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    Subject Term: Errors

    9 publications with a total of 26 open recommendations including 2 priority recommendations
    Director: Kimberly M. Gianopoulos
    Phone: (202) 512-8612

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

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

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

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

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

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

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

    6 open recommendations
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Operations to further consider cost savings as part of its prioritization of full medical reviews. Such options could include considering the feasibility of prioritizing different types of beneficiaries on the basis of their estimated average savings and, as appropriate, integrating case-specific indicators of potential cost savings, such as beneficiary age and benefit amount, into its modeling or prioritization process.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA stated that there is no accepted way to accurately predict future benefit payments at the individual level and that any improvement from implementing this recommendation would be minimal - and would be reduced over time as the continuing disability review (CDR) backlog diminishes - because SSA already considers expected return on investment by cohort in its overall approach to releasing CDRs. It is unclear whether SSA will be able to achieve and sustain currency in its CDR workloads. Even if SSA were to eliminate the backlog of full medical reviews, refining its prioritization process would enable the agency to more efficiently use its resources with any future backlogs. SSA could use actuarial considerations to prioritize refined cohorts of beneficiaries (e.g., types of DI beneficiaries) on the basis of their estimated average savings. SSA Operations could collaborate with SSA's Office of the Actuary on this work as needed. SSA previously agreed that it could look for ways to improve its return on conducting CDRs, but also stated that its statistical models and prioritization process already do much of what we recommend. For example, SSA stated that age is already a strong variable in its statistical models. However, these models predict medical improvement and are not designed to take expected cost savings into account. We continue to believe that to maximize expected cost savings SSA could refine its prioritization process by factoring in additional actuarial considerations.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to complete a re-estimation of the statistical models that are used to prioritize CDRs and determine a plan for re-estimating these models on a regular basis to ensure that they reflect current conditions.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2016, SSA re-estimated the statistical models that it uses to prioritize CDRs. However, as of October 2017, SSA has not yet produced a plan for re-estimating the models on a regular basis to ensure that they continually reflect current conditions.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to monitor the characteristics of CDR errors to identify potential root causes and report results to the Disability Determination Services. For example, SSA could analyze CDRs with and without errors to identify trends by impairment, beneficiary type, or other characteristics.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and stated that it reports all errors to the relevant DDS for corrective action. SSA further stated that its identification of root causes is limited by the relatively few reviewed CDRs that have errors. However, in fiscal year 2014 as an example, SSA identified over 600 CDRs with errors. Although these CDRs make up a small percentage of the CDRs reviewed by SSA that year, the agency could analyze the characteristics of CDRs with errors by comparing relevant percentages without modeling. In addition, SSA could combine data from multiple years if it determined that considering more CDRs with errors would be helpful. There is no change in the status of this recommendation for 2017.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to regularly track the number and rate of date errors, which can affect benefit payments (e.g., incorrect cessation dates), and consider including those errors in its reported CDR accuracy rates.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA disagreed with this recommendation and stated that, per SSA regulation, the agency does not consider date errors when calculating accuracy rates because date errors do not affect the decision to cease or continue benefits. SSA also stated its stewardship reviews examine the non-medical quality of benefit payment decisions. However, these reviews are not focused on CDRs, and SSA does not report results from them for CDRs specifically. SSA also explained that it does not track the number and rate of date errors because they are infrequent. However, SSA's regulations do not prevent the agency from tracking date errors, and until it does, SSA cannot definitively determine the frequency of these errors. In addition, we found that considering date errors substantially reduced some states' estimated CDR accuracy rates. Without tracking these errors, SSA cannot assess their effect and consider whether including them in its reported CDR accuracy rates has merit. There is no change in the status of this recommendation for 2017.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to adjust its approach to sampling CDRs to efficiently produce reliable accuracy rate estimates for continuances and cessations separately in each state.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA disagreed with this recommendation and stated that some states do not generate enough CDR decisions, particularly cessations, to generate statistically valid samples. However, for states with CDR samples that are consistently too small to produce reliable results, SSA could, for example, pool decisions from more months than it currently does to generate statistically valid samples by state. Conversely, for states with CDR samples that are consistently larger than necessary to efficiently achieve reliable results, SSA could, for example, reduce sample sizes. Because CDR accuracy rates vary by state and cessations are consistently less accurate than continuances, we maintain that SSA should adjust its approach to sampling CDRs. There is no change in the status of this recommendation for 2017.
    Recommendation: The Acting Commissioner of Social Security should direct the Chief Actuary to better document the methods including data sources, assumptions, and limitations that factor into its estimates of CDR cost savings.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and stated that it will improve and expand its existing documentation as time and resources permit. As of July 2017, SSA had begun to improve documentation of its OASDI estimates and plans further enhancements including documenting the methods of its SSI estimates.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To strengthen management of the Direct Loan Program and ensure good customer service for borrowers, the Secretary of Education should direct the Office of Federal Student Aid's Chief Operating Officer to review its methods of providing instructions and guidance to servicers, identifying areas to improve clarity and sufficiency, and ensure consistent delivery of instructions and guidance to ensure program integrity and improve service to borrowers. For example, the Department could consider implementing a detailed, common servicing manual for the Direct Loan program.

