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    Subject Term: "Improper payments"

    40 publications with a total of 133 open recommendations including 30 priority recommendations
    Director: Seto Bagdoyan
    Phone: (202) 512-6722

    3 open recommendations
    Recommendation: The Administrator of CMS should provide fraud-awareness training relevant to risks facing CMS programs and require new hires to undergo such training and all employees to undergo training on a recurring basis. (Recommendation 1)

    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: The Administrator of CMS should conduct fraud risk assessments for Medicare and Medicaid to include respective fraud risk profiles and plans for regularly updating the assessments and profiles. (Recommendation 2)

    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: The Administrator of CMS should, using the results of the fraud risk assessments for Medicare and Medicaid, create, document, implement, and communicate an antifraud strategy that is aligned with and responsive to regularly assessed fraud risks. This strategy should include an approach for monitoring and evaluation. (Recommendation 3)

    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: Beryl H. Davis
    Phone: (202) 512-2623

    1 open recommendations
    Recommendation: The Administrator of NASA should take steps to revise the agency's procedures for conducting improper payment risk assessments to include the activities of its Office of Inspector General in its risk assessment process to help ensure that all programs and activities are assessed for susceptibility to significant improper payments at least once every 3 years as required by the Improper Payments Information Act of 2002. (Recommendation 1)

    Agency: National Aeronautics and Space Administration
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Courts, Michael J
    Phone: (202) 512-8980

    3 open recommendations
    Recommendation: The Director of the Office of Allowances (ALS) should clearly document how the conditions at relevant posts meet the criteria for Director Points to ensure that hardship pay rates for overseas posts are consistently determined across posts and tenures of ALS Directors. (Recommendation 1)

    Agency: Department of State
    Status: Open

    Comments: In commenting on the report State concurred with the recommendation. We are awaiting evidence of their documentation to ensure the consistent determination of Director points.
    Recommendation: The Undersecretary of Management should assess the cost-effectiveness of State's policies and procedures for stopping and starting hardship pay for employees who temporarily leave their assigned overseas posts. (Recommendation 2)

    Agency: Department of State
    Status: Open

    Comments: In commenting on the report State concurred with the recommendation. We are awaiting evidence of their review and assessment of the cost-effectiveness of policies, procedures, and processes for stopping and starting hardship pay for employees who temporarily leave their assigned post.
    Recommendation: The Department's Comptroller should analyze available diplomatic cable data from overseas posts to identify posts at risk of improper payments for hardship pay, identify any improper payments, and take steps to recover and prevent them. (Recommendation 3)

    Agency: Department of State
    Status: Open

    Comments: In commenting on the report, State concurred with the recommendation. We are awaiting evidence of their efforts to enhance analytical tools to ensure posts are properly identifying and reporting starts and stops for hardship pay, and to identify, recover, and prevent improper payments.
    Director: Beryl H. Davis
    Phone: (202) 512-2623

    15 open 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

    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

    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

    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

    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: Allison Bawden
    Phone: (202) 512-7215

    6 open recommendations
    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should ensure that CNCS completes its efforts to benchmark its assessment criteria and scoring process to further develop a risk-based approach to grant monitoring and that information from this effort is used to (a) score the indicators so that the riskiest grants get the highest scores; (b) revise the assessment indicators to meaningfully cover all identifiable risks, including fraud and improper payments; and (c) document decisions on how indicators are selected and weighted.

    Agency: Corporation for National and Community Service
    Status: Open

    Comments: CNCS stated that it would continue to periodically benchmark its assessment criteria to ensure risk assessment. The agency recognizes the need to move from compliance- to risk-based monitoring and will refine its existing approach as part of reviewing and revising risk criteria and scoring. The agency's risk-based approach will begin with FY18 grant awards. To close this recommendation, CNCS will need to show documentation for how it selected and weighted revised indicators to cover identifiable risks, and how the revised scoring system identifies the riskiest grants.
    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should establish and implement a policy to ensure that all grants expected to be active in a fiscal year, including those awarded after the annual assessment, are assessed for potential risk.

