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Highlights

What GAO Found

The five agencies GAO reviewed used a variety of approaches to estimate and report improper payments related to Disaster Relief Appropriations Act, 2013 (DRAA) funding, in accordance with Office of Management and Budget (OMB) guidance. Specifically, these agencies, which received approximately 94 percent of the $50 billion provided by DRAA, used various approaches regarding the following:

Estimate presentation. Some agencies reported separate estimates for DRAA funding, while others developed one combined improper payment estimate that also included non-DRAA funding.

Estimate methodology. Agencies used statistical sampling methodologies, used alternative (nonstatistical) sampling methodologies, or tested 100 percent of DRAA-funded payments to estimate improper payments for DRAA funding.

Time period of estimate. Agencies used different time periods (or sampling windows) of the underlying transactions that were tested to develop improper payment estimates, such as October 2012 through September 2013 or April 2013 through March 2014.

The five agencies GAO reviewed had developed policies and procedures to guide their processes for estimating improper payments for 21 of 22 programs. However, GAO found that the agencies' policies and procedures did not address all key requirements from relevant laws, guidance, and Standards for Internal Control in the Federal Government . For example, GAO found the following:

Ten of the 22 programs did not have policies and procedures that included key quality assurance procedures, such as reconciliations, to validate that the populations of transactions were complete and accurate before selecting the samples used to estimate improper payments. Standards for Internal Control in the Federal Government states that control activities, such as reconciliations, are an integral part of an entity's planning, implementing, reviewing, and accountability for stewardship of government resources and achieving effective results.

Fourteen of the 22 programs did not have policies and procedures that included a requirement to maintain sufficient documentation to support their improper payment estimates as required by OMB guidance. Standards for Internal Control in the Federal Government also states that internal controls and all transactions and other significant events need to be clearly documented, and that the documentation should be readily available for examination and properly managed and maintained.

During the audit, one of the five agencies addressed the deficiencies that GAO identified. If key requirements for estimating improper payments are not documented in policies and procedures, agencies face an increased risk that their estimation processes as designed will not comply with the provisions of relevant laws and regulations or consistently produce reliable estimates that can help agencies improve stewardship of taxpayer dollars.

Why GAO Did This Study

DRAA provided approximately $50 billion in supplemental appropriations, before sequestration, to 19 federal agencies for expenses related to Hurricane Sandy and other purposes. DRAA deemed all programs and activities receiving appropriations under the act as susceptible to significant improper payments, making such appropriations subject to improper payment estimation requirements established in law and through OMB guidance.

GAO was asked to review agencies' efforts to estimate improper payments for expenses related to Hurricane Sandy. For DRAA funds, this report (1) describes how selected agencies estimated and reported improper payments and (2) determines the extent to which selected agencies developed policies and procedures for estimating improper payments. GAO reviewed the Departments of Homeland Security, Housing and Urban Development, and Transportation; the U.S. Army Corps of Engineers; and the Small Business Administration, which collectively received most of the DRAA funds. GAO reviewed sampling plans, evaluated agencies' policies and procedures, and conducted interviews with officials at these agencies and OMB.

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Recommendations

GAO is making recommendations to four of the five agencies to either develop or revise their policies and procedures for estimating improper payments for DRAA funds. These four agencies generally agreed with GAO's recommendations and cited plans for implementing them.

