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    Subject Term: Overpayments

    23 publications with a total of 97 open recommendations including 27 priority recommendations
    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: 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: 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: Beryl H. Davis
    Phone: (202) 512-2623

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

    Agency: Congress
    Status: Open

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

    Agency: Department of the Treasury
    Status: Open

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

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

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

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

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

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

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

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

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

    Comments: As of February 2017, IRS is taking steps toward developing a comprehensive compliance strategy that includes the three refundable tax credits GAO reviewed, as well as the PTC. These steps include initial planning meetings with Lean Six Sigma consultants and refundable credit policy and program managers and soliciting volunteers for the teams needed to develop the strategy. GAO will continue to monitor the progress of this effort.
    Director: bertonid@gao.gov
    Phone: (202) 512-7215

    8 open recommendations
    including 1 priority recommendation
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should clarify its policy for assessing the reasonableness of expenses used in determining beneficiaries' repayment amounts to help ensure that withholding plans are consistently established across the agency and accurately reflect individuals' ability to pay.

    Agency: Social Security Administration
    Status: Open

    Comments: As a result of the Bipartisan Budget Act of 2015, SSA gained the ability to use the Access to Financial Information (AFI) system to verify information about the assets of beneficiaries. In February 2017, the agency reported it is continuing to work on clarifying its policy for assessing the reasonableness of expenses used in determining repayment amounts, including guidance on using the new AFI process. As part of this effort, SSA is also reviewing the Internal Revenue Service's (IRS) Collection Financial Standards and determining whether it can incorporate these or similar standards in its policies for determining reasonable repayment amounts. We will continue to track SSA's efforts to clarify its policies, including efforts to incorporate IRS standards.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should improve oversight of DI benefit withholding agreements to ensure that they are completed appropriately. This could include requiring supervisory review of repayment plans or sampling plans as part of a quality control process, and requiring that supporting documentation for all withholding plans be retained to enable the agency to perform such oversight.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation, but does not believe that it is necessary to conduct supervisory reviews. As of February 2017, SSA reported that it is exploring system, policy, and training opportunities to better ensure staff appropriately complete benefit withholding agreements. We will continue to track SSA's efforts to improve oversight in this area.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should explore the feasibility of using additional methods to independently verify financial information provided by beneficiaries to ensure that complete and reliable information is used when determining repayment amounts. These additional tools could include those already being used by the agency for other purposes.

    Agency: Social Security Administration
    Status: Open

    Comments: According to SSA, Section 834 of the Bipartisan Budget Act of 2015 gave the agency the authority to use the Access to Financial Information system as part of the agency's waiver determination process. SSA reported that, as of February 2017, it also considered using the National Directory of New Hires Query for verifying an overpaid beneficiary's financial information, but preliminarily determined that the information in this system would be of limited value since it is a quarterly report of past earnings. SSA states that it continues to explore other options to verify financial information such as The Work Number and the Interstate Benefit Inquiry. We will monitor SSA's efforts to explore additional options for verifying financial information.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should adjust the minimum withholding rate to 10 percent of monthly DI benefits to allow quicker recovery of debt.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: SSA agreed with this recommendation and as of April 2017, it estimated that this would result in an additional $213 million in collections over a 5-year period. The fiscal year 2017 President's budget submission contained a legislative proposal to make this change, but has not yet been enacted. In April 2017, the agency reported that, in the third quarter of fiscal year 2017, it intends to resubmit a regulatory change to establish the minimum withholding rate to 10 percent in the event that its legislative proposal is not included in the fiscal year 2017 budget.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should consider adjusting monthly withholding amounts according to cost of living adjustments or charging interest on debts being collected by withholding benefits. Should SSA determine that it is necessary to do so, it could pursue legislative authority to use recovery tools that it is currently unable to use.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA continued to disagree with this recommendation. For debt subject to benefit withholding, which is not considered delinquent debt, SSA asserted that these measures would not have a significant effect on the amount of debt recovered, especially compared to the option of changing the minimum withholding rate to 10 percent of monthly benefits. For delinquent debt, SSA stated charging interest on debts would require substantial changes to multiple systems that affect its overpayment businesses processes, and would require extensive training to its employees. We continue to believe there is merit in further consideration of these measures. While SSA reported it has studied the potential changes needed to charge interest on debt, without further consideration of, for example, the costs and benefits of charging interest or adjusting withholding amounts according to cost of living adjustments, SSA cannot know the extent to which these options would improve debt recovery efforts or help protect the value of debts against the effects of inflation, which can be substantial given that withholding plans can take decades to complete.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should pursue additional debt collection tools for collecting delinquent penalties. This includes taking steps to implement tools within its existing authority and exploring the use of those not within its authority, and seeking legislative authority if necessary.

