Recommendation: The FEMA Administrator should improve the completeness and consistency of its communication of the requirement to apply for an SBA disaster loan prior to being considered for SBA-dependent other needs assistance. (Recommendation 1)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should assess the extent to which its process for determining an applicant's eligibility for SBA-dependent other needs assistance limits or prevents survivors' access to IHP assistance, and work with SBA to identify options to simplify and streamline the disaster assistance application process for survivors. (Recommendation 2)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should improve the IHP award determination letters by using federal guidance and best practices for communicating with the public to ensure that applicants understand that an "ineligible" determination does not mean they cannot continue to pursue assistance. (Recommendation 3)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should identify and implement strategies to provide additional information to applicants about how FEMA determined their eligibility for assistance and the amount of assistance to award. (Recommendation 4)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should evaluate the method for communicating changes in IHP standard operating procedures (SOP) to identify ways to improve their accessibility and usability by National Processing Service Center (NPSC) staff. (Recommendation 5)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should use desirable characteristics of employee engagement—including performance feedback, career development, communication, and attention to work-life balance—while completing planned activities for improving morale among call center staff. (Recommendation 6)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should use desirable characteristics of employee engagement—including performance feedback, career development, communication, and attention to work-life balance—when assessing NPSC staff satisfaction scores and identifying additional steps to strengthen employee morale. (Recommendation 7)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should assess the effectiveness of the IHP training and support for NPSC staff during surge events and implement any necessary changes. (Recommendation 8)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should identify and implement strategies to help ensure staff deployed to Disaster Recovery Centers (DRC) have the needed skills and capabilities to provide support and consistent service to survivors. (Recommendation 9)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should identify and implement strategies to provide readily accessible information and resources, such as guidance and training, about the Individuals and Households Program to state, local, tribal, and territorial officials. (Recommendation 10)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should identify and implement best practices for information sharing and coordinating with local officials, and other recovery partners, on the delivery of Transportable Temporary Housing Units in the interim while FEMA completes system improvements. (Recommendation 11)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should correct and refine the methodology used to survey survivor experiences with the IHP by (1) weighting the survey data to reflect the stratification of its survey design, (2) adjusting the base sampling weights for survey nonresponse within each stratum, and (3) calculating the sampling error for the survey data after adjusting the base sampling weights for nonresponse. (Recommendation 12)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should complete the following key process improvement activities as part of its effort to redesign the Individual Assistance Program: (1) engage with additional program customers and stakeholders to obtain a more comprehensive understanding of their needs; (2) assess performance gaps between current processes and customer and stakeholder needs, and develop measurable and achievable improvement goals to address any identified performance gaps; and (3) prioritize the processes that need improvement based on documented selection criteria. (Recommendation 13)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FEMA Administrator should establish time frames for finalizing the Individual Assistance Division's draft strategic plan and developing implementation plans that integrate its IHP improvement efforts. (Recommendation 14)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should ensure that the Secretaries of the Military Departments revise AFI 36-3026, Volume 1, to provide detailed guidance for financial determinations and to establish consistent medical standards for all of the military services to use in determining the dependency status of incapacitated adult children, including what household and personal expenses and income are allowable, how these are to be calculated, and what medical documentation is required. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and indicated that it would develop and apply a single set of financial and medical standards across the Department. DOD indicated that these standards would be published in an upcoming policy memorandum.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Secretaries of the Military Departments and the Director of the Defense Finance and Accounting Service, identifies and implements the most effective means to provide information to families of incapacitated adult children to assist them in completing the dependency determination process. Such methods could include providing additional application instructions to families, making improvements to the DD Form 137-5, Dependency Statement – Incapacitated Child Over Age 21, such as providing detailed explanations of allowable expenses and how they should be calculated, providing detailed information about available support services, and providing additional and more advance notice to families. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation and noted that existing instructional tools exist to help families navigate the dependency determination process. However, DOD indicated that a Under Secretary of Defense for Personnel and Readiness user group will identify additional means to improve the information available to military families.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clearly defines oversight responsibilities of the Department of Defense Human Resources Activity and the military services for the incapacitated adult child dependency process, including the consistent tracking, monitoring, and reporting of reliable data on incapacitated adult child dependency applications and determinations across the military services for use in data-driven decision-making. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation and stated that while current DOD guidance does not include specific oversight responsibilities for the incapacitated adult child program DOD concurred with the need for a single office to provide oversight of the program. DOD noted that the Under Secretary of Defense for Personnel and Readiness would identify the office and assign responsibility within 60 days of our report.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the Department of Defense Human Resources Activity to exercise its oversight responsibilities for the incapacitated adult child dependency process, as clarified, including the use of consistent and reliable data on applications and determinations for data-driven decision-making to identify and address deficiencies and to inform program efforts. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, however DOD noted that it would address the recommendation after it takes action on our recommendation related to defining oversight responsibilities for the incapacitated adult child dependency determination process.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clarifies the definition of a nondependent family member in DOD Instruction 1315.19 and the circumstances under which nondependent family members should be considered for services provided by the Exceptional Family Member Program. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it will review its policy to determine if the definition of a nondependent family member continues to be current and appropriate.