    Agency: Corporation for National and Community Service
    Status: Open

    Comments: CNCS agrees with this recommendation and plans to revise its current assessment policy to ensure that all grants are included in the assessment process.
    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should review monitoring protocols, including the level of information collected for oversight of subrecipients' activities such as criminal history checks, and enhance protocols, as appropriate.

    Agency: Corporation for National and Community Service
    Status: Open

    Comments: Although CNCS said that by regulation, grantees are primarily responsible for subgrantee monitoring, the agency acknowledged that more needs to be done to address risk at the sub-recipient level, particularly regarding criminal history check compliance, and noted that it is taking several actions to improve criminal history check compliance. However, the agency's comments did not specifically address reviewing monitoring protocols. We continue to believe that it is important to determine whether monitoring protocols are designed to gather sufficient and appropriate information on subrecipient oversight, to help ensure that grantees are monitoring subgrantees as required.
    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should establish activities to systematically evaluate grant monitoring results.

    Agency: Corporation for National and Community Service
    Status: Open

    Comments: CNCS said that its Office of the Chief Risk Officer has been building on the agency's current risk assessment framework and capturing the information and data necessary to enhance its approach to risk-based monitoring. However, CNCS's comments did not specifically address any planned activities to systematically evaluate grant monitoring results. We continue to believe that reviewing the outcomes and findings from its monitoring activities would help the agency analyze how well its CNCS's current efforts assess risk, and help guide improvements.
    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should develop and document a strategic workforce planning process.

    Agency: Corporation for National and Community Service
    Status: Open

    Comments: CNCS reported that its senior level executive committee reviews all staffing requests and ensures that appropriate staffing justifications are provided, and ensures that all functions in the agency are provided appropriate resources. The agency also noted that, in accordance with direction received from OMB following the release of OMB Memorandum M-17-22 ("Memorandum for Heads of Executive Departments and Agencies"), it is launching an enterprise-wide re-examination of its mission, strategy and structure in order to develop a plan to ensure employee performance is maximized and the agency is operating effectively. To help close this recommendation, CNCS will need to document and develop a strategic workforce planning process that addresses key principles for effective strategic workforce planning, such as to develop strategies tailored to address gaps in number, deployment, and alignment of human capital approaches for enabling and sustaining the contributions of all critical skills and competencies, and to monitor and evaluate process toward human capital goals and programmatic results.
    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should, as part of CNCS's efforts to develop an employee development program, update critical competencies for grant monitoring, and establish a training planning process linked with agency goals and these competencies.

    Agency: Corporation for National and Community Service
    Status: Open

    Comments: CNCS cited its training efforts, such as providing training to grants management staff in FY15 and FY16 related to grants monitoring. The agency is in the process of developing a broader agency-wide employee development program that will link competencies to development needs in various mission-critical roles. To close this recommendation, CNCS will need to determine which competencies are critical for grant monitoring, and show how the competencies are linked with the agency's training planning processes and agency goals.
    Director: Carolyn L. Yocom
    Phone: (202) 512-7114

    3 open recommendations
    Recommendation: To build upon CMS's collaborative audit efforts and help enhance future collaboration, CMS should identify opportunities to address barriers that limit states' participation in collaborative audits. Such opportunities could include improving communication with states before, during, and after audits are completed; and ensuring that audits align with states' program integrity needs, including the need for oversight of services provided in managed care delivery systems.

    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: To better support states' efforts to reduce improper payments and communicate effective program integrity practices across the states, CMS should collaborate with states to develop a systematic approach to collect promising state program integrity practices.

    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: To better support states' efforts to reduce improper payments and communicate effective program integrity practices across the states, CMS should collaborate with states to create and implement a communication strategy for sharing promising program integrity practices with states in an efficient and timely manner.

