.
    Recommendation: To comply with improper payments reporting requirements and improve procedures related to processing PTC information on tax returns, the Commissioner of Internal Revenue should direct the appropriate officials to assess whether IRS should require its examiners to verify health care coverage of individuals to determine eligibility for PTC. To do this, IRS should complete its evaluation of the level of noncompliance related to duplicate health insurance coverage. Based on this evaluation and if cost effective, IRS should design and implement formal policies and procedures to routinely identify individuals inappropriately receiving PTC because of their eligibility for or enrollment in health care programs outside of the marketplaces and notify such individuals of their ineligibility for PTC.

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

    Comments: IRS agreed with this recommendation. IRS stated that it developed an Affordable Care Act (ACA) Compliance Strategy in October 2016, which included post-filing checks for the PTC. The IRS must rely upon post refund checks to verify if taxpayers had other healthcare coverage and therefore were not eligible to claim the PTC. For tax year 2017 the IRS plans to implement additional capabilities to evaluate coverage. The IRS will continue to evaluate the results and design and implement cost effective policies and procedures that routinely identify individuals inappropriately receiving PTC, as warranted.
    Recommendation: To comply with improper payments reporting requirements and improve procedures related to processing PTC information on tax returns, the Commissioner of Internal Revenue should direct the appropriate officials to design and implement procedures in the Internal Revenue Manual (IRM) for examiners in the post-filing compliance units to review tax returns for health insurance coverage for the entire year, and to identify and assess individual shared responsibility payments (SRP) from those who are not appropriately reporting SRPs on their tax returns.

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

    Comments: IRS disagreed with this recommendation. However, IRS stated that, among other things, it has drafted a new IRM section for examiners who are responsible for reviewing tax returns to determine whether health insurance is reflected for the taxpayer for the entire year, and for identifying and assessing SRP on taxpayers who are not appropriately reporting SRP on their tax returns. IRS stated that the IRM section is pending approval by Exam Policy. Although IRS stated that it disagreed with our recommendation, we believe that the actions that IRS described in its response to our draft report would sufficiently address our recommendation if implemented effectively.
    Recommendation: To comply with improper payments reporting requirements and improve procedures related to processing PTC information on tax returns, the Commissioner of Internal Revenue should direct the appropriate officials to design and implement procedures in the IRM to regularly notify nonfilers of the requirement to file tax returns in order to continue to receive advance PTC in the future.

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

    Comments: The IRS partially agreed with this recommendation. IRS stated that using a research-based approach to evaluate the 2015 tax filing season, it developed a post-compliance process for sending notices to individuals who received advance PTC paid on their behalf in the previous calendar year but failed to file a tax return and also to those who requested an extension to file. IRS stated that being flexible in its approach has allowed IRS to refine the process to improve efficiency and effectiveness. IRS further stated that based on the 2017 research analysis, IRS will determine whether the information should be included in an existing IRM. We agree that IRS should review its process to improve the efficiency and effectiveness of its operations. However, we continue to believe that designing and implementing procedures to regularly notify non-filers of the need to file to continue receiving advance PTC decreases the risk that the ad hoc notification process will not be followed consistently in each filing season.
    Director: Beryl H. Davis
    Phone: (202) 512-2623

    2 open recommendations
    Recommendation: To help ensure that government-wide compliance under IPERA is consistently determined and reported, the Director of OMB should coordinate with CIGIE to develop and issue guidance, either jointly or independently, to specify what procedures should be conducted as part of the IGs' IPERA compliance determinations.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: OMB had no comments on the report or the recommendation to coordinate with CIGIE to develop guidance. Although this recommendation was not directed to CIGIE, the CIGIE Chairperson stated that CIGIE would coordinate with OMB as needed and provide feedback on any draft OMB guidance.
    Recommendation: To help fulfill USDA's requirements under IPERA and OMB guidance--that agencies submit proposals to Congress when a program reaches 3 or more consecutive years of noncompliance with IPERA criteria--the Secretary of Agriculture should submit a letter to Congress detailing proposals for reauthorization or statutory changes in response to 3 consecutive years of noncompliance as of fiscal year 2015 for its Farm Security and Rural Investment Act Program. To the extent that reauthorization or statutory changes are not considered necessary to bring a program into compliance, the Secretary or designee should state so in the letter.

    Agency: Department of Agriculture
    Status: Open

    Comments: USDA's Acting Deputy Secretary concurred with this recommendation.
    Director: David C. Trimble
    Phone: (202) 512-3841

    6 open recommendations
    Recommendation: To allow DOE management to effectively monitor invoice reviews and have assurance that this control activity is operating as intended, the Secretary of Energy should establish a DOE-wide invoice review policy that includes requirements for sites to establish well-documented invoice review operating procedures.

    Agency: Department of Energy
    Status: Open

    Comments: DOE stated that it already has an established, detailed DOE-wide invoice review policy provided in DOE's Financial Management Handbook and in the DOE Acquisition Guide, and that they are updating the Financial Management Handbook to include additional procedures to address intra-governmental payment and collection transactions that they believe will allow the recommendation to be closed by September 30, 2017. However, DOE officials with the office of the CFO at DOE headquarters previously told us that they do not have department-wide invoice review policies and procedures, and that CFOs and contracting officials in DOE field offices are responsible to develop their own invoice review policies and procedures. In addition, we reviewed the Financial Management Handbook and the Acquisition Guide and found that these documents do not contain the detail necessary to serve as an invoice review policy. We will continue to review DOE's implementation of this recommendation to determine whether its actions meet the intent of the recommendation.
    Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including creating a structure with a dedicated entity within DOE to design and oversee fraud risk management activities.

    Agency: Department of Energy
    Status: Open

    Comments: DOE considers this recommendation to be closed without corrective action. Instead of establishing a dedicated entity within DOE to design and oversee fraud risk management activities, DOE will rely on the existing Office of Financial Policy and Internal Controls and on the DOE Office of Inspector General (OIG)to design and oversee financial fraud risk management activities. We disagree that reliance on these offices meets best practices because neither office is solely dedicated to designing or overseeing fraud risk management activities. Furthermore, according the best practices in GAO's Fraud Risk Framework, the dedicated entity should not be the OIG.
    Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including conducting fraud risk assessments that are tailored to each program and use the assessments to develop a fraud risk profile

    Agency: Department of Energy
    Status: Open

    Comments: DOE concurred with the substance of the recommendation; however they consider the recommendation to be closed without corrective action because its risk assessments meet the requirements of the Improper Payments Elimination and Recovery Improvement Act of 2012, as reported by the Office of Inspector General (OIG), and because it has implemented updates to OMB Circular A-123 that added requirements related to managing fraud risk and adherence to GAO's Fraud Risk Framework. However, we found that DOE has not conducted fraud risk assessments that are tailored to its programs and therefore do not allow the department to create a fraud risk profile. We also found that, although DOE updated its internal control assessment tools with a list of fraud risks as required by OMB Circular A-123, the list of risks were the same for all DOE sites and were not tailored to the sites' different programs.
    Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including developing and documenting an antifraud strategy that describes the programs' approaches for addressing the prioritized fraud risks identified during the fraud risk assessment.

    Agency: Department of Energy
    Status: Open

    Comments: DOE concurred with this recommendation but considers the recommendation closed without corrective action because DOE has implemented the updated OMB Circular A-123 and because DOE's anti-fraud strategy is imbedded in the DOE internal control program. However, DOE officials told us that they have not developed or documented a DOE-wide antifraud strategy or directed individual programs to develop program-specific strategies. Furthermore, DOE's implementation of OMB Circular A-123 included adding a list of potential risks to their internal control assessment tool that were the same for all DOE sites and were not tailored to the sites' different programs.
    Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including designing and implementing specific control activities, including fraud awareness training and data analytics, to prevent and detect fraud and other improper payments.

    Agency: Department of Energy
    Status: Open

    Comments: DOE believes that they are either implementing or have already implemented this recommendation and considers the recommendation closed without additional action. Specifically, DOE stated that the Office of Inspector General (OIG) already provides fraud awareness training and that the OIG provided expanded fraud risk training on June 12, 2017 through a CFO-hosted webinar. However, of the 10 field offices responsible for overseeing contractor costs, none required employees responsible for overseeing contractor costs to attend fraud awareness training.
    Recommendation: To help ensure that necessary data are available to employ data analytics as a tool to perform contractor cost-surveillance activities, the Secretary of Energy should require contractors to maintain sufficiently detailed transaction-level cost data that are reconcilable with amounts charged to the government, including (1) cost data that, at a minimum, represent a full data population and (2) the details necessary to determine the nature of each cost transaction, with such identifiers as transaction date, dollar amount, item or service description, and transaction codes to indicate the type of cost represented (e.g., construction materials, property lease, and office supplies).