    Agency: Social Security Administration
    Status: Open

    Comments: In June 2016, SSA reported that: it had drafted regulations to use existing external debt collection tools for penalties, was developing a legislative proposal to allow the use of additional debt collection tools such as Federal salary offset and credit bureau reporting, and had started planning for a multi-activity, multi-year administrative sanctions project. In February 2017, SSA reported that, as part of its administrative sanctions project, the agency revised policy guidance on factors significant to OCIG's civil monetary penalty determinations. We will track SSA's progress in applying new tools to collecting penalties.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should take steps to collect complete, accurate, and timely data on, and thereby improve its ability to track civil monetary penalties and their disposition.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA reported that it is developing a workload tracking tool for penalties to provide accurate management information on cases. SSA expects to implement this tool by September 2017, and have the first full year of management information available in fiscal year 2018. We will close this recommendation once SSA implements and begins using this tool.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should take steps to collect complete, accurate, and timely data on, and thereby improve its ability to track administrative sanctions and their disposition.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA reported that it has been developing a new workload tracking tool for administrative sanctions. The first phase of this tool was implemented in December 2016 and allows SSA to track administrative sanction cases throughout the development process. The second phase, expected to be implemented by September 2017, will provide SSA with management information on sanctions cases. We will continue to monitor SSA's process in developing this tool. We will close this recommendation once the tool is implemented.
    Director: Carolyn L. Yocom
    Phone: (202) 512-7114

    1 open recommendations
    Recommendation: To ensure states have appropriate and current guidance to assist them in designing and administering Medicaid NEMT, the Secretary of HHS should direct CMS to assess current Medicaid NEMT guidance and update that guidance as needed.

    Agency: Department of Health and Human Services
    Status: Open

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

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

    Agency: Social Security Administration
    Status: Open

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

    Agency: Social Security Administration
    Status: Open

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

    Agency: Social Security Administration
    Status: Open

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

    Agency: Social Security Administration
    Status: Open

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

    Agency: Social Security Administration
    Status: Open

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

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

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

    Agency: Social Security Administration
    Status: Open

    Comments: In August 2016, the agency reported that it had taken several actions, including producing a comprehensive training series on overpayment and waiver policy and procedures, building a policy cluster to serve as a "one-stop resource shop" of policy references and tools for technicians, and clarifying agency policies including the Administrative Tolerance Decision Tree to assist technicians with making appropriate low-dollar overpayment waiver decisions. The agency also reported that its Continuous Quality work group continues to review the accuracy of waivers under Title II of the Social Security Act. Based on these efforts, in November 2016, SSA reported that it has closed this recommendation. However, as of April 2017, SSA did not specifically report that its review of Title II waivers will target DI waivers, including administrative waivers and waivers less than $2,000, or that such review will be an ongoing effort. To close this recommendation, SSA will need to show its plans for periodically assessing the accuracy of DI waiver decisions--particularly for administrative waivers and waivers under $2,000--through its continuous quality initiative or other means.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

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

    Agency: Department of Veterans Affairs
    Status: Open

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

    Agency: Department of Veterans Affairs
    Status: Open

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

    Agency: Department of Veterans Affairs
    Status: Open

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

    Agency: Department of Veterans Affairs
    Status: Open

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

    Agency: Department of Veterans Affairs
    Status: Open

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

    Agency: Department of Veterans Affairs
    Status: Open

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

    Agency: Department of Veterans Affairs
    Status: Open

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

    Agency: Department of Veterans Affairs
    Status: Open

    Comments: VA officials reported in March 2017 that the agency plans to amend its procedures to account for school refund policies when calculating veterans' overpayment debts, as GAO recommended in its 2015 report. VA officials said they plan to publish this information in the School Certifying Official Handbook and notify schools and student veterans about the change. However, officials also reported that the agency needs to address several issues with its information technology systems before these changes can be made. Officials said they expect to complete these upgrades by December 2017 once the necessary IT resources requested by the Veterans Benefits Administration are provided.
    Director: Carolyn L. Yocom
    Phone: (202) 512-7114

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

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

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

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

    Comments: As of April 2017, HHS is establishing a process to make the eligibilty and expenditure reviews interact with one another. GAO will work with the agency to determine if these actions address the recommendation.
    Director: King, Kathleen M
    Phone: (202) 512-7114