    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: Katherine Iritani
    Phone: (202) 512-7114

    4 open recommendations
    Recommendation: To improve the collection of complete and consistent personal care services data and better ensure CMS can effectively monitor the states' provision of and spending on Medicaid personal care services, CMS should establish standard reporting guidance for personal care services collected through Transformed-MSIS (T-MSIS) to ensure that key data reported by states, such as procedure codes, provider identification numbers, units of service, and dates of service, are complete and consistent.

    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: To improve the collection of complete and consistent personal care services data and better ensure CMS can effectively monitor the states' provision of and spending on Medicaid personal care services, CMS should better ensure, for all types of personal care services programs, that data on provision of personal care services and other home-and community-based services (HCBS) collected through T-MSIS claims can be specifically linked to the expenditure lines on the CMS-64 that correspond with those particular types of HCBS services.

    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: To improve the collection of complete and consistent personal care services data and better ensure CMS can effectively monitor the states' provision of and spending on Medicaid personal care services, CMS should better ensure that personal care services data collected from states through T-MSIS and MBES comply with CMS reporting requirements.

    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: To improve the collection of complete and consistent personal care services data and better ensure CMS can effectively monitor the states' provision of and spending on Medicaid personal care services, CMS should develop plans for analyzing and using personal care services data for program management and oversight.

    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: Katherine Iritani
    Phone: (202) 512-7114

    2 open recommendations
    Recommendation: To achieve a better understanding of the effect of certain Personal care services (PCS) services on beneficiaries and a more consistent administration of policies and procedures across PCS programs, the Acting Administrator of CMS should collect and analyze states' required information on the impact of the Participant-Directed Option and Community First Choice programs on the health and welfare of beneficiaries as well as the state quality measures for the Participant-Directed Option and Community First Choice programs.

    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: To achieve a better understanding of the effect of certain PCS services on beneficiaries and a more consistent administration of policies and procedures across PCS programs, the Acting Administrator of CMS should take steps to harmonize requirements, as appropriate, across PCS programs in a way that accounts for common risks faced by beneficiaries and to better ensure that billed services are provided.

    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: Kathleen M. King
    Phone: (202) 512-7114

    1 open recommendations
    Recommendation: To improve the efficiency and effectiveness of the agency's enrollment screening process, the Administrator of CMS should establish objectives and performance measures for assessing progress toward achieving its goals.

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

    Comments: As of August 2017, the Department of Health and Human Services (HHS) considers this recommendation still open. HHS noted that the Centers for Medicare & Medicaid Services is planning to implement this recommendation in early 2018. GAO will continue to monitor the agency's progress and will update the status of the recommendation when we receive additional information.
    Director: J. Lawrence Malenich
    Phone: (202) 512-3406

    1 open recommendations
    Recommendation: CCI's Chief Financial Officer should update its existing Procurement and Accounts Payable Policy to fully document CCI's management approval controls over payments made by check, including exemptions to regular procedures. This should include approval procedures to be followed during periods when only one authorized manager is available to sign checks for payment.

    Agency: Capital Concerts, Inc.
    Status: Open

    Comments: We provided a draft of this report to Capital Concerts, Inc. (CCI) for comment. In its written comments, CCI stated that its Board of Directors will take appropriate action to address this recommendation.
    Director: Kay E. Brown
    Phone: (202) 512-7215

    2 open recommendations
    including 1 priority recommendation
    Recommendation: The Secretary of Agriculture should take additional steps to collect and disseminate information on promising practices that could help improve data matching processes among state SNAP agencies, including broad and timely dissemination of information on results of recent relevant pilots or demonstrations.