    Agency: Department of Energy
    Status: Open

    Comments: DOE did not agree to implement this recommendation because they believe that the recommendation establishes agency-specific requirements for DOE contractors that are more prescriptive than current federal requirements. DOE states that they plan to evaluate the merits of government-wide guidance for applying data-analytics to contract costs only if an OMB working group--established as a requirement of the Fraud Reduction and Data Analytics Act of 2015 to promote interagency coordination on fraud reduction and data analytics--requires them to do so. However, the purpose of the working group is to share fraud management best practices. It is not an implementing body and agencies do not need its permission before proceeding with fraud risk reduction efforts.
    Director: King, Kathleen M
    Phone: (202) 512-7114

    3 open recommendations
    Recommendation: To ensure MACs' provider education efforts are focused on areas vulnerable to improper billing and to strengthen CMS's oversight of those efforts, CMS should require sufficient detail in MAC reporting to allow CMS to determine the extent to which MACs' provider education department efforts focus on areas identified as vulnerable to improper billing.

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

    Comments: HHS concurred with this recommendation and said it would take steps to implement it. In April 2017, CMS released a revised Provider Customer Service Program Activity Report (PAR) template to Medicare Administrative Contractors (MAC). This revised template collects additional information from MACs on their provider outreach and education activities that are specifically geared towards reducing their improper payment rate. All PAR Reports submitted after July 2017 will include information on these topics. Additionally, CMS is implementing increased reporting by MACs in the Provider Customer Service Program Contractor Information Database to track whether education was provided related to the prioritization of efforts to reduce the error rate. CMS expects these additional reporting requirements to be released to the MACs in fall 2017. GAO will continue to monitor CMS efforts.
    Recommendation: To ensure MACs' provider education efforts are focused on areas vulnerable to improper billing and to strengthen CMS's oversight of those efforts, CMS should explicitly require that Medicare Part A and B claims, DME, and home health and hospice MACs work together to educate referring providers on documentation requirements for DME and home health services.

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

    Comments: HHS concurred with this recommendation and said it would take steps to implement it. CMS is developing instructions for the Medicare Administrative Contractors (MAC) that will require MACs to collaborate on a regular basis to provide education to referring providers on documentation and other requirements relative to durable medical equipment and home health services. CMS expects these new instructions to be released to MACs in fall 2017. Additionally, CMS is implementing increased reporting by MACs in the Provider Customer Service Program Contractor Information Database to track the instances of collaboration with other MACs. CMS expects these additional reporting requirements to be released to the MACs in fall 2017. Finally, CMS revised the Provider Customer Service Program Activity Report (PAR) to collect additional information from MACs on education topics where MACs collaborated with each other and with external partners. This new template was released to MACs in April 2017, and all PARs submitted after July 2017 will include information on these topics. GAO will continue to monitor CMS efforts.
    Recommendation: To ensure MACs' provider education efforts are focused on areas vulnerable to improper billing and to strengthen CMS's oversight of those efforts, for any future probe and educate reviews, CMS should establish performance metrics that will help the agency determine the reviews' effectiveness in reducing improper billing.

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

    Comments: HHS concurred with this recommendation and said it would take steps to implement it. Through the Targeted Probe and Educate Pilot, currently under way in Jurisdiction F and set to expand in the near future to additional jurisdictions, CMS has been working to develop more thorough metrics to monitor the outcome and impact of the probe and educate reviews. Detailed metrics in the expanded pilot include service and provider specific error rates, claims metrics, financial impact, education metrics, provider/suppler behavior metrics, as well as volume and outcome of appeals both pre- and post-probe and educate implementation. GAO will continue to monitor CMS efforts.
    Director: Carolyn L. Yocom
    Phone: (202) 512-7114

    1 open recommendations
    including 1 priority recommendation
    Recommendation: The Administrator of CMS should take immediate steps to assess and improve the data available for Medicaid program oversight, including, but not limited to, T-MSIS. Such steps could include (1) refining the overall data priority areas in T-MSIS to better identify those variables that are most critical for reducing improper payments, and (2) expediting efforts to assess and ensure the quality of these T-MSIS data.

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

    Comments: As of September 2017, CMS has begun targeted efforts to assess and improve T-MSIS data available for Medicaid program oversight, including initiating a pilot study with four states to identify data anomalies and obtaining input from external experts on data quality. However, because these initiatives are ongoing and further efforts to improve T-MSIS data are still evolving, this recommendation remains open.
    Director: Beryl H. Davis
    Phone: (202) 512-2623

    9 open recommendations
    including 4 priority recommendations
    Recommendation: To provide agencies access to SSA's more complete set of death data, Congress should consider amending the Social Security Act to explicitly allow SSA to share its full death file with Treasury for use through the DNP working system.

    Agency: Congress
    Status: Open

    Comments: When we confirm what actions have been taken we will update. As of August 3, 2017, no updated information has been provided.
    Recommendation: To reasonably assure that additional relevant databases are identified and evaluated for inclusion in the DNP working system, the Director of OMB should develop, document, and communicate a formal process that user agencies can use to identify, suggest, and receive feedback on additional databases to be evaluated for inclusion in the DNP working system.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: We provided a draft of this report to OMB and Treasury and other agencies we reviewed for comment. In its written comments, OMB agreed with this recommendation and cited plans to implement it. As of August 3, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.
    Recommendation: To reasonably assure that the DNP working system is used effectively and consistently, the Director of OMB should develop guidance that clarifies whether the use of DNP's payment integration functionality is required and--if required--the circumstances and process in which agencies may obtain an exemption from this requirement.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: We provided a draft of this report to OMB and Treasury and other agencies we reviewed for comment. In its written comments, OMB agreed with this recommendation and cited plans to implement it. As of August 3, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.
    Recommendation: To reasonably assure that agencies use the DNP working system effectively, the Director of OMB should develop a strategy--and communicate its strategy through guidance--for how agencies should use the DNP working system to complement existing data matching processes and whether and how agencies should consider using the DNP working system to streamline existing data matching. Such guidance may cover how agencies should demonstrate that their data matching processes meet the requirements in the Improper Payments Elimination and Recovery Improvement Act of 2012, whether agencies can decide on their own which specific databases to use, and how agencies should use the functionalities available through the DNP working system.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: We provided a draft of this report to OMB and Treasury and other agencies we reviewed for comment. In its written comments, OMB stated that it generally agreed with the concept of developing a strategy for how agencies should use the Do Not Pay (DNP) working system to complement existing data matching processes and would explore the concept further. As of August 3, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.
    Recommendation: To reasonably assure that agencies develop consistent policies and procedures to verify DNP matches, the Director of OMB should provide additional guidance that outlines when and how agencies should verify DNP matches against a secondary source and provide individuals an opportunity to contest before taking adverse actions as a result of DNP matches.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: We provided a draft of this report to OMB and Treasury and other agencies we reviewed for comment. In its written comments, OMB stated that it agreed with the of consistent policies and procedures and will work with agencies so that their policies and procedures for verifying Do Not Pay (DNP) matches are developed consistently. As of August 3, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.
    Recommendation: To better monitor agency use of the DNP working system once a strategy has been developed, the Director of OMB should develop and implement monitoring mechanisms--such as goals, benchmarks, and performance measures--to evaluate agency use of the DNP working system.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: We provided a draft of this report to OMB and Treasury and other agencies we reviewed for comment. In its written comments, OMB stated that it agreed with the concept of monitoring mechanisms and will continue to work with agencies to reduce improper payments and encourage agencies to establish goals to improve payment accuracy that will be monitored and evaluated by OMB. As of August 3, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.
    Recommendation: To reasonably assure that agency-reported information on use of the DNP working system is reliable, the Director of OMB should develop a process for comparing agency reporting on the use of the DNP working system to available sources, such as OMB guidance and DNP working system adjudication reports.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: We provided a draft of this report to OMB and Treasury and other agencies we reviewed for comment. In its written comments, OMB stated that it agreed with the concept of ensuring that data are reliable and will consider the feasibility of a process to compare agency submissions to available sources to reasonably assure that agency-reported information on use of the Do Not Pay (DNP) working system is reliable. As of August 3, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.
    Recommendation: To reasonably assure that agency-reported information on use of the DNP working system is complete, the Director of OMB should revise its guidance to clarify whether agencies should report on their uses of all of the functionalities of the DNP working system in their agency financial reports.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: We provided a draft of this report to OMB and Treasury and other agencies we reviewed for comment. In its written comments, OMB stated that it agreed with ensuring the completeness of data and will continue to work with agencies and the Chief Financial Officer community to ensure that agency-reported information on the use of the Do Not Pay (DNP) working system is complete. As of August 3, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.
    Recommendation: The Secretary of the Treasury should modify the DNP working system to track adjudication of matches obtained through all functionalities.