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

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

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

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

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

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

    Comments: HHS agreed with our recommendations. As of March 2017, HHS stated that the agency was evaluating its strategy for the Medicare Part D RAC. Once HHS has completed its evaluation, we will update the status of these recommendations. As of May 2017, GAO considers this recommendation open.
    Director: Seto Bagdoyan
    Phone: (202) 512-6722

    4 open recommendations
    including 2 priority recommendations
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should review the potential DI overpayments resulting from FECA benefits identified in our case studies, as well as any indicators of fraudulent activity related to FECA benefits that were not self-reported by DI beneficiaries, and establish debt-collection efforts and fraud-related penalties, as appropriate.

    Agency: Social Security Administration
    Status: Open

    Comments: As of January 2017, SSA stated that it will continue reviewing the potential DI overpayments resulting from FECA benefits identified in GAO's case studies, as GAO recommended in July 2015, and that actions are due to be completed by the end of April 2017. GAO will continue to monitor SSA's efforts in this area.
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should review the instances described in our report in which SSA staff did not obtain proof of FECA benefits that were reported by DI beneficiaries and (1) determine the reasons for these occurrences and whether this is a pervasive problem; and (2) if necessary, design appropriate controls or make other efforts, such as staff training, to help ensure SSA staff obtain proof of workers' compensation payments, as required by SSA policy.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA stated that it will continue reviewing the instances described in GAO's report in which SSA staff did not obtain proof of FECA benefits that DI beneficiaries reported nor took follow-up actions as needed, as GAO recommended in July 2015. SSA expected to complete its analysis by the end of April 2017. SSA also stated that it has published an administrative message to remind staff of correct development and processing procedures for FECA claims. GAO will continue to monitor SSA's efforts in this area.
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should, in accordance with OMB guidance, compare the costs and benefits of alternatives to SSA's current approach for reducing the potential for overpayments that result from the concurrent receipt of FECA benefits, which relies on beneficiaries to self-report any FECA benefits they receive. These alternatives could include, among others, routinely matching DOL's FECA program data with DI program data to detect potential DI overpayments.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: SSA has taken steps to address this recommendation, but it has not completed its efforts. Specifically, in February 2017, SSA told GAO that the agency continues to discuss with DOL a data-matching agreement to obtain FECA payment data for offsetting DI benefits in accordance with federal law, as GAO recommended in July 2015. SSA also stated that it has reviewed its internal controls, policies, and workflow processes related to DI beneficiaries who receive concurrent FECA payments. Because SSA has not completed its work in this area, it is too early to determine whether these actions will address the problems GAO identified. GAO will continue to monitor SSA's work in this area.
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should strengthen internal controls designed to prevent DI overpayments due to the concurrent receipt of FECA benefits by implementing the alternative that provides the greatest net benefits.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: SSA has taken steps to address this recommendation, but it has not completed its efforts. Specifically, in February 2017, SSA told GAO that the agency was negotiating with DOL to enter into a data matching agreement to obtain FECA payment data for offsetting DI benefits in accordance with federal law, as GAO recommended in July 2015. SSA also stated that it was reviewing its internal controls related to DI beneficiaries who receive concurrent FECA payments and is in the process of considering the best options for strengthening these internal controls. SSA further stated that in August 2016, it issued reminders to technicians regarding developing and processing DI cases when an individual is concurrently receiving FECA benefits. Because SSA has not completed its work in this area, it is too early to determine whether these actions will address the problems GAO identified. GAO will continue to monitor SSA's work in this area.
    Director: Katherine M. Iritani
    Phone: (202) 512-7114

    3 open recommendations
    including 2 priority recommendations
    Recommendation: To improve CMS's oversight of Medicaid payments, the Administrator of CMS should take steps to ensure that states report accurate provider-specific payment data that include accurate unique national provider identifiers (NPI).

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

    Comments: HHS concurred with GAO's recommendation. As of September 2016, CMS has not provided additional information showing that the recommendation has been implemented. GAO considers it to be open. We will update the status of this recommendation when we receive additional information.
    Recommendation: To improve CMS's oversight of Medicaid payments, the Administrator of CMS should develop a policy establishing criteria for when such payments at the provider level are economical and efficient.