    Agency: Department of Agriculture
    Status: Open
    Priority recommendation

    Comments: The U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) agreed with this recommendation. The agency noted it is moving in this direction and would build on current efforts to address them. GAO will monitor these efforts and consider closing the recommendation when these efforts have been completed.
    Recommendation: The Secretary of Agriculture should work with the Department of Health and Human Services (as appropriate) to analyze spending and understand data needs for SNAP across federal and state contracts and in relation to other programs as FNS explores ways to potentially reduce the costs of using commercial data services.

    Agency: Department of Agriculture
    Status: Open

    Comments: The U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) agreed with this recommendation. The agency noted it has been moving in this general direction and would build on current efforts to address it. GAO will monitor these efforts and consider closing the recommendation when these efforts have been completed.
    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: Dan Bertoni
    Phone: (202) 512-7215

    1 open recommendations
    Recommendation: To ensure the agency has sufficient information about risks to SSI program integrity when making decisions about efforts to address them, the Commissioner of the Social Security Administration should conduct a risk assessment of the current manual process for connecting and adjusting claim records of SSI recipients who live in households with other SSI recipients, and, as appropriate, take steps to make cost-effective improvements to SSA's claims management system to address identified risks.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA disagreed with this recommendation stating that current SSI program rules do not support connecting records of unrelated individuals living in multiple recipient households. SSA also noted that it does not have evidence from its fiscal year 2014 payment accuracy reviews that manual processing of married couple multiple recipient household claims led to payment errors. As such, the agency stated that it could not commit resources to address this recommendation at this time, but noted if a legislative proposal is put forth that affects unrelated multiple SSI recipient households, SSA will assess program policy and systems risks as part of its evaluation and planning. However, we continue to believe that the manual processing currently used to connect and adjust claim records of SSI recipients who live in households with other SSI recipients leaves the agency at risk. SSA has acknowledged that it has not assessed the extent to which manual processing leads to payment errors, and the data they provided us on fiscal year 2014 improper payments to married couple recipients does not address the full scope of the issues we identified. Specifically, field office staff reported several instances in which manual processing is used to connect and adjust claims records for multiple recipient households due to system limitations, and indicated that these manual adjustments increase the likelihood of erroneous payments. These manually processed claims are for households with multiple related recipients whose SSI benefits are currently inter-related under program rules, such as multiple child recipients who are siblings or individual recipients who marry another recipient. Without an assessment of the risks associated with the manual processing of these claims, SSA is unable to determine if additional adjustments to its system would be a cost-effective use of its resources.
    Director: Beryl Davis
    Phone: (202) 512-2623

    2 open recommendations
    Recommendation: To help fulfill the IPERA and OMB requirements to submit proposals to Congress when agencies reach 3 or more consecutive years of noncompliance with IPERA criteria, the Secretary of Agriculture or a designee 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 2014 for its (1) Child and Adult Care Food Program; (2) School Breakfast Program; (3) National School Lunch Program; and (4) Special Supplemental Nutrition Program for Women, Infants, and Children. 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: We provided a draft of this report to OMB, the IG offices of the 24 CFO Act agencies, and the CFO offices of those agencies with programs that were determined to be noncompliant with IPERA criteria for 3 consecutive years as of fiscal year 2014. In their e-mailed response, officials from the CFO office at USDA neither concurred nor disagreed with our recommendations. We will continue to monitor the status of this recommendation.
    Recommendation: To help fulfill the IPERA and OMB requirements to submit proposals to Congress when agencies reach 3 or more consecutive years of noncompliance with IPERA criteria, the Secretary of Defense or a designee 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 2014 for its Department of Defense Travel Pay program. To the extent that reauthorization or statutory changes are not considered necessary to bring the program into compliance, the Secretary or designee should state so in the letter.