Recommendation: The Secretary of Defense should ensure that the Secretaries of the Military Departments revise military service-level policy to ensure consistency with the DOD Instruction 1315.19 definition of nondependent family members and the circumstance under which a nondependent family member should be considered for services provided by the Exceptional Family Member Program. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation and stated that if DOD determines the current definition of a nondependent family member is no longer appropriate, it will ensure that Service-level policies will be revised to be consistent with the definition.

Recommendation: The Commissioner of FHA should clearly define DASP objectives and develop measurable targets for all program objectives. (Recommendation 3)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued Standard Operating Procedures for these sales on October 17, 2019. We will continue to follow up with the agency on how it defines the DASP objectives and its development of measurable targets for the program objectives.

Recommendation: The Commissioner of FHA should use performance data to develop criteria for when to hold DASP sales. (Recommendation 4)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued a Standard Operating Procedure for these sales on October 17, 2019. However, HUD has not yet developed criteria for when to hold a DASP sale based on performance criteria.

Recommendation: The Commissioner of FHA should monitor individual purchasers' compliance with FHA's modification requirements and ensure the purchasers submit the data needed to evaluate the sustainability of modifications. (Recommendation 6)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued s Standard Operating Procedure for these sales on October 17, 2019. However, HUD has not yet addressed purchasers' compliance with FHA's modification requirements to ensure that purchasers submit the data needed to evaluate the sustainability of modifications. We will continue to follow up on the agency's response to this recommendation.

Recommendation: The Commissioner of FHA should develop a methodology to assess the range of possible outcomes for loans when setting DASP reserve prices. (Recommendation 8)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued a Standard Operating Procedure for these sales on October, 17, 2019. The procedures address reserve pricing but we will continue to follow up with the agency on any plans to develop a methodology to assess the range of possible outcomes when setting the reserve prices.

Recommendation: The Director of ICE should build on existing efforts to use data analytics by employing techniques, such as network analysis, to identify potential fraud indicators in schools petitioning for certification. (Recommendation 2)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should develop an implementation plan for the project aimed at strengthening background checks for DSOs; that plan should outline how the project will be executed, monitored, and controlled. (Recommendation 5)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should implement mandatory DSO training and verify that the training is completed. (Recommendation 6)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should complete the development and implementation of its plans for mandatory fraud-specific training for DSOs. (Recommendation 7)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Labor, in conducting any assessment of its staff training designed to improve clarity of communication with claimants, should ensure that the assessment considers claimants' challenges with understanding DOL's written communications on the evidence needed to successfully reopen or otherwise support a claim.

Agency: Department of Labor
Status: Open

Comments: DOL neither agreed nor disagreed with this recommendation. However, DOL acknowledged that it plans to focus its staff training efforts on a variety of needed training topics, including improving the quality of written communications. DOL further noted that its recently hired training analyst will be responsible for, among other things, designing assessment measures to gauge the quality of training and the effect it has improving the overall quality of claim outcomes. We encourage DOL to continue designing its assessment so that it considers claimants' challenges in understanding the evidence needed. As of July 2019, DOL said it will soon contract with a training vendor to help update training materials and expects training to be rolled out in fiscal year 2020. In addition, DOL said it has conducted hands-on staff training that includes providing claimants with a clear understanding as to why a claim is accepted or denied. We will consider closing this recommendation pending implementation of the updated training and efforts to assess it.