    Agency: Department of the Treasury
    Status: Open

    Comments: In a memo dated April 13, 2017, the Department of Treasury (Treasury) stated that it is in the process of evaluating potential solutions to capture information on the impact of Portal functionalities (online single search, continuous monitoring, and batch matching), and has developed a plan with timeframes to assess the technical feasibility as well as user willingness to provide information. However, Treasury stated that it cannot be certain that this evaluation will identify viable solutions, and therefore cannot commit to making any modifications to the working system. Treasury explained, for instance, it may not be possible to design an effective and user-friendly strategy to capture agency decisions to remove an excluded party identified in a continuous monitoring file from a list of approved vendors. Further, Treasury explained that even if it can capture those decisions, it may be even more difficult to assign a dollar value to that decision as there would be no payment pending in this example. Nevertheless, Treasury stated that it is committed to thoroughly evaluating whether a solution is possible, and--if a solution proves feasibly--its goal is to complete a development plan for the implementation of any identified solutions by September 30, 2018.
    Director: James R. McTigue, Jr.
    Phone: (202) 512-9110

    4 open recommendations
    Recommendation: To strengthen efforts to identify and address noncompliance with the EITC, ACTC, and AOTC, the Commissioner of Internal Revenue should direct Refundable Credits Policy and Program Management (RCPPM) to, building on current efforts, develop a comprehensive operational strategy that includes all the RTCs for which RCPPM is responsible. The strategy could include use of error rates and amounts, evaluation and guidance on the proper use of indicators like no-change and default rates, and guidance on how to weigh trade-offs between equity and return on investment in resource allocations.

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

    Comments: As of February 2017, IRS is taking steps toward developing a comprehensive compliance strategy that includes the three refundable tax credits GAO reviewed, as well as the PTC. These steps include initial planning meetings with Lean Six Sigma consultants and refundable credit policy and program managers and soliciting volunteers for the teams needed to develop the strategy. GAO will continue to monitor the progress of this effort.
    Recommendation: To strengthen efforts to identify and address noncompliance with the EITC, ACTC, and AOTC, the Commissioner of Internal Revenue should direct Refundable Credits Policy and Program Management (RCPPM) to assess whether the data received from the Department of Education's Postsecondary Education Participants System (PEPS) database (a) are sufficiently complete and accurate to reliably correct tax returns at filing and (b) provide additional information that could be used to identify returns for examination; if warranted by this research, IRS should use this information to seek legislative authority to correct tax returns at filing based on PEPS data.

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

    Comments: In February 2016, Refundable Credits Policy and Program Management asked Wage & Investment Strategy & Solutions (WISS) to test the Department of Education's Postsecondary Education Participants System database (PEPS) to match and validate the EINS reported on Form 8863, Education Credits. According to IRS, preliminary assessment of the PEPS database indicates that it is not a sufficiently complete database to confirm AOTC eligibility during return processing or post processing. GAO reviewed the study results and submitted several follow-up questions to IRS in May 2017. GAO followed-up with IRS on the status of that information request in June 2017.
    Recommendation: To strengthen efforts to identify and address noncompliance with the EITC, ACTC, and AOTC, the Commissioner of Internal Revenue should direct Refundable Credits Policy and Program Management (RCPPM) to take necessary steps to ensure the reliability of collections data and periodically review that data to (a) compute a collections rate for post-refund enforcement activities and (b) determine what additional analyses would provide useful information about compliance results and costs of post-refund audits and document-matching reviews.

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

    Comments: IRS raised concerns about the cost of studying collections data for post-refund enforcement activities. GAO recognizes that gathering collections data has costs. However, a significant amount of enforcement activity is occurring after refunds have been paid, and use of these data could better inform resource allocation decisions and improve the overall efficiency of enforcement efforts.
    Recommendation: To strengthen efforts to identify and address noncompliance with the EITC, ACTC, and AOTC, the Commissioner of Internal Revenue should direct Refundable Credits Policy and Program Management (RCPPM) to, as RCPPM begins efforts to track the number of erroneous returns claiming the ACTC or AOTC identified through pre-refund enforcement activities, such as screening filters and use of math error authority, it should develop and implement a plan to collect and analyze these data that includes such characteristics as identifying timing goals, resource requirements, and the appropriate methodologies for analyzing and applying the data to compliance issues.

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

    Comments: As of February 2017, IRS is taking steps toward developing a comprehensive compliance strategy that includes the three refundable tax credits GAO reviewed, as well as the PTC. These steps include initial planning meetings with Lean Six Sigma consultants and refundable credit policy and program managers and soliciting volunteers for the teams needed to develop the strategy. GAO will continue to monitor the progress of this effort.
    Director: Carolyn L. Yocom
    Phone: (202) 512-7114

    3 open recommendations
    including 2 priority recommendations
    Recommendation: To improve the effectiveness of states' and plans' Medicaid managed care (MMC) plan provider screening efforts, the Acting Administrator of CMS should consider which additional databases that states and MMC plans use to screen providers could be helpful in improving the effectiveness of these efforts and determine whether any of these databases should be added to the list of databases identified by CMS for screening purposes.

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

    Comments: HHS concurred with this recommendation. CMS analyzed 22 databases that were reported to GAO as being used by Medicaid managed care plans to screen providers. It determined that several were already in use by CMS and mentioned in its guidance, several required more study by CMS, and others were not reliable. In April 2017, we reviewed CMS's analysis. For 8 of the databases, CMS noted that more information is needed, including the availability of the data and whether CMS would need an identifier to link providers to the data. CMS has requested additional information for these databases and has not yet concluded whether the databases should be added to the list of databases it has identified for screening purposes. To close the recommendation, CMS will need to determine whether the remaining databases it has studied should be added to the CMS list of databases to be used for provider screening and take the appropriate action.
    Recommendation: To improve the effectiveness of states' and plans' MMC plan provider screening efforts, the Acting Administrator of CMS should collaborate with SSA to facilitate sharing CMS's Death Master File subscription with state Medicaid programs.

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

    Comments: HHS concurred with this recommendation. CMS has signed an Interagency Agreement that provides for the states' ability to access the SSA Death Master File. CMS said that it will provide Death Master File information to specific individuals within each state in the near future. To close the recommendation, CMS will need to begin to provide the states with access to Death Master File data and provide us with documentation that it has done so.
    Recommendation: To improve the effectiveness of states' and plans' MMC plan provider screening efforts, the Acting Administrator of CMS should coordinate with other federal agencies, as necessary, to explore the use of an identifier that is relevant for the screening of MMC plan providers and common across databases used to screen MMC plan providers.

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

    Comments: HHS concurred with the recommendation. We will update the status of this recommendation when we receive additional information.
    Director: Kathleen M. King
    Phone: (202) 512-7114

    2 open recommendations
    including 2 priority recommendations
    Recommendation: In order to better ensure proper Medicare payments and protect Medicare funds, CMS should seek legislative authority to allow the RAs to conduct prepayment claim reviews.

    Agency: Department of Health and Human Services
    Status: Open
    Priority recommendation

    Comments: In May 2016, we recommended that the Centers for Medicare and Medicaid Services (CMS) should seek legislative authority to allow the Recovery Auditors (RAs) to conduct prepayment claim reviews. The Department of Health and Human Services did not concur with this recommendation. We continue to believe CMS should seek legislative authority to allow RAs to conduct these reviews. Until CMS seeks and implements this authority, it will be missing an opportunity to help identify improper payments before they are made.
    Recommendation: In order to ensure that CMS has the information it needs to evaluate MAC effectiveness in preventing improper payments and to evaluate and compare contractor performance across its Medicare claim review program, CMS should provide the MACs with written guidance on how to accurately calculate and report savings from prepayment claim reviews.