    Agency: Department of Defense
    Status: Open

    Comments: We provided a draft of this report to OMB, the IG offices of the 24 CFO Act agencies, and the CFO offices of those agencies with programs that were determined to be noncompliant with IPERA criteria for 3 consecutive years as of fiscal year 2014. In their written comments, the offices of the DOD CFO and DOD IG concurred with our recommendations. The DOD CFO office noted that it does not consider reauthorization or statutory change necessary for its Travel Pay program, but will submit a letter to Congress containing planned actions for improvement by August 30, 2016. As of June 2, 2017, no updated information has been provided by the Department of Defense. We will continue to monitor the status of this recommendation.
    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: Seto Bagdoyan
    Phone: (202) 512-6722

    1 open recommendations
    Recommendation: To help preserve a proven resource supporting the oversight community's analytic capabilities, Congress may wish to consider directing CIGIE to develop a legislative proposal to reconstitute the essential capabilities of the ROC to help ensure federal spending accountability. The proposal should identify a range of options at varying scales for the cost of analytic tools, personnel, and necessary funding, as well as any additional authority CIGIE may need to ensure such enduring, robust analytical and investigative capability for the oversight community.

    Agency: Congress
    Status: Open

    Comments: When we determine what steps Congress has taken, we will provide updated information.
    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: Mihm, J Christopher
    Phone: (202) 512-6806

    2 open recommendations
    including 2 priority recommendations
    Recommendation: To ensure that federal program spending data are provided to the public in a transparent, useful, and timely manner, the Director of OMB should accelerate efforts to determine how best to merge DATA Act purposes and requirements with the GPRAMA requirement to produce a federal program inventory.

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

    Comments: OMB staff stated that they expect to issue new guidance on the Program Management Improvement Accountability Act by the end of 2017. According to these staff, OMB expects that, within a year of issuing the new guidance, they will be able to move forward with plans to resume implementation of the federal program inventory. In October 2017, OMB staff told us they believe there are opportunities to leverage the DATA Act taxonomy in service to the goals of GPRAMA and they continue to work with their performance management colleagues on this effort. However, they said no formal progress has been made to identify programs for the purposes of DATA Act reporting.
    Recommendation: To ensure that the integrity of data standards is maintained over time, the Director of OMB, in collaboration with the Secretary of the Treasury, should establish a set of clear policies and processes for developing and maintaining data standards that are consistent with leading practices for data governance.

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

    Comments: OMB and Treasury have taken some initial steps to build a data governance structure standardizing data elements and definitions, conducting interviews with key stakeholders and developing a set of recommendations for decision-making authority. In September 2016, OMB and Treasury established a Data Standards Committee (DSC) that is responsible for advising OMB and Treasury, and providing recommendations on DATA Act data standards to the Executive Steering Committee (ESC) -- the decision making body regarding DATA Act and other data standards. According to OMB staff, the DSC meets on a monthly basis, but has not yet provided recommendations to OMB or to the ESC. OMB staff told us in October 2017 that, in accordance with their broader data governance mandates and overall transparency efforts, they are reviewing opportunities to incorporate and leverage other mandates and existing governance structures. As part of our ongoing feedback with OMB, we shared 5 key practices that we believe should inform their plans to develop a data governance framework moving forward.
    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: 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: 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: The Department of Education stated that it has already developed policies and procedures for preparing cost-benefit analyses related to computer matching agreements (CMA). The agency believes these analyses already incorporate the appropriate key elements, although it continues to reexamine them in the interest of continuous improvement. ED also noted that not all key elements apply to every computer matching program. For example, the agency did not think it appropriate to address the recovery of improper payments and debts for matching programs to establish eligibility. However, we believe all key elements should be addressed in cost benefit analyses, even if only to note that certain types of benefits have been considered and determined not to be applicable in the specific circumstances of a given computer matching program. Without a thorough assessment, the Data Integrity Board may not have sufficient information to determine whether a thorough cost analysis has been conducted. In 2017, the agency provided three cost benefit analyses from recent CMAs that include personnel and computer costs.
    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: Khan, Asif A
    Phone: (202)512-9869