Recommendation: The Under Secretary for Benefits should develop and implement a plan for how VBA will use data from the new exam management system to oversee contractors, including how it will capture accurate data on the status of exams and use it to (1) assess contractor timeliness, (2) monitor time spent correcting inadequate and insufficient exams, and (3) verify proper exam invoicing. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and outlined improvements in the information collected through VBA's new exam management system. VBA is testing a mechanism to validate exam invoices submitted by contractors. It will be important for VBA to take the next step of developing and implementing a plan for how it will use information from the new system to ensure both accurate timeliness data and proper exam invoicing.

Recommendation: The Under Secretary for Benefits should regularly monitor and assess aggregate performance data and trends over time to identify higher-level trends and program-wide challenges. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA will use improved data in the new exam management system to regularly monitor and assess aggregate performance data, identify error trends, and monitor contractor performance and program-wide challenges.

Recommendation: The Under Secretary for Benefits should document and implement a plan and processes to verify that contracted examiners have completed required training. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA has started developing a training plan for contractors, as well as a new training delivery system, to validate that required training has been completed and to assess the effectiveness of this training through feedback from trainees, contractors, and quality review staff in VBA's contract exam program office. VBA intends to use this information to improve the implementation and content of training. VBA expects to fully implement its new training system before the end of fiscal year 2020. Once implemented, GAO will be able to close both of its recommendations related to training verification and assessment.

Recommendation: The Under Secretary for Benefits should collect information from contractors or examiners on training and use this information to assess training and make improvements as needed. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA has started developing a training plan for contractors, as well as a new training delivery system, to validate that required training has been completed and to assess the effectiveness of this training through feedback from trainees, contractors, and quality review staff in VBA's contract exam program office. VBA intends to use this information to improve the implementation and content of training. VBA expects to fully implement its new training system before the end of fiscal year 2020. Once implemented, GAO will be able to close both of its recommendations related to training verification and assessment.

Recommendation: The Administrator of SBA should conduct and document reviews of staff compliance with procedures associated with HUBZone certification and recertification. (Recommendation 2)

Agency: Small Business Administration
Status: Open

Comments: In January 2020, SBA officials told us that the agency is re-aligning resources and developing standards to reflect new processing times for certifications and recertifications, which will include revised employee performance elements and quarterly performance reviews. When SBA has completed these changes, we will assess whether the agency is conducting and documenting reviews of staff compliance.

Recommendation: To improve RRB's ability to make accurate disability benefit eligibility determinations, including CDRs, and to decrease the potential for making improper payments, Congress should consider granting RRB access to the Department of Health and Human Services' quarterly earnings information from the National Directory of New Hires database. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of March 2020, no legislation has been enacted resulting from this matter to Congress. RRB's (the Board) fiscal year 2020 budget proposal included a legislative proposal to provide the Board access to the NDNH. Although the Board reported that the resulting proposed legislation drafted by HHS - the entity that maintains the NDNH - would, if enacted, provide access to the NDNH, the Board opposed the proposal in part because it would not waive associated fees to access the NDNH, and concluded access to the NDNH would not be cost-effective. In January 2020, the Board informed GAO it is not currently seeking legislation to gain access to the NDNH, resulting in the Board continuing to use earnings data that may be outdated in its continuing disability reviews, but that it may seek access in the future.

Recommendation: To enhance RRB's ability to manage and oversee its CDR program, RRB should routinely compile and analyze CDR program data, such as the number of cases selected for review, the number of beneficiaries in each medical improvement category, outcomes, and the costs and benefits of conducting CDRs, to improve program oversight. (Recommendation 3)

Agency: Railroad Retirement Board
Status: Open

Comments: RRB agreed with this recommendation. In June 2020, RRB reported that its Program Evaluation and Management Services (PEMS) section will compile and analyze all relevant CDR program case and cost data to better oversee CDRs. RRB said that its first analysis would cover CDR's adjudicated from April 2019 through September 2020; as of June 2020 they had adjudicated 107 CDR cases. In addition, RRB reported that its monthly reporting on CDRs to the Director of Disability includes information on the type of CDR completed, the medical improvement category for medical CDR, and the disposition of the CDR. In August 2018, the agency had reported that it began reporting in October 2017 weekly pending CDR type action cases to the Director of Programs, and that it had begun tracking CDR reason codes for each medical improvement category. To close this recommendation, RRB will need to include an analysis of the costs and benefits of conducting CDRs, including any overpayments or underpayments processed, and share its complete analysis of CDRs through September 2020 after it is completed. At that point GAO will review the analysis and decide if it provides a sufficient bases for program oversight.