    Agency: Department of Education
    Status: Open
    Priority recommendation

    Comments: The Department of Education agreed with this recommendation and has reviewed its guidance to servicers, as of October 2016. It has issued clarifications to servicers in several areas. In addition, the Department had been in the process of an acquisition for a new loan servicing solution but, as of September 2017, is reassessing its acquisition strategy. While the plan for the revised acquisition is not finalized, FSA expects its approach to significantly streamline the process of communicating instructions and guidance to servicers, as well as improve the overall experience for students and borrowers. Upon resolution of its acquisition strategy, Education needs to demonstrate that its final contract for a new loan servicing solution is structured to provide clear and consistent instructions and guidance to servicers to ensure program integrity and improve service to borrowers.
    Director: James R. McTigue, Jr.
    Phone: (202) 512-9110

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

    Agency: Congress
    Status: Open

    Comments: In 2017, several bills were introduced in Congress that would authorize the Department of Treasury to regulate paid tax return preparers. As of September 2017, no action has been taken on any of the bills. GAO testified on October 1, 2015 on improper payments and the tax gap before Senate Finance and on December 10, 2015 on GAO recommendations before the Subcommittee on Regulatory Affairs and Federal Management, Committee on Homeland Security and Governmental Affairs, US Senate. Both hearings increased attention to GAO's matter to Congress that tax preparers be regulated. Paid preparer regulation may increase the accuracy of tax returns and potentially reduce the tax gap.
    Director: Khan, Asif A
    Phone: (202)512-3000

    4 open recommendations
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), in coordination with the military service secretaries (as appropriate), to revise the Army procedures to include specific steps required to retain documentation of the activities performed and related results.

    Agency: Department of Defense
    Status: Open

    Comments: In commenting on the draft report, DOD concurred with the recommendation and cited actions in process to revise its Financial Management Regulation (FMR). In 2016, the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) stated that the Components provided comments and edits to the draft Chapter 23. The comments were more detailed than projected and require extensive research to verify. However, it is not clear whether this action will provide sufficient Army-specific procedural requirements. As of August 2017, we have not been able to obtain supporting documentation to assess whether the recommendation was implemented.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), in coordination with the military service secretaries (as appropriate), to revise the Marine Corps and Air Force procedures to include specific steps required to validate data in the OCO report including reconciliations and retain documentation of the activities performed and related results.

    Agency: Department of Defense
    Status: Open

    Comments: In commenting on the draft report, DOD concurred with the recommendation and cited actions in process to revise its Financial Management Regulation (FMR). In 2016, the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) stated that the Components provided comments and edits to the draft Chapter 23. The comments were more detailed than projected and require extensive research to verify. However, it is not clear whether this action will provide sufficient Marine Corps and Air Force-specific procedural requirements. As of August 2017, we have not been able to obtain supporting documentation to assess whether the recommendation was implemented.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), in coordination with the military service secretaries (as appropriate), to establish Navy procedures to include specific steps required to validate data in the OCO report including variance analysis and reconciliations, and retain documentation of the activities performed and related results.