    9 open recommendations
    including 9 priority recommendations
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to estimating improper payments, to establish and implement key quality assurance procedures, such as reconciliations, to ensure the completeness and accuracy of the sampled populations.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: The Department of Defense (DOD), in concurring with this recommendation, stated that the Department will work with the Defense Finance and Accounting Service (DFAS) to implement key quality assurance procedures, such as reconciliations, to ensure the completeness and accuracy of sampled populations. In June 2016, DOD officials stated that while the department is moving toward full auditability of its financial statements, the capability to ensure the completeness and accuracy of the sampled populations is still under development. As of August 31, 2017, DOD's efforts in this area were ongoing.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to estimating improper payments, to revise the procedures documented in DOD's sampling methodologies so that they (1) are in accordance with OMB guidance and generally accepted statistical standards and (2) produce statistically valid improper payment error rates, statistically valid improper payment dollar estimates, and appropriate confidence intervals for both. At a minimum, such procedures should take into account the size and complexity of the transactions being sampled.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: The Department of Defense (DOD) partially concurred with this recommendation, stating that sampling methodologies would be reviewed for all payment types and would be modified as appropriate to produce valid improper payment estimates and appropriate confidence intervals for them. In its May 2016 FIAR Plan Status Report, DOD officials stated that the department is reviewing the methodologies associated with identifying improper payments for seven improper payment programs, and if warranted, will change their sampling plans (methodologies). These seven programs are: Defense Finance and Accounting Service's Military Pay, Civilian Pay, Military Retirement, and Travel Pay; U.S. Corps of Engineers' Commercial Pay and Travel Pay; and Navy ERP commercial payments. In June 2016, DOD officials stated that the Office of the Under Secretary of Defense (Comptroller) will continue to coordinate with those DOD components currently using simple random sample designs, to develop methodologies that are stratified by an appropriate variable, such as an invoice or payment amount based on appropriate confidence intervals. As of August 31, 2017, this recommendation was still open.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to identifying programs susceptible to significant improper payments, to conduct a risk assessment that is in compliance with IPERA.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: The Department of Defense (DOD), in concurring with this recommendation, stated that it would work collaboratively with the applicable Defense components to develop a framework to conduct a risk assessment that is in compliance with the Improper Payments Elimination and Recovery Act (IPERA). Risk assessments for six DOD programs (military health benefits, military pay, civilian pay, Defense Finance and Accounting Service (DFAS) travel pay, retiree & annuitant pay, and DFAS commercial pay) complied with IPERA requirements based on documentation provided to support them. However, based on our review of documentation provided by the U.S. Army Corps of Engineers (USACE), risk assessments for the two programs it administers (USACE travel pay and USACE commercial pay) have not been performed. DOD officials stated that the risk assessment documentation for the two USACE programs is under development. In October 2016, DOD issued a remediation plan for travel pay improper payments and recovery. As of August 31 2017, this recommendation was still open.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to reducing improper payments, to establish procedures that produce corrective action plans that comply fully with IPERA and OMB implementation guidance, including at a minimum, holding individuals responsible for implementing corrective actions and monitoring the status of the corrective actions.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: The Department of Defense, in concurring with this recommendation, stated that it would work collaboratively with applicable components to establish procedures that produce corrective action plans that fully comply with the Improper Payment Elimination and Recovery Act and Office of Management and Budget (OMB) guidance. According to DOD officials, these established procedures will include individual accountability for implementing corrective actions and monitoring the status of corrective actions. As of June 2016, DOD officials told us that department enters corrective actions plans associated with audit findings into a notice of findings and recommendations (NFR) database developed to track their status and progress. The database was deployed in May 2016. According to DOD's fiscal year 2015 Agency Financial Report, DOD's travel pay had the highest error rate among all DOD-reported improper payment programs, and therefore DOD would place its initial focus to achieve measurable progress more quickly in this area. In June 2016, DOD officials stated that the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) would revise and expand the DOD Travel Remediation Plan into a more comprehensive plan which includes establishing Senior Accountable Officials (SAOs) within each military service. OUSD(C) will collaborate with each SAO to ensure the development of standardized procedures and corrective action plans to include training, root cause identification, and quality assurance goals that comply with improper payment law and regulatory guidance. On October 7, 2016, DOD issued its remediation plan entitled "Preventing Travel Pay Improper Payments and Recovery." The remediation plan notes two primary causes of improper travel payments; each of which highlights the need for increased detail (documentation), attention to detail (accuracy), and a more regular and effective training regimen. The remediation plan includes several requirements that must be met to reinforce internal controls and accountability. Beginning in fiscal year 2017, the DOD Comptroller and component SAOs are to receive travel pay metrics reports to measure progress. The first report is intended to establish a baseline. As of April 2017, DOD officials stated that there are corrective action plans, but the implementation of these plans needs to be assigned to the individual level components. As of August 31, 2017, this recommendation was still open.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to reducing improper payments, to establish procedures that produce corrective action plans that are in accordance with best practices, such as those recommended by the Chief Financial Officers Council (CFOC), and include (1) measuring the progress made toward remediating root causes and (2) communicating to agency leaders and key stakeholders the progress made toward remediating the root causes of improper payments.