Recommendation: The Administrator of CMS should ensure that all types of Medicaid HCBS programs have requirements for states to avoid or mitigate potential conflicts of interest on the part of entities that conduct needs assessments that are used to determine eligibility for HCBS and to develop HCBS plans of service. These requirements should address both service providers and managed care plans conducting such assessments. (Recommendation 1)

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

Comments: HHS concurred with our recommendation. However, in an April 2018 update, HHS noted that the recommendation should be closed based on existing Medicaid regulations. GAO disagrees. The existing regulations--which GAO reviewed at the time of this study--do not address all types of Medicaid HCBS programs. For example, specific conflict of interest requirements are generally not in place for needs assessments that are used to inform HCBS eligibility determinations. Similarly, managed care plans may have a financial interest in the outcome of HCBS assessments used for both determining eligibility and service amounts. GAO maintains that states should be required to avoid or mitigate potential conflicts of interest on the part of entities-including both service providers and managed care plans-that perform the needs assessments that states use for eligibility determinations and to develop plans of service. As of December 2019, HHS officials have not informed us of any additional actions taken to ensure that states avoid or mitigate potential conflict of interests in needs assessments for all types of Medicaid HCBS programs. We will update the status of this recommendation when we receive additional information.

Recommendation: The Director of the USMS should develop and implement a mechanism to provide specific feedback to employees on the results of the promotion process, including their readiness for promotion. (Recommendation 2)

Agency: Department of Justice: United States Marshals Service
Status: Open

Comments: USMS concurred with this recommendation and said that it is taking steps to implement it. In August 2018, USMS began providing feedback reports to employees completing the redesigned competency assessment process, which include detailed breakouts of scores by competency. However, these reports do not contain specific feedback, including the employee's readiness for promotion. As of June 2019, USMS is finalizing plans to provide training to employees on the GS-13 and GS-14 competencies. As of August 2020, USMS is building development programs and computer-based courses for each grade level, including GS-13 and GS-14. To fully address this recommendation, USMS should provide information on efforts or plans to provide specific feedback to employees, including on their readiness for promotion, and provide final training plans.

Recommendation: The Secretary of Health and Human Services should direct the Administrator of the Centers for Medicare & Medicaid Services to take steps to ensure that state-based marketplace annual sustainability plans, to the extent possible, have complete 5-year budget forecasts. (Recommendation 1)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS did not concur with our recommendation and stated that it had updated its requirement to request 2-year budget forecasts instead of 5-year budget forecasts. In its December 2017 statement of actions, HHS stated that it was working to streamline and simplify its data collection effort as part of the annual sustainability plan. In April 2018, HHS provided a revised 2-year budget forecast template as well as related state marketplace training documentation. As of April 2020, HHS had not provided further documented evidence of its streamlined process using the 2-year budget forecast template or justification that a 5-year budget is not necessary for assessing long-term financial sustainability and state marketplace sustainability risks.

Recommendation: The Secretary of Health and Human Services should direct the Administrator of the Centers for Medicare & Medicaid Services to take steps to ensure that all state-based marketplaces provide required annual financial audit reports which are in accordance with generally accepted government auditing standards. (Recommendation 2)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with our recommendation and stated in its December 2017 update that it continued to provide technical assistance such as webinars and other trainings on independent financial and programmatic audit submission requirements. In April 2018, HHS provided evidence that it had taken some steps to ensure that state-based marketplaces provide required annual financial audit reports, including draft financial audit procedures, documentation of related training provided to states, and a revised HHS state officer annual review checklist emphasizing financial audit reporting. However as of April 2020, the department had not provided evidence of finalized procedures, examples of checklist usage, or of states providing annual financial audit reports. Further, HHS training documentation stated that state-based marketplaces could provide alternate financial audit reports, such as a state-wide financial audit report, in lieu of a marketplace specific report. It is not clear from the provided evidence that the department has ensured that state-based marketplaces are in compliance with financial audit reporting requirements. We will continue to monitor the department's progress in implementing the recommendation and provide updates when the agency takes further action.