    Agency: Department of Health and Human Services
    Status: Open
    Priority recommendation

    Comments: In May 2016, we recommended that the Centers for Medicare and Medicaid Services (CMS) should provide the Medicare Administrative Contractors (MACs) with written guidance on how to accurately calculate and report savings from prepayment claim reviews. HHS concurred with this recommendation and stated that it will develop a uniform method to calculate savings from prepayment claim reviews and issue guidance to the MACs. According to CMS, as of April 2017, the agency is in the process of developing a methodology for the MACs to use to estimate the amount that CMS would have paid providers had their claims not been denied. We will assess HHS's actions once we can review any guidance provided to the MACs.
    Director: James Cosgrove
    Phone: (202) 512-7114

    5 open recommendations
    including 1 priority recommendation
    Recommendation: As CMS continues to implement and refine the contract-level RADV audit process to improve the efficiency and effectiveness of reducing and recovering improper payments and to improve the accuracy of CMS's calculation of coding intensity, the Administrator should modify that calculation by taking actions such as the following: (1) including only the three most recent pair-years of risk score data for all contracts; (2) standardizing the changes in disease risk scores to account for the expected increase in risk scores for all MA contracts; (3) developing a method of accounting for diagnostic errors not coded by providers, such as requiring that diagnoses added by MA organizations be flagged as supplemental diagnoses in the agency's Encounter Data System to separately calculate coding intensity scores related only to diagnoses that were added through MA organizations' supplemental record review (that is, were not coded by providers); and (4) including MA beneficiaries enrolled in contracts that were renewed from a different contract under the same MA organization during the pair-year period.

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

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As CMS continues to implement and refine the contract-level RADV audit process to improve the efficiency and effectiveness of reducing and recovering improper payments. The Administrator should modify CMS's selection of contracts for contract-level RADV audits to focus on those contracts most likely to have high rates of improper payments by taking actions such as the following: (1) selecting more contracts with the highest coding intensity scores; (2) excluding contracts with low coding intensity scores; (3) selecting contracts with high rates of unsupported diagnoses in prior contract-level RADV audits; (4) if a contract with a high rate of unsupported diagnoses is no longer in operation, selecting a contract under the same MA organization that includes the service area of the prior contract; and (5) selecting some contracts with high enrollment that also have either high rates of unsupported diagnoses in prior contract-level RADV audits or high coding intensity scores.

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

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As CMS continues to implement and refine the contract-level RADV audit process to improve the efficiency and effectiveness of reducing and recovering improper payments. The Administrator should enhance the timeliness of CMS's contract-level RADV process by taking actions such as the following: (1) closely aligning the time frames in CMS's contract-level RADV audits with those of the national RADV audits the agency uses to estimate the MA improper payment rate; (2) reducing the time between notifying MA organizations of contract audit selection and notifying them about the beneficiaries and diagnoses that will be audited; (3) improving the reliability and performance of the agency's process for transferring medical records from MA organizations, including assessing the feasibility of updating Electronic Submission of Medical Documentation for use in transferring medical records in contract-level RADV audits; and (4) requiring that CMS contract-level RADV auditors complete their medical record reviews within a specific number of days comparable to other medical record review time frames in the Medicare program.

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

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As CMS continues to implement and refine the contract-level RADV audit process to improve the efficiency and effectiveness of reducing and recovering improper payments. The Administrator should improve the timeliness of CMS's contract-level RADV appeal process by requiring that reconsideration decisions be rendered within a specified number of days comparable to other medical record review and first-level appeal time frames in the Medicare program.

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

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As CMS continues to implement and refine the contract-level RADV audit process to improve the efficiency and effectiveness of reducing and recovering improper payments. The Administrator should ensure that CMS develops specific plans and a timetable for incorporating a RAC in the MA program as mandated by the Patient Protection and Affordable Care Act.

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

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    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: Carolyn L. Yocom
    Phone: (202) 512-7114

    2 open recommendations
    including 2 priority recommendations
    Recommendation: To improve the effectiveness of its oversight of eligibility determinations, the Administrator of CMS should conduct reviews of federal Medicaid eligibility determinations to ascertain the accuracy of these determinations and institute corrective action plans where necessary.

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

    Comments: The Department of Health and Human Services (HHS) has taken some steps to improve the accuracy of Medicaid eligibility determinations, as GAO recommended in October 2015, but has not conducted a systematic review of federal eligibility determinations. In March 2017, HHS reported that it is reviewing federal determinations of Medicaid eligibility in two of the nine states that have delegated eligibility determination authority to the federal marketplace and HHS is planning to include reviews of federal determinations as part of its future Payment Error Rate Measurement (PERM) reviews, which will resume in 2018 pending final publication of the proposed PERM rule (81 FR 40596). In October 2016, HHS officials provided information indicating that the Department is relying upon operational controls within federally marketplaces to ensure accurate eligibility determinations as well as new processes that would identify duplicate coverage. These actions have value, however, they are not sufficient to identify other types of erroneous eligibility determinations. Without a systematic review of federal eligibility determinations, HHS lacks a mechanism to identify and correct errors and associated payments.
    Recommendation: To increase assurances that states receive an appropriate amount of federal matching funds, the Administrator of CMS should use the information obtained from state and federal eligibility reviews to inform the agency's review of expenditures for different eligibility groups in order to ensure that expenditures are reported correctly and matched appropriately.

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

    Comments: As of October 2016, HHS is establishing a process to make the eligibilty and expenditure reviews interact with one another. GAO will work with the agency to determine if these actions address the recommendation.
    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: Seto J. Bagdoyan
    Phone: (202) 512-6722

    1 open recommendations
    Recommendation: To further improve efforts to limit improper payments, including fraud, in the Medicaid program, the Acting Administrator of CMS should provide guidance to states on the availability of automated information through Medicare's enrollment database--the Provider Enrollment, Chain and Ownership System (PECOS)--and full access to all pertinent PECOS information, such as ownership information, to help screen Medicaid providers more efficiently and effectively.

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

    Comments: HHS considers this recommendation closed because they provide states with training and direct access to PECOS on an ongoing basis. Additionally, CMS also makes Medicare Enrollment data available to states through custom data extracts. We do not consider this action sufficient to close the recommendation, to provide states information on the availability of automated information through PECOS. For example, custom extracts do not constitute automated information containing all information in PECOS states need to screen providers in Medicaid. Additionally, the states the we interviewed for our study were not aware that custom extracts were available. CMS should provide guidance to state Medicaid programs that this information is available until fully automated access to PECOS is available. We reached out to CMS about the status of this recommendation. As of May 2017, we have not received a response. We will continue to monitor progress on this recommendation.
    Director: Beryl H. Davis
    Phone: (202) 512-2623

    3 open recommendations
    Recommendation: To help reduce the risk that improper payment estimates related to DRAA funding developed and reported by selected agencies may not be accurate or reliable, and to help ensure that DOT produces reliable estimates of its DRAA improper payments, as applicable to each administration, the Secretary of Transportation should direct the Administrators of the Federal Aviation Administration, Federal Highway Administration, Federal Railroad Administration, and Federal Transit Administration to revise their policies and procedures for estimating improper payments by: (1) clearly identifying roles and responsibilities for estimating improper payments; (2) defining improper payments consistently with IPIA, as amended, and OMB Circular No. A-123, Appendix C; (3) requiring payments to federal employees to be included in populations for testing as required by IPIA, as amended; (4) including steps to assess the completeness of the population of transactions used for selecting the samples to be tested; (5) requiring the agency to maintain sufficient documentation to support improper payment estimates; (6) requiring that the sampling methodologies meet the precision requirements outlined in OMB Circular No. A-123, Appendix C; and (7) requiring a consultation with a statistician to ensure the validity of sample design, sample size, and measurement methodology.