Recommendations for Executive Action

Agency Affected Recommendation Status
Small Business Administration 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 SBA produces reliable estimates of its DRAA improper payments, the Administrator of SBA should direct the appropriate officials to revise its Disaster Assistance Loans program 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) require 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; (5) requiring the agency to maintain sufficient documentation to support improper payment estimates; and (6) requiring that the sampling methodologies meet the precision requirements outlined in OMB Circular No. A-123, Appendix C.
Closed - Implemented
The Small Business Administration provided GAO with a copy of an SBA Procedural Notice, Control No. 6000-9903, which provides guidance for SBA personnel responsible for estimating annual improper payments for programs susceptible to such payments. The notice became effective March 25, 2015. The new guidance (1) defines improper payments consistently with the Improper Payments Information Act of 2000 (IPIA); (2) defines payments to include those made to Federal employees; (3) requires SBA personnel to follow the guidance for sampling methodologies outlined in OMB A-123 and for sample selection to be performed by a person who has training and experience in designing statistical samples and using statistical methods; (4) requires the testing office to examine the payment for each sample selected using a test plan or checklist that shows the key elements of a payment for that specific type of disbursement; (5) requires each office to maintain sufficient documentation/records to support the improper payment estimates, including population reconciliations to the general ledger, submissions to the statistician, testing work papers, statistician estimates, and documentation of improper payment discrepancies; and (6)requires a statistician to select a sample and prepare a sampling methodology plan in accordance with OMB Circular A-123. The new guidance should reduce the risk that improper payment estimates at SBA are not accurate or reliable.
Department of Transportation 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.
Closed - Not Implemented
In January 2013, Congress enacted the Disaster Relief Appropriations Act, which provides aid for Hurricane Sandy victims and their communities. In fiscal year 2019, the Department of Transportation (DOT), in consultation with the Office of Management and Budget (OMB), ceased annual improper payment estimate reporting of its affected disaster relief programs (i.e., Federal Transit Administration's Emergency Relief Program - Disaster Relief Act, and the Office of Inspector General Disaster Relief Appropriations Act Activity). DOT's Office of Inspector General, in accordance with its statutory responsibility to annually determine whether DOT has reported all necessary improper payment estimates, acknowledged this action by DOT and OMB in its fiscal year 2019 improper payment compliance report and did not report any findings related to these disaster relief programs. Since DOT is now not reporting an improper payment estimate related to these disaster relief programs, we no longer believe this particular recommendation is relevant. While we recognize that subsequent risk assessments may require DOT to report improper payment estimates for these programs in future years, we believe the likelihood of this occurring is low and getting lower with each passing year. Therefore, we are closing this recommendation as not implemented.
Department of Housing and Urban Development 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.
Closed - Not Implemented
In January 2013, Congress enacted the Disaster Relief Appropriations Act, which provides aid for Hurricane Sandy victims and their communities. In our prior year status update for this recommendation, we reported that the Department of Housing and Urban Development (HUD) met the intent of first part of the recommendation by updating its recapture audit plan (dated June 26, 2015) to require payments to federal employees be included in the population for testing when estimating improper payments. However, we left the recommendation open because HUD had not provided support that demonstrated HUD met the intent of second part of the recommendation, which indicates that HUD include steps to assess the completeness of the population of transactions used for selecting the samples to be tested when estimating improper payments. In fiscal year 2019, HUD, in consultation with the Office of Management and Budget (OMB), ceased reporting improper payment estimates for its affected disaster relief program (i.e., Office of Community Planning and Development - Disaster Relief Appropriations Act - Sandy program). HUD's Office of Inspector General, in accordance with its statutory responsibility to annually determine whether HUD has reported all necessary improper payment estimates, acknowledged this action by HUD and OMB in its fiscal year 2019 improper payment compliance report and did not report any findings related to this disaster relief program. Since HUD is now not reporting an improper payment estimate related to this disaster relief program, we no longer believe this particular recommendation is relevant. While we recognize that subsequent risk assessments may require HUD to report improper payment estimates for this program in future years, we believe the likelihood of this occurring is low and getting lower with each passing year. Therefore, we are closing this recommendation as not implemented.
Department of the Army 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.
Closed - Implemented
U.S. Army Corps of Engineers (USACE) concurred with this recommendation. On May 2, 2018, we received correspondence from USACE with support that demonstrated actions it has taken to address the recommendation. From our review of the support, we found that in June 2015, the Department of Defense (DOD) updated its Financial Management Regulation, which provides department-wide policy for estimating improper payments. DOD's Financial Management Regulation (1) includes additional narrative that defines improper payments consistent with the Improper Payments Information Act of 2002 and Office of Management and Budget Circular No. A-123 and (2) requires all payments to federal employees be included as part of their risk assessments. In addition, in May 2016, USACE has revised its Commercial Payment Review Standard Operating Procedures (SOP). USACE's SOP (1) includes a requirement for samples to be taken from a population which is pulled from the Corps of Engineers Financial Management System and verified against the check register to ensure all payments are identified and included in the population; (2) contains detailed procedures covering receipt vouchers, invoices, receiving reports, progress payments, reoccurring payments, and procurement document/obligation and the process for determining errors for each; and (3) requires disbursement vouchers and original supporting documentation be retained at the originating location for a minimum period of 10 years. The revised guidance should reduce the risk that improper payment estimates at USACE are not accurate or reliable.
Small Business Administration 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 SBA produces reliable estimates of its DRAA improper payments, the Administrator of the Small Business Administration (SBA) should direct the appropriate officials to develop policies and procedures for the Office of Entrepreneurial Development Grants program to estimate 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) providing sufficient procedures for determining an error and what documentation is necessary to substantiate a payment; (6) requiring the agency to maintain sufficient documentation to support improper payment estimates; (7) requiring that the sampling methodologies meet the precision requirements outlined in OMB Circular No. A-123, Appendix C; and (8) requiring a consultation with a statistician to ensure the validity of sample design, sample size, and measurement methodology.
Closed - Implemented
The Small Business Administration provided GAO with a copy of an SBA Procedural Notice, Control No. 6000-9903, which provides guidance for SBA personnel responsible for estimating annual improper payments for programs susceptible to significant improper payments. The notice became effective March 25, 2015. The new guidance: (1) provides a list of responsible parties and identifies their roles and associated responsibilities; (2) defines improper payments consistently with the Improper Payments Information Act of 2000 (IPIA); (3) defines payments to include those made to Federal employees; (4) requires the testing office to examine payments in relation to a test plan or checklist for each sample selected; (5) requires supporting documents for the key elements be obtained and reviewed to confirm the disbursement was proper; (6) requires each office to maintain sufficient documentation/records to support the improper payment estimates; (7) requires the preparation of a sampling methodology plan in accordance with the OMB Circular A-123; and (8) requires each office responsible for a program/activity susceptible to improper payments contract with an outside statistician for statistical services. The new guidance should reduce the risk that improper payment estimates at SBA's Office of Entrepreneurial Development are not accurate or reliable.

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