Recommendation: The Secretary of Health and Human Services should direct the Administrator of the Centers for Medicare & Medicaid Services to take steps to ensure that marketplace IT self-sustainability risk assessments are based on fully defined measurable terms, a clear categorization process, and a defined response to high risks. (Recommendation 3)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with our recommendation and stated in its December 2017 update that it would refine its marketplace self-sustainability risk assessment process to provide greater insight into the state marketplace sustainability efforts and to identify areas where states may need assistance. In April 2018, HHS provided evidence that it had taken some steps to base its risk assessments on fully defined processes. CMS provided documentation of clearly defined and measurable terms used for state marketplace budget analysis. However, HHS did not provide evidence that these defined terms were incorporated into analyses or risk assessments. As of April 2020, CMS has not provided evidence that it took steps to develop a clear categorization process or a defined response to high risks. We will continue to monitor the department's progress in implementing the recommendation and provide updates when the agency takes action.

Recommendation: The Secretary of Health and Human Services should direct the Administrator of the Centers for Medicare & Medicaid Services to take steps to ensure that states develop, update, and follow performance measurement plans that allow the states to continuously identify and assess the most important IT metrics for their state marketplaces. (Recommendation 4)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS partially concurred with our recommendation and stated in its December 2017 update that though each marketplace was accountable for managing and reporting its own IT metrics in accordance with federal and state law, HHS would work with states on the improvement of their management and operations through technical assistance and oversight and accountability measures. As of April 2020, the agency had not yet provided sufficient evidence that it has implemented the recommendation. We will continue to monitor the department's progress in implementing the recommendation and provide updates when the agency takes action.

Recommendation: The Secretary of Health and Human Services should direct the Administrator of the Centers for Medicare & Medicaid Services to take steps to conduct operational analysis reviews and systematically monitor the performance of states' marketplace IT systems using key performance indicators. (Recommendation 5)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS did not concur with our recommendation and stated that it conducted Open Enrollment Readiness Reviews to assess marketplace key performance indicators, which according to CMS officials, are similar to operational analysis reviews. However, as of October 2018, HHS had not provided evidence that the Open Enrollment Readiness Reviewed systematically and comprehensively reported on the key performance indicators or include discussion of other key elements identified in best practices for operational analysis reviews, such as how objectives could be better met, or costs could be saved. As of April 2020, the agency had not yet provided sufficient evidence that it has implemented the recommendation.

Recommendation: The Secretary of Health and Human Services should direct the Administrator of the Centers for Medicare & Medicaid Services to take steps to ensure that metrics collected from states to monitor marketplaces' operational performance link to performance goals and include baselines and targets to monitor progress. (Recommendation 6)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS partially concurred with our recommendation and stated in its December 2017 update that states were responsible for monitoring their own performance measures but HHS would continue to review IT metrics of state marketplaces in the implementation phase of their systems through technical assistance activities and oversight and accountability measures. As of April 2020, the agency had not yet provided sufficient evidence that it has implemented the recommendation. We will continue to monitor the department's progress in implementing the recommendation and provide updates when the agency takes action.

Recommendation: To provide reasonable assurance that USRAP applicant fraud prevention and detection controls are adequate and effectively implemented, the Secretaries of Homeland Security and State should conduct regular joint assessments of applicant fraud risk across USRAP.

Agency: Department of Homeland Security
Status: Open

Comments: We reported that the Department of State and DHS's U.S. Citizenship and Immigration Services (USCIS) have not jointly assessed applicant fraud risks across the U.S. Refugee Admissions Program (USRAP), consistent with federal internal control standards and leading practices for fraud risk management. Specifically, we reported that although State and USCIS perform a number of fraud risk management activities and have responded to individual instances of applicant fraud in the program, these efforts do not position State and USCIS to assess fraud risks program-wide for USRAP or know if their controls are appropriately targeted to the areas of highest risk in the program. Therefore, we recommended that the Secretaries of Homeland Security and State conduct regular joint assessments of applicant fraud risk across USRAP. USCIS concurred with our recommendation. In response, State reported that it will work together with USCIS to conduct joint risk assessments by jointly developing a risk assessment framework. According to DHS and State documentation, the departments finalized a joint framework in January 2018. In February 2019, DHS and State provided us with the interim progress report on their efforts to conduct an assessment of applicant fraud risk across USRAP. In June 2019, USCIS reported that DHS and