    Agency: Department of Transportation
    Status: Open

    Comments: On April 14, 2017, we were informed that the Office of the Chief Financial Officer has oversight over the Department of Transportation's (DOT) improper payments implementation and is revising DOT's policies for estimating improper payments. DOT plans to complete this action by 10/31/2017. We will continue to monitor the status of this recommendation.
    Recommendation: To help reduce the risk that improper payment estimates related to DRAA funding developed and reported by selected agencies may not be accurate or reliable, and to help ensure that the Department of Housing and Urban Development produces reliable estimates of its DRAA improper payments, the Secretary of Housing and Urban Development should direct appropriate officials to revise its policies and procedures for estimating improper payments by (1) requiring payments to federal employees to be included in populations for testing as required by the Improper Payments Information Act of 2002 (IPIA), as amended, and (2) including steps to assess the completeness of the population of transactions used for selecting the samples to be tested.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: Overall, we believe the Department of Housing and Urban Development (HUD) is on track for taking corrective actions that meet the intent of GAO recommendation. For example, we believe HUD has met the intent of this recommendation with regards to HUD revising its policies and procedures for estimating improper payments. Specifically, we have reviewed HUD's updated recapture audit plan dated June 26, 2015, and verified it requires payments to federal employees to be included in populations for testing. However, we do not believe HUD has met the intent of this recommendation with regards to including steps to assess the completeness of the population of transactions used for selecting the samples to be tested. Specifically, we have not seen where HUD's policies and procedures show how HUD ensures that it is selecting from a complete list of grantee files when conducting tests related to estimating improper payments. On July 19, 2017, a HUD official explained that HUD does not have controls in place to ensure that the grantee files are complete. Further, the HUD official indicated that the grantee files come from the grantee, and HUD relies on the grantees to provide a complete list of files. However, HUD does not currently have a way to verify that this list is complete. According to the HUD official, HUD he will explore options HUD can implement for ensuring that grantee files are complete, including possibly having grantees to sign a statement certifying that their grantee files are complete when provided to HUD. We will continue to monitor the agency's actions to address this recommendation.
    Recommendation: To help reduce the risk that improper payment estimates related to DRAA funding developed and reported by selected agencies may not be accurate or reliable, and to help ensure that the U.S. Army Corps of Engineers (USACE) produces reliable estimates of its DRAA improper payments, the Secretary of the Army should direct the Chief of Engineers and Commanding General of USACE to revise policies and procedures for estimating improper payments by: (1) defining improper payments consistently with IPIA, as amended, and OMB Circular No. A-123, Appendix C; (2) requiring payments to federal employees to be included in populations for testing as required by IPIA, as amended; (3) including steps to assess the completeness of the population of transactions used for selecting the samples to be tested; (4) providing sufficient procedures for determining an error and what documentation is necessary to substantiate payment; and (5) requiring the agency to maintain sufficient documentation to support improper payment estimates.

    Agency: Department of Defense: Department of the Army
    Status: Open

    Comments: As of June 5, 2017, no updated information has been provided by the Department of Defense. We will continue to monitor the status of this recommendation.
    Director: Vijay D'Souza
    Phone: (202) 512-7114

    2 open recommendations
    including 2 priority recommendations
    Recommendation: To better assess and address the full extent of improper payments in the TRICARE program, the Secretary of Defense should direct the Assistant Secretary of Defense (Health Affairs) to implement a more comprehensive TRICARE improper payment measurement methodology that includes medical record reviews, as done in other parts of its existing postpayment claims review programs.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: The Department of Defense's Defense Health Agency (DHA) has taken some action to incorporate medical record reviews in its improper payment estimate, as GAO recommended in February 2015. In October 2016, DHA released a request for proposals for claim record reviews, including medical record reviews, that the agency plans to use to support the agency's requirement to identify and report on the potential of improper payments to the Office of Management and Budget. This is a good first step. Once DHA incorporates medical record reviews in its improper payment rate calculation methodology, GAO will be able to close this recommendation.
    Recommendation: To better assess and address the full extent of improper payments in the TRICARE program, and once a more comprehensive improper payment methodology is implemented, the Secretary of Defense should direct the Assistant Secretary of Defense (Health Affairs) to develop more robust corrective action plans that address underlying causes of improper payments, as determined by the medical record reviews.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: Until the department implements a more comprehensive TRICARE improper payment measurement methodology and identifies the underlying causes of improper payments, the full extent of improper payments in the TRICARE program will likely not be identified and addressed. As of October 2016, the Department of Defense's Defense Health Agency has not yet implemented a more comprehensive TRICARE improper payment measurement methodology, and has, therefore, not developed more robust corrective action plans.
    Director: Melvin, Valerie C
    Phone: (202) 512-6304

    1 open recommendations
    Recommendation: To ensure that the federal government's and states' investments in information systems result in outcomes that are effective in supporting efforts to save funds through the prevention and detection of improper payments in the Medicaid program, the Secretary of Health and Human Services should direct the Administrator of CMS to require states to measure quantifiable benefits, such as cost reductions or avoidance, achieved as a result of operating information systems to help prevent and detect improper payments. Such measurement of benefits should reflect a consistent and repeatable approach and should be reported when requesting approval for matching federal funds to support ongoing operation and maintenance of systems that were implemented to support Medicaid program integrity purposes.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: In comments on our report, agency officials agreed with this recommendation and provided information on CMS's plans to use a template to track cost savings resulting from state Medicaid offices' use of information systems for program integrity purposes. In April 2017, CMS officials said that they were no longer planning to use the template to gather information from the states, because of the varied approaches that states take to implement systems support for program integrity purposes. The officials stated that they are developing an alternative approach for capturing this information from the states, which will be provided to us when completed. We will continue to monitor CMS's progress toward addressing the recommendation.
    Director: David C. Trimble
    Phone: (202) 512-3841

    5 open recommendations
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and direct field office sites with responsibility for non-M&O contractor risk assessments to address risk factors as they relate to those sites and take steps to ensure sites implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal year 2015 and 2016 improper payments guidance. The revised guidance directs field office sites with responsibility for non-M&O contractor risk assessments to address risk factors as they relate to those sites. The guidance further requires each site Chief Financial Officer to certify to the accuracy of improper payments and risk rating. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and clarify how payment sites are to address risk factors and document the basis for their risk rating determinations and take steps to ensure sites implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal years 2015 and 2016 improper payments guidance requiring sites to prepare risk assessments using a new risk assessment format. The guidance states that the new format was developed to improve consistency among the sites and improve documentation supporting the risk ratings. In the new format, each risk factor includes a description of the risk factor, rating criteria and/or questions to consider during the evaluation to assist sites in determining a risk rating by payment type. The guidance also requires all sites to maintain supporting documentation for their risk assessment. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and clarify who is responsible at DOE for reviewing and approving risk assessments for consistency across sites and take steps to ensure those entities implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal years 2015 and 2016 improper payments guidance to require site Chief Financial Officers and the Director of Risk Management of the Loan Programs Office to provide a signed certification to DOE's Director of the Office of Finance and Accounting certifying to the accuracy of improper payments and the risk assessment and rating submitted. The guidance provides templates for these certifications. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and provide specific examples of other risk factors that present inherent risks likely to contribute to significant improper payments, in addition to the eight risk factors, direct payment sites to consider those when performing their improper payment risk assessments, and take steps to ensure sites implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal year 2015 and 2016 improper payments guidance. In addition to the required OMB risk factors, the guidance added the following additional risk factors to be included in the risk assessments: (1) contractor payment processing oversight and (2) segregation of duties. The guidance states these factors have been added to ensure that inherently high-risk areas that can contribute to a site's susceptibility to significant improper payments are properly evaluated. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To provide better transparency regarding its total known improper payments reported under IPERA, the Secretary of Energy should direct the department's Chief Financial Officer to improve public reporting on the amount of total known improper payments by disclosing additional information regarding this amount and the extent to which improper payments could be occurring.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had added supplemental information to its fiscal year 2016 Agency Financial Report. We will continue to gather additional information from DOE to determine the extent to which this information addresses the amount of total known improper payments.
    Director: Dave Wise
    Phone: (202) 512-2834

    3 open recommendations
    Recommendation: To promote and enhance federal, state, and local NEMT coordination activities, the Secretary of Transportation, as the chair of the Coordinating Council, should convene a meeting of the member agencies of the Coordinating Council and complete and publish a new or updated strategic plan that, among other things, clearly outlines a strategy for addressing NEMT and how it can be coordinated across federal agencies that fund NEMT service.