    Agency: Department of Defense
    Status: Open

    Comments: In commenting on the draft report, DOD concurred with the recommendation and cited actions in process to revise its Financial Management Regulation (FMR). In 2016, the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) stated that the Components provided comments and edits to the draft Chapter 23. The comments were more detailed than projected and require extensive research to verify. However, it is not clear whether this action will provide sufficient Navy-specific procedural requirements. As of August 2017, we have not been able to obtain supporting documentation to assess whether the recommendation was implemented.
    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), in coordination with the military service secretaries (as appropriate), to revise DOD requirements in FMR 7000.14-R, Volume 12, Chapter 23, Contingency Operations, to provide clear, detailed guidance on (1) conducting reconciliations and other validations and (2) documenting military service-level reviews and DOD Comptroller-level reviews.

    Agency: Department of Defense
    Status: Open

    Comments: In commenting on the draft report, DOD concurred with the recommendation and cited actions in process to revise its Financial Management Regulation (FMR). In 2016, the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) stated that the Components provided comments and edits to the draft Chapter 23. The comments were more detailed than projected and require extensive research to verify. As of August 2017, we have not been able to obtain supporting documentation to assess whether the recommendation was implemented.
    Director: Brostek, Michael
    Phone: (202)512-9039

    1 open recommendations
    Recommendation: To improve compliance with shareholder basis rules, Congress may wish to require S corporations to calculate and report shareholder's stock and debt basis as completely as possible. S corporations would report the calculation on the Schedule K-1 and send it to shareholders as well as IRS. If Congress judges that stock purchase price information that is currently only available to shareholders should not be transmitted to the S corporation due to privacy concerns, an alternative is to require that S corporations report less complete basis calculations using information already available to the S corporation.

    Agency: Congress
    Status: Open

    Comments: As of August 2017, Congress had not enacted legislation to require S corporations--a federal business type that provides certain tax benefits like passing income and losses to shareholders' individual returns-- to calculate and report shareholder's stock and debt basis as completely as possible and report the calculation to shareholders and IRS, as GAO suggested in December 2009.
    Director: White, James R
    Phone: (202)512-5594

    1 open recommendations
    Recommendation: Congress may wish to consider providing IRS with math error authority (MEA) to use prior years' tax return information to automatically verify taxpayers' compliance with the limit on the number of years the Hope credit can be claimed.

    Agency: Congress
    Status: Open

    Comments: As of August 3, 2017, Congress has not provided IRS with math error authority (MEA) to use prior years' tax return information to automatically verify taxpayers' compliance with the limit on the number of years the Hope Scholarship Credit, now known as the American Opportunity Tax Credit (AOTC) can be claimed. The AOTC can be claimed by taxpayers for qualified tuition and related expenses for 4 years of postsecondary education. Under the Protecting Americans From Tax Hikes Act of 2015, IRS was granted MEA to disallow a claim for the AOTC if the taxpayer is not permitted to claim the credit due to prior fraudulent or reckless claims, or if the taxpayer omitted information relating to prior improper claims of the credit. IRS does not have authority to automatically deny an AOTC even if the taxpayer claims the credit for more than the 4 allowable years. GAO has in the past provided technical assistance to the House Solutions Caucus in drafting legislative language for a bill on extending MEA to use prior years' returns for verifying compliance with limits on the credit. In addition, the Administration has for many years included a revenue proposal in Treasury's Green Book to provide IRS with "correctable error authority" where the (1) information provided by the taxpayer does not match the information contained in government databases, (2) taxpayer has exceeded the lifetime limit for claiming the credit or deduction, or (3) taxpayer failed to include proper documentation with his or her return. If this revenue proposal was enacted, IRS would have the authority to deny claims for the AOTC if the taxpayer has already received the credit for 4 years.
    Director: White, James R
    Phone: (202) 512-5594

    1 open recommendations
    Recommendation: Given the potential for improving compliance now and in the future, Congress may wish to provide IRS with the authority to use math error checks to identify and correct returns with ineligible (1) IRA "catch-up" contributions, and (2) contributions to traditional IRAs from taxpayers over age 70-1/2.

    Agency: Congress
    Status: Open

    Comments: As of April 2017, the Congress has not provided IRS with the math error authority to ensure that taxpayers comply with certain catch-up and contributions requirements.