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: The Department of Defense (DOD), in concurring with this recommendation, stated that it would work collaboratively with the applicable components to establish procedures that produce corrective action plans that incorporate best practices, including those recommended by the Chief Financial Officers Council. DOD's corrective action plans would include information on (1) measuring the progress made toward remediating root causes and (2) communicating to agency leaders and key stakeholders the progress made toward remediating the root causes of improper payments. In June 2016, DOD officials told us that department enters corrective actions plans associated with audit findings into a notice of findings and recommendations (NFR) database developed to track their status and progress. The database was deployed in May 2016. According to DOD's fiscal year 2015 Agency Financial Report, DOD's travel pay had the highest error rate among all DOD-reported improper payment programs, and therefore DOD would place its initial focus to achieve measurable progress more quickly in this area. In June 2016, DOD officials stated that the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) will revise and expand the DOD Travel Remediation Plan into a more comprehensive plan which will include establishing Senior Accountable Officials (SAOs) within each military service. OUSD(C) will collaborate with each SAO to ensure the development of standardized procedures and corrective action plans to include training, root cause identification, and quality assurance goals that comply with improper payment law and regulatory guidance. On October 7, 2016, DOD issued its corrective/remediation plan entitled "Preventing Travel Pay Improper Payments and Recovery." We plan to review this plan for consistency with OMB and IPERA guidelines. In April 2017, we learned that the Office of Management and Budget had done an assessment of this plan and provided helpful suggestions. As of August 31, 2017, this recommendation was still open.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to develop and implement procedures to (1) identify costs related to the department's recovery audits and existing recovery efforts and (2) evaluate existing improper payment recovery efforts to ensure that they are cost effective.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: Department of Defense (DOD) officials concurred with this recommendation, stating that the DOD would review its procedures for improper payment recovery activities to ensure currency and accuracy and that it would also perform analyses to ensure that its recovery efforts are cost-effective. In July 2015, DOD reported that the development of cost estimates for recovery auditing was ongoing. In addition, DOD officials indicated that only the United States Army Corps of Engineers (USACE) has developed an analysis to evaluate the cost effectiveness of performing recovery audits. As of April 2017, DOD's efforts to develop cost-estimates for recovery audits were still under way. As of August 31, 2017, this recommendation was still open.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to monitor the implementation of the revised FMR chapter on recovery audits to ensure that the components either develop recovery audits or demonstrate that it is not cost effective to do so.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would work with the applicable components to monitor the implementation of the revised Financial Management Regulation (FMR) chapter on recovery audits. According to DOD officials, this action would help to ensure that recovery audits are developed, or will demonstrate that it is not cost-effective to do these audits. In July 2015, DOD was working to update the FMR chapter on recovery audits to reflect revised Office of Management and Budget (OMB) guidance issued in October 2014. DOD issued its revised FMR chapter in November 2015. This chapter requires components to develop cost-effective payment recapture audits or to submit a quantitative justification to the Office of the Under Secretary (Comptroller) for approval. However, we consider this recommendation to be open because DOD did not provide documentation demonstrating that the Office of the Under Secretary of Defense (Comptroller) is monitoring component implementation of recovery auditing. Further, as of April 2017, DOD's efforts to develop cost-estimates for recovery audits were still under way. As of August 31, 2017, this recommendation was still open.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to develop and submit to OMB for approval a payment recapture audit plan that fully complies with OMB guidance.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would develop and submit to the Office of Management and Budget (OMB) a payment recapture plan that fully complies with OMB guidance and is informed by a cost-effectiveness analysis. In July 2015, DOD's Office of the Under Secretary of Defense (Comptroller) efforts to develop a payment recapture audit plan to ensure cost-effectiveness were ongoing and these efforts must be completed before a plan can be submitted to the OMB. In June 2016, DOD officials stated that the Comptroller's efforts to develop a payment recapture audit plan to ensure cost-effectiveness were ongoing. As of August 31,2017, the department's efforts to implement this recommendation are continuing.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to reporting, to design and implement procedures to ensure that the department's annual improper payment and recovery audit reporting is complete, accurate, and in compliance with IPERA and OMB guidance.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would design and implement procedures to further ensure that its annual improper payment and recovery audit reporting is complete, accurate, and in compliance with the Improper Payments Elimination and Recovery Act (IPERA) requirements and Office of Management and Budget (OMB) guidance. In June 2015, DOD revised its FMR chapter on improper payments to require components to provide information needed to report on improper payment and recovery audit activities in its annual financial report (AFR) in accordance with IPERA requirements and OMB guidance. DOD's fiscal year 2015 AFR reflected its implementation of the revised FMR. We found that DOD's improper payment reporting in its fiscal year 2015 AFR had improved. However, we were not provided with evidence that Office of the Under Secretary of Defense (Comptroller) is performing oversight and monitoring activities to ensure the accuracy and completeness of the improper payment and recovery audit data submitted by DOD components for inclusion in the AFR. As of April 2017, DOD is continuing to work on procedures for ensuring that its reporting on improper payment and recovery audits is accurate, complete, and in compliance with IPERA and OMB guidance. As of August 31, 2017, this recommendation was still open.
    Director: King, Kathleen M
    Phone: (202) 512-7114