    Agency: Department of Transportation
    Status: Open

    Comments: The Federal Transit Administration (FTA) concurred with this recommendation. As of November 2016, FTA stated that Administrator-level members of the Coordinating Council on Access and Mobility (CCAM) met in July 2016 to begin the process of developing a strategic plan. A follow-up meeting of the same group is planned for December 2016. According to FTA, it is anticipated this meeting will result in agreement on a strategic plan framework and that interagency working groups will begin implementation of the framework in early 2017. Based on the minutes of the July 2016 CCAM meeting, emerging themes identified for the strategic plan included improved access to medical care and to better coordinate transportation planning, particularly integrating transportation planning into healthcare planning. This recommendation will be kept open pending finalization of the strategic plan framework and how it relates to NEMT.
    Recommendation: To promote and enhance federal, state, and local NEMT coordination activities, the Secretary of Transportation, as the chair of the Coordinating Council, should convene a meeting of the member agencies of the Coordinating Council and finalize and issue a cost-sharing policy and clearly identify how it can be applied to programs under the purview of member agencies of the Coordinating Council that provide funding for NEMT.

    Agency: Department of Transportation
    Status: Open

    Comments: FTA concurred with this recommendation. As of November 2016, FTA stated that Administrator-level members of the Coordinating Council on Access and Mobility met in July 2016 to begin the process of developing a strategic plan. A follow-up meeting of the same group is planned for December 2016. According to FTA, it is anticipated the December meeting will result in agreement on a strategic plan framework and that interagency working groups will begin implementing the plan in early 2017. FTA expects development of a cost-sharing policy and proposed model will be an objective in the strategic plan. We plan to keep this recommendation open pending completion of the strategic plan framework and further information related to implementing this recommendation.
    Recommendation: To promote and enhance federal, state, and local NEMT coordination activities, the Secretary of Transportation, as the chair of the Coordinating Council, should convene a meeting of the member agencies of the Coordinating Council and using the on-going work of the Health, Wellness, and Transportation working group and other appropriate resources, (1) identify the challenges associated with coordinating Medicaid and VA NEMT programs with other federal programs that fund NEMT, (2) develop recommendations for how these challenges can be addressed while still maintaining program integrity and fraud prevention, and (3) report these recommendations to appropriate committees of Congress. To the extent feasible, the Coordinating Council should implement those recommendations that are within its legal authority.

    Agency: Department of Transportation
    Status: Open

    Comments: FTA said they concurred in part with this recommendation. FTA announced the selection of 19 Rides to Wellness Demonstration and Innovative Coordinated Access and Mobility pilot projects, totally about $7.3 million, in September 2016. According to FTA, seven of the 19 projects have a NEMT focus. In addition, during 2016 FTA conducted outreach sessions in various cities throughout the United States to discuss partnership opportunities between the health and transportation industries. FTA stated that a new series of NEMT-specific listening sessions is now underway and additional sessions are planned for 2017. The purpose of these sessions is to identify challenges related to NEMT coordination that will be addressed by Coordinating Council on Access and Mobility (CCAM) working groups in the future. CCAM is also in the process of developing a strategic plan framework. FTA anticipates agreement on this framework in December 2016. The Fixing America's Surface Transportation (FAST) Act requires CCAM to develop and publish a strategic plan. FTA anticipates issues related to this recommendation will be developed through 2020. We plan to keep this recommendation open to further monitor CCAM and FTA progress and the extent challenges are identified and addressed related to better coordinating Medicaid and VA NEMT with other NEMT programs in the federal government, through the strategic plan framework or other actions resulting from the listening sessions.
    Director: Kay E. Brown
    Phone: (202) 512-7215

    2 open recommendations
    Recommendation: The Secretary of Agriculture should direct the Administrator of FNS to establish additional guidance to help states analyze SNAP transaction data to better identify SNAP recipient households receiving replacement cards that are potentially engaging in trafficking, and assess whether the use of replacement card benefit periods may better focus this analysis on high-risk households potentially engaged in trafficking.

    Agency: Department of Agriculture
    Status: Open

    Comments: FNS officials reported that, in September 2013, they awarded a contract to provide expert business consultation and technical assistance in the area of recipient fraud prevention and detection to 7 states. The purpose of the contract was to improve how effectively recipients suspected of trafficking SNAP benefits were identified and investigated, including the use of predictive analytics involving transaction and replacement card data to uncover potential recipient trafficking. As of August 2017, FNS officials reported that they have completed studies in 10 states, helping the states build predictive analytics models that incorporate use of replacement card data to better identify SNAP recipient trafficking. FNS officials report that the models have demonstrated a significant improvement in state effectiveness. FNS officials also report that, in the fourth quarter of fiscal year 2016, the agency conducted a training program for state technical staff to teach them how to build predictive models that incorporate the use of replacement card data. In addition, FNS officials report that the agency is currently developing a SNAP Fraud Framework to provide guidance to states on improving fraud prevention and detection, including the use of excessive card replacements and other data sources, as potential indicators of fraud. FNS tentatively anticipates releasing the framework by the end of calendar year 2017. GAO will monitor these efforts and await information, including related technical assistance materials and documentation, on how these activities are used to guide states' efforts to use transaction and replacement card data to better focus on high-risk households for potential investigation.
    Recommendation: The Secretary of Agriculture should direct the Administrator of FNS to reassess the effectiveness of the current guidance and tools recommended to states for monitoring e-commerce and social media websites, and use this information to enhance the effectiveness of the current guidance and tools.

    Agency: Department of Agriculture
    Status: Open

    Comments: FNS officials reported that, in 2016, the agency conducted additional analysis to evaluate states' current use of social media in their detection of SNAP trafficking and develop a proof of concept for the use of market-leading tools to assist states in more efficient monitoring. Based on the information gained through this analysis, FNS officials reported in August 2017 that a draft of the social media guidance is currently in FNS clearance and is expected to be released by the end of the calendar year. GAO will await the issuance of this guidance.
    Director: Kathleen M. King
    Phone: (202) 512-7114

    1 open recommendations
    including 1 priority recommendation
    Recommendation: In order to improve the efficiency and effectiveness of Medicare postpayment claims review efforts and simplify compliance for providers, the Administrator of CMS should monitor the Recovery Audit Data Warehouse to ensure that all postpayment review contractors are submitting required data and that the data the database contains are accurate and complete.

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

    Comments: As of March 2017, CMS had taken initial steps to monitor the Recovery Audit Data Warehouse, including implementing a new process to monitor monthly compliance reports on the data that contractors enter into the Warehouse. However, CMS noted that as it is in the beginning stages of implementing these compliance reports, it does not currently verify that contractors upload all of the records that they reviewed, nor does it assess the accuracy of the records they entered into the Warehouse. Also, CMS indicated that it does not currently monitor whether certain contractors "suppress" claims in the Warehouse that those contractors are considering for review as part of an investigation. CMS said it was considering additional options for future monitoring of compliance reports, but did not indicate when it would determine what additional steps to take. To close this recommendation, CMS should take additional steps to improve its oversight of the Recovery Audit Data Warehouse, such as verifying that contractors upload all of the records that they reviewed and taking steps to assess the accuracy of the records they uploaded.
    Director: James R. McTigue, Jr.
    Phone: (202) 512-9110

    1 open recommendations
    Recommendation: If Congress agrees that significant paid preparer errors exist, it should consider legislation granting IRS the authority to regulate paid tax preparers.

    Agency: Congress
    Status: Open

    Comments: In 2017, several bills were introduced in Congress that would authorize the Department of Treasury to regulate paid tax return preparers. As of September 2017, no action has been taken on any of the bills. GAO testified on October 1, 2015 on improper payments and the tax gap before Senate Finance and on December 10, 2015 on GAO recommendations before the Subcommittee on Regulatory Affairs and Federal Management, Committee on Homeland Security and Governmental Affairs, US Senate. Both hearings increased attention to GAO's matter to Congress that tax preparers be regulated. Paid preparer regulation may increase the accuracy of tax returns and potentially reduce the tax gap.
    Director: Wilshusen, Gregory C
    Phone: (202) 512-6244

    17 open recommendations
    Recommendation: To make government-wide computer matching program planning efforts more consistent, the Director of OMB should revise guidance on computer matching to clarify whether front-end verification queries are covered by the Computer Matching Act.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: We have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To make government-wide computer matching program planning efforts more consistent, the Director of OMB should direct agencies to address all key elements when preparing cost-benefit analyses.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To make government-wide computer matching program planning efforts more consistent, the Director of OMB should ensure that agencies receive assistance in implementing computer matching programs as envisioned by the act.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Agriculture should develop and implement policies and procedures for cost-benefit analyses related to computer matching agreements to include key elements such as personnel and computer costs, as well as avoidance of future improper payments and recovery of improper payments and debts.