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

    Comments: HHS concurred with GAO's recommendation and as of October 2016 was evaluating ways to improve its oversight, including gathering information from states to better inform future policies. In November 2016, CMS plans to publish a proposed rule for public comment to improve the oversight of supplemental payments made to individual providers. Supplemental payments are large lump sum payments that most states make to certain providers and are not based on claims for services provided. According to CMS, the proposed rule will establish criteria for determining the economy and efficiency of Medicaid payments made to individual providers.
    Recommendation: To improve CMS's oversight of Medicaid payments, the Administrator of CMS should, once criteria are developed, develop a process for identifying and reviewing payments to individual providers in order to determine whether they are economical and efficient.

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

    Comments: HHS concurred with GAO's recommendation and as of October 2016 was evaluating ways to improve its oversight, including gathering information from states to better inform future policies. In November 2016, CMS plans to publish a proposed rule for public comment to improve the oversight of supplemental payments made to individual providers. According to CMS, the proposed rule will establish a process for identifying and reviewing payments to individual providers to determine if these payments meet the criteria of economy and efficiency established by the rule.
    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: 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: Daniel Bertoni
    Phone: (202) 512-7215

    2 open recommendations
    Recommendation: As part of initiatives currently under way to improve agency information on claims with appointed representatives and detect potential fraud associated with representatives, the Commissioner of the Social Security Administration should consider actions to provide more timely access to data on representatives and enhance mechanisms for identifying and monitoring trends and patterns related to representation, particularly trends that may present risks to program integrity. Specifically, SSA could (1) Identify additional data elements, or amendments to current data collection efforts, to improve information on all appointed representatives, including those under contract with states and other third parties; (2) Implement necessary policy changes to ensure these data are collected. This could include enhancing technical systems needed to finalize SSA's 2008 proposed rules that would recognize organizations as representatives; and (3) Establish mechanisms for routine data extracts and reports on claims with representatives.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA reported that it is approaching the conclusion of the first phase of a new initiative, called Registration, Appointment and Services for Representatives (RASR). This initiative aims to register all appointed representatives and improve relevant business processes and data collection. SSA reported that it had to postpone the first release of RASR, originally targeted for December 2016, due to some systems issues. SSA stated that it has not yet set a new target date for the first release. SSA stated that this new application will enhance data collection and management of representatives' information and that it will help make strides toward better oversight and improved data analysis and reporting. We will consider closing this recommendation when these efforts are completed.
    Recommendation: To address risks associated with potential overpayments to representatives and protect claimant benefits, the Commissioner of the Social Security Administration should take steps to enhance coordination with states, counties, and other third parties with the goal of improving oversight and preventing and identifying potential overpayments. This coordination could be conducted in a cost-effective manner, such as issuing guidance to states and other third parties on vulnerabilities for overpayment; sharing best practices on how to prevent overpayments; or considering the costs and benefits, including any privacy and security concerns, of providing third parties controlled access to portions of the eFolder to facilitate the detection of potential overpayments.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA stated that it added a section to a new form--Form SSA-1698, Fee Agreement for Representation before the Social Security Administration--that claimants and representatives can use to enter into fee agreements. According to SSA, this form requires the disclosure of fees that the representative will receive from a third party and the amount of those fees. SSA expects this form to be in use upon OMB approval. Similar language already exists in another form--Form SSA-1560-U4, Petition to Obtain Approval of a Fee for Representing a Claimant before the Social Security Administration--that claimants and representatives can use for fee petitions. SSA stated that these forms are (and will be) included in the folder of evidence that adjudicators may review before determining whether and how much to authorize in fees. According to SSA, disclosure and approval of any third party fees, with potential adjustment of the fee, by both the claimant and SSA should help prevent excessive fees. While the proposed change to the form may help improve transparency of fee arrangements, the potential for a representative to receive a payment from SSA and also receive a payment from a state or other third party still exists. Unless SSA and the state or other third party share information on their payments or have policies and procedures in place to prevent such cases, representatives could still receive both SSA and state payments that total more than the SSA-authorized fee. In order to address this vulnerability, we continue to believe that SSA should enhance coordination or issue guidance to states and other third parties about this vulnerability, which could include SSA sharing best practices for preventing these types of overpayments. For example, one state requires contracted organizations to submit copies of their signed form 1696 (Appointment of Representative) so the state could verify the representative checked the appropriate box for payment.
    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: 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: Melvin, Valerie C
    Phone: (202)512-6304

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

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

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

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

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

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

    Agency: Congress
    Status: Open

    Comments: As of May 2017, we are awaiting an update from HHS on the status of this recommendation. We will update the status of this recommendation when we receive additional information.