    1 open recommendations
    Recommendation: To improve the effectiveness of the unpublished MUEs and better ensure Medicare program integrity, the CMS Administrator should consider periodically reviewing claims to identify the providers exceeding the unpublished MUE limits and determine whether their billing was proper.

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

    Comments: In its comments on a draft of this report, HHS concurred with this recommendation and indicated that CMS would conduct further analysis to determine the most appropriate way to respond. In July 2015, HHS told us that CMS has established a process to identify providers exceeding the unpublished MUE limits and determine whether their billing was proper. In August 2016, CMS informed us that the agency is developing a process to review provider level data to determine potential improper billing that exceeds unpublished MUE limits. However, as of September 2016, CMS has not yet implemented this process. We requested that CMS provide documentation of the process once it has been implemented. With this documentary support, we hope to close the recommendation.
    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: Scire, Mathew J
    Phone: (202)512-3000

    1 open recommendations
    Recommendation: To help estimate, reduce, and recover improper payments in the Section 521 rental assistance program, the Secretary of Agriculture should draft proposed legislation for congressional consideration that would grant RHS access to SSA benefits data for purposes of verifying tenant incomes.

    Agency: Department of Agriculture
    Status: Open

    Comments: As of July 2016, USDA had not drafted proposed legislation that would grant RHS access to SSA benefits data.
    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: 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.