    Agency: Department of Agriculture
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Agriculture should ensure the DIB reviews cost-benefit analyses to make certain cost savings information for the computer matching program is included before approving CMAs.

    Agency: Department of Agriculture
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Agriculture should ensure the DIB performs annual reviews and submits annual reports on the agency's computer matching activities, as required by the act.

    Agency: Department of Agriculture
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Education should develop and implement policies and procedures for cost-benefit analyses related to computer matching agreements to include key elements such as personnel and computer costs, as well as avoidance of future improper payments and recovery of improper payments and debts.

    Agency: Department of Education
    Status: Open

    Comments: We have not yet received sufficient information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Health and Human Services should ensure the DIB reviews cost-benefit analyses to make certain cost savings information for the computer matching program is included before approving CMAs.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: We have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Health and Human Services should ensure the DIB performs annual reviews and submits annual reports on agency computer matching activities, as required by the act.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: We have not yet received information needed to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Homeland Security should develop and implement policies and procedures for cost-benefit analyses related to computer matching agreements to include key elements such as personnel and computer costs, as well as avoidance of future improper payments and recovery of improper payments and debts.

    Agency: Department of Homeland Security
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Homeland Security should ensure the DIB reviews cost-benefit analyses to make certain cost savings information for the computer matching program is included before approving CMAs.

    Agency: Department of Homeland Security
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Homeland Security should ensure the DIB performs annual reviews and submits annual reports on agency computer matching activities, as required by the act.

    Agency: Department of Homeland Security
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Labor should develop and implement policies and procedures for cost-benefit analyses related to computer matching agreements to include key elements such as personnel and computer costs, as well as avoidance of future improper payments and recovery of improper payments and debts.

    Agency: Department of Labor
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Labor should ensure the DIB reviews cost-benefit analyses to make certain cost savings information for the computer matching program is included before approving CMAs.

    Agency: Department of Labor
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Labor should ensure the DIB performs annual reviews and submits annual reports on agency computer matching activities, as required by the act.

    Agency: Department of Labor
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Secretary of Veterans Affairs should ensure the DIB reviews cost-benefit analyses to make certain cost savings information for the computer matching program is included before approving CMAs.

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: We have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Recommendation: To improve the implementation of the act, the Administrator of Social Security should ensure the DIB performs annual reviews and submits annual reports on agency computer matching activities, as required by the act.

    Agency: Social Security Administration
    Status: Open

    Comments: We have not yet received information to validate agency actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.
    Director: Bertoni, Daniel
    Phone: (202) 512-7215

    2 open recommendations
    Recommendation: In order to enhance the accuracy of and ensure appropriate agency access to SSA's death data, and to clarify how SSA applies the eligibility requirements of the Social Security Act and enhance agencies' awareness of how to obtain access, the Social Security Administration's Acting Commissioner should direct the Deputy Commissioner of Operations to develop and publicize guidance it will use to determine whether agencies are eligible to receive SSA's full death file.

    Agency: Social Security Administration
    Status: Open

    Comments: The Social Security Administration (SSA) disagreed with this recommendation, stating that each request to obtain the full death file is unique, and that officials must review them on a case-by-case basis to ensure compliance with various legal requirements. It also expressed concern that developing this guidance as we recommended would require agency expenditures unrelated to its mission in an already fiscally constrained environment. SSA noted that any federal agency that would like to explore accessing the full death master file (which includes state death records) should submit a request to SSA. SSA will review the file and, if satisfactory, enter into an Information Exchange Agreement covering terms, conditions and reimbursement for the exchange. As of April 2017, SSA reports that it is continuing its efforts and there is no change in status. GAO appreciates that agencies may base their request for the full death file on different intended uses, and supports SSA's efforts to ensure compliance with all applicable legal requirements. However, developing such guidance could help to ensure consistency in SSA's future decision making by the new Office of Data Exchange, and enhance agencies' ability to obtain the data in a timely and efficient manner.
    Recommendation: In order to enhance the accuracy of and ensure appropriate agency access to SSA's death data, and to increase transparency among recipient agencies, the Social Security Administration's Acting Commissioner should direct the Deputy Commissioner of Operations to share a more detailed explanation of how it determines reimbursement amounts for providing agencies with death information.

    Agency: Social Security Administration
    Status: Open

    Comments: The Social Security Administration (SSA) reported that it has implemented improvements in its estimating procedures for future reimbursable agreements to ensure consistent estimates for all customers. It reviews all reimbursable requests on a case-by-case basis to determine full costs (including direct and indirect expenses) to provide goods, resources, or services. However, the agency stated that it is not a typical government business practice to share these detailed costs for reimbursable agreements. As of April 2017, SSA reports that it is continuing its efforts and there is no change in status. We are encouraged that SSA has made efforts to standardize the estimates it shares with its federal partners. While we recognize that there may be limitations on the type of cost details SSA can provide to recipient agencies, we continue to believe that more transparency in conveying the factors that lead to the estimated and final reimbursement amounts recipient agencies are charged could help them make more informed decisions.
    Director: Davis, Beryl H
    Phone: (202) 512-2623

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To proactively prepare for oversight of future disaster relief funding, the Director of OMB should develop standard guidance for federal agencies to use in designing internal control plans for disaster relief funding. Such guidance could leverage existing internal control review processes and should include, at a minimum, the following elements: (1) robust criteria for identifying and documenting incremental risks and mitigating controls related to the funding and (2) requirements for documenting the linkage between the incremental risks related to disaster funding and efforts to address known internal control risks.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: To address the recommendation, OMB should issue guidance on internal control for disaster relief funding, including criteria for identifying additional risks and mitigating controls related to the funding and a requirement to link these incremental risks to ongoing efforts to address known internal control risks. On July 15, 2016, OMB issued the revised Circular No. A-123, Management's Responsibility for Enterprise Risk Management and Internal Control. The Circular requires agencies to implement enterprise risk management, which includes the development of a risk profile that analyzes the risks faced in achieving strategic objectives and identifies options for addressing them. In April 2017, OMB staff stated that they believe that the implementation of enterprise risk management through Circular No. A-123 satisfies the intent our recommendation. Because the responsibility for implementing enterprise risk management lies with agency management, Circular No. A-123 does not include specific guidance for identifying risks related to disaster funding. Further discussion and documentation to support OMB's position that the revised Circular addresses our recommendation will be necessary.
    Director: Garcia-diaz, Daniel
    Phone: (202) 512-3841

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To further improve agency controls that help prevent payments to participants whose incomes exceed eligibility limits, the Secretary of Agriculture should direct the Administrator of FSA to implement a process to verify that accountants' and attorneys' statements accurately reflect participants' incomes as reported on income tax returns and supporting documentation or other equivalent documents.

    Agency: Department of Agriculture
    Status: Open
    Priority recommendation

    Comments: The Department agreed with this recommendation at the time of our report but, as of April 2017, has not acted to implement it because of the sensitive nature of questioning accountants' and attorneys' professional judgement. However, we believe doing so would reduce the likelihood of improper payments supported by U.S. taxpayers and would be an appropriate action for the agency to take.
    Director: Bagdoyan, Seto J
    Phone: (202) 512-4749

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To improve SSA's ability to detect and prevent potential DI cash benefit overpayments due to work activity during the 5-month waiting period, the Commissioner of Social Security should assess the costs and feasibility of establishing a mechanism to detect potentially disqualifying earnings during all months of the waiting period, including those months of earnings that the agency's enforcement operation does not currently detect and implement this mechanism, to the extent that an analysis determines it is cost-effective and feasible.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: While the Social Security Administration (SSA) initially concurred with our August 2013 recommendation, as of February 2017, SSA has not assessed costs and feasibility of establishing a mechanism to detect potentially disqualifying earnings during all months of the waiting period. Instead, SSA concluded that conducting a study at this time would yield unreliable information because the agency's ability to obtain and track earnings from alternative sources is changing due to several requirements of the Bipartisan Budget Act of 2016, which SSA believes will likely affect GAO's concerns. GAO continues to believe that undertaking an analysis to assess costs and feasibility could provide SSA with more comprehensive information with which to decide on potential revisions to its enforcement operation. We will continue to monitor SSA's efforts in this area.
    Director: Bagdoyan, Seto J
    Phone: (202) 512-4749

    1 open recommendations
    Recommendation: Congress should consider granting Labor the additional authority it is seeking to access wage data to help verify claimants' reported income and help ensure the proper payment of benefits.

