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 DOD 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 August 2017, DOD officials stated that its Office of the Under Secretary of Defense (Comptroller) will continue its work with DFAS to annually reconcile gross outlays (as stated on its Statement of Budgetary Resources) with outlays as reported in its Agency Financial Report. These reconciliations are currently done only on a summary level. In the future, DOD's validation of its universe of transactions combined with planned reconciliations with the Defense Departmental Reporting System trial balance and transaction data from DOD's entitlement systems will provide more complete reconciliations. As of December 2019, DOD officials stated that DOD needs to resolve its material weakness relating to the universe of transactions. This material weakness is preventing the department from performing the reconciliations necessary to ensure that the populations, from which the samples are drawn to estimate improper payments, are complete and accurate. As of May 2020, DOD had developed a spreadsheet including over 80 financial management and disbursing systems. The Office of the Under Secretary of Defense, OUSD(C), is planning to review and analyze these systems to (1) determine the types of payments and lists of systems used to process the types of payments; (2) confirm if reconciliations are done to verify the total outlays; and (3) determine the testing status of the universe of payments. As of September 30, 2020, this recommendation remains 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 (subsequently renamed as payment recapture 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 October 2018, this recommendation remains open. As of December 2019, DOD stated that in FY 2020, the Office of the Under Secretary (Comptroller) will coordinate with the DOD improper payment reporting components to analyze whether it would be cost effective to implement payment recapture audit programs for their payments. In a March 20, 2020 memorandum, the Deputy CFO asked DOD components, programs, or activities with annual payments exceeding $1 million to submit a payment recapture plan by June 30, 2020. If a component determines that payment recapture audits are not cost-effective, then the plan must provide the specific analysis and documentation used to reach that conclusion. When completed, the results of the evaluation will serve the Department's final position on payment recapture audit programs. As of September 30, 2020, this recommendation remains open as this evaluation was not yet complete.

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 28, 2017, DOD officials stated that the Office of the Under Secretary of Defense (Comptroller) will determine if a payment recapture audit plan was developed and submitted to OMB for approval in the previous fiscal years. If so, the Office of the Under Secretary of Defense (Comptroller) will determine its relevance and significance (i.e. cost effectiveness)to the improper payments program. If the payment recapture audit plan is considered to be applicable, the Office of the Under Secretary of Defense (Comptroller) will update the previous plan to comply with current OMB guidance. As of October 2018, this recommendation remains open. As of December 2019, DOD stated that in FY 2020, the Office of the Under Secretary (Comptroller) will coordinate with the DOD improper payment reporting components to analyze whether it would be cost effective to implement payment recapture audit programs for their payments. In a March 20, 2020 memorandum, the Deputy CFO asked DOD components, programs, or activities with annual payments exceeding $1 million to submit a payment recapture plan by June 30, 2020. If a component determines that payment recapture audits are not cost-effective, then the plan must provide the specific analysis and documentation used to reach that conclusion. When completed, the results of the evaluation will serve the Department's final position on payment recapture audit programs. As of September 30, 2020, this recommendation remains open as this evaluation was not yet complete..

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. 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. The Office of the Under Secretary of Defense (Comptroller) has developed and implemented a Payment Integrity Checklist to ensure that the department's annual improper payment and recovery audit reporting was complete, accurate, and in compliance with IPERA and OMB guidance. However, the DOD Inspector General in its May 2020 report, stated that while DOD published improper payment estimates for all eight programs for fiscal year 2019, it did not publish reliable estimates for five of the eight programs: Military Health Benefits, Civilian Pay, Military Retirement, DOD Travel Pay, and Commercial Pay. Moreover, DOD did not use accurate populations in calculating the improper payment estimates for the Military Retirement, Commercial Pay, and DOD Travel Pay programs. Based on these issues affecting improper payment reporting, we consider this recommendation to be open as of September 30, 2020.