    Agency: Congress
    Status: Open

    Comments: No legislation introduced as of February 2017. The Workers' Compensation Reform Act of 2015 (S. 2051, title V) was introduced in the 114th Congress. It would have allowed DOL to access wage data, as GAO suggested in April 2013, from the National Directory of New Hires to improve the integrity of the Federal Employees' Compensation Act program, among other actions. If introduced in the 115th Congress and enacted, this legislation could help to prevent and detect improper payments in the Federal Employees' Compensation Act program.
    Director: Cosgrove, James C
    Phone: (202) 512-7114

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To reduce the incentive for facilities to restrict their service provision to avoid reaching the LVPA treatment threshold, the Administrator of CMS should consider revisions such as changing the LVPA to a tiered adjustment.

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

    Comments: CMS stated in April 2017 that the agency would continue examining the performance of the LVPA to determine whether a tiered adjustment is warranted.
    Director: King, Kathleen M
    Phone: (202) 512-7114

    1 open recommendations
    including 1 priority recommendation
    Recommendation: In order to promote greater use of effective prepayment edits and better ensure proper payment, and to promote implementation of effective edits based on national policies, the CMS Administrator should develop written procedures to provide guidance to agency staff on all steps in the processes for developing and implementing edits based on national policies, including (1) time frames for taking corrective actions, (2) methods for assessing the effects of corrective actions, and (3) procedures for ensuring consideration of automated edits whenever possible, including for all existing NCDs and other national policies.

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

    Comments: HHS concurred with this recommendation. CMS developed written procedures in November 2012 to provide guidance to agency staff on procedures for ensuring consideration of automated edits whenever possible, as GAO recommended in November 2012, but these procedures do not include several key elements of GAO's recommendation. For example, the written procedures do not include time frames for making decisions on whether an edit will be developed for all existing National Coverage Determinations (NCD) and national policies. The written procedures also do not include requirements for methods to assess the effects of corrective actions taken. Implementing a comprehensive written process for developing edits for national policies could help ensure that edits are implemented whenever possible to reduce improper payments. As of September 2017, CMS had not provided us updated documentation that addressed these aspects of our recommendation. Once received, we will review the information and update this recommendation accordingly.
    Director: Melvin, Valerie C
    Phone: (202)512-6304

    2 open recommendations
    Recommendation: To help ensure that the development and implementation of IDR and One PI are successful in helping the agency meet the goals and objectives of its program integrity initiatives, the Administrator of CMS should implement and manage plans for incorporating data in IDR to meet schedule milestones.

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

    Comments: While CMS has incorporated shared systems Medicare Part A (insurance for hospital and other inpatient services), Part B (insurance for hospital outpatient, physician, and other services), and three states' Medicaid data into IDR, it has not yet implemented and managed plans for incorporating all states' Medicaid data, as GAO recommended in June 2011. As a result, the repository does not yet include all the data that were planned to be incorporated by the end of 2012, and efforts to add the remaining states' Medicaid data to IDR continue to be behind schedule. As of March 2017, agency officials are working to develop plans to integrate all states' data into IDR as part of ongoing program integrity initiatives.
    Recommendation: To help ensure that the development and implementation of IDR and One PI are successful in helping the agency meet the goals and objectives of its program integrity initiatives, the Administrator of CMS should define any measurable financial benefits expected from the implementation of IDR and One PI.

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

    Comments: As of March 2017, CMS officials reported that they have identified areas of potential cost savings to be achieved by requiring program integrity contractors to use IDR and One PI, as GAO recommended in June 2011. CMS is awarding new contracts to include this requirement, which is expected to result in the agency no longer funding contractors' efforts to establish and maintain their own data warehouses and analytical tools. However, not all of the contracts have been awarded and, therefore, the requirement has not been fully implemented. Until all the new contracts have been awarded that require the contractors to use IDR and One PI for program integrity purposes, CMS will not have reasonable assurance that using the systems will help improve CMS's ability to detect fraud, waste, and abuse in the Medicare and Medicaid programs, and to achieve the $21 billion in financial benefits program officials projected.
    Director: Cosgrove, James C
    Phone: (202)512-7029

    1 open recommendations
    Recommendation: To ensure that savings are realized from the implementation of an MPPR or other policies that reflect efficiencies occurring when services are furnished together, Congress may wish to consider exempting these savings from budget neutrality.

    Agency: Congress
    Status: Open

    Comments: As of May 2017, we are awaiting an update from HHS on the status of this recommendation. We will update the status of this recommendation when we receive additional information.
    Director: Aronovitz, Leslie G
    Phone: (312)220-7767

    1 open recommendations
    Recommendation: The Administrator of CMS should require the PSCs to develop thresholds for unexplained increases in billing--and use them to develop automated prepayment controls as one component of their manual medical review strategies.

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

    Comments: Despite progress in identifying potentially improper groups of claims by provider, CMS has not developed thresholds for unexplained increases in billing by providers and used them to develop automated prepayment controls, as GAO recommended in January 2007. CMS took action in July 2011 to improve Medicare payment accuracy by introducing predictive analytics to help identify patterns of potentially improper claims and has some other prepayment controls in place. Specifically, the Small Business Jobs Act of 2010 requires CMS to use predictive modeling and other analytic techniques?known as predictive analytic technologies?to identify improper claims and prevent improper payments under the Medicare fee-for-service program. CMS is streaming every Medicare fee-for-service claim through a predictive modeling technology system, known as the Fraud Prevention System (FPS), prior to payment. The FPS uses a series of algorithms to identify potentially fraudulent claims. As each claim streams through the FPS, the system builds profiles of providers, networks, and billing patterns. Using these profiles, CMS estimates a claim's likelihood of being fraudulent and prioritizes providers with the most suspicious groups of claims for further investigation. CMS also has other prepayment controls in place, for example, to identify duplicate billing. As of December 2015, CMS did have algorithms in FPS to flag providers with unexpected increases in billings for investigation. CMS also instituted prepayment controls that can deny a claim before payment, however these controls are related to Medicare coverage requirements and do not address the issue of large increases in provider billing. Prepayment controls can suspend claims processing or deny claims before claims are paid, which would provide a greater assurance that Medicare funds are not going to potentially fraudulent providers. As of August 2016, HHS officials reported that they have not implemented this recommendation. GAO considers it to be open. We will update the status of this recommendation when we receive additional information.
    Director: Daly, Kay L
    Phone: 2025166906

    1 open recommendations
    Recommendation: To help further the progress toward meeting the goals of IPIA and determining states' role in assisting federal agencies to report a national improper payment estimate on federal programs, the Director, Office of Management and Budget, should expand IPIA guidance to provide criteria that federal agencies should consider when developing a plan or methodology for estimating a national improper payment estimate for state-administered programs, such as criteria that address the nature and extent of data and documentation needed from the states to calculate a national improper payment estimate.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: On August 10, 2006, OMB issued its revised guidance to implement the Improper Payments Information Act of 2002 (IPIA)--OMB Circular No. A-123, Appendix C "Requirements for Effective Measurement and Remediation of Improper Payments." OMB expanded its guidance to define federally funded state-administered programs and provided that federal agencies, upon the approval of OMB, could implement alternative methodologies for generating a national improper payment estimate for state-administered programs such as a systematic selection of States each year. The IPIA guidance provides that as part of the justification for using an alternative methodology, the federal agency must include a description of the States selected each year, the methodology for generating annual national estimates, and basis for using an alternative approach rather than the required methodology to calculate the national estimate based on a random statistical sample. While this revision, if fully and effectively implemented, may improve OMB's ability to carry out its oversight responsibilities with respect to determining appropriate methodologies to be employed in generating a program's improper payment estimate, these revisions did not include criteria that agencies should consider in developing plans or methodologies for estimating a national improper payment estimate for state-administered programs--the essence of our recommendation. In fiscal year 2017, we sent a follow inquiry to the OMB to get an update of actions it has taken to address this recommendation. As of August 24, 2017, no updated information has been provided by the OMB. We will continue to monitor the status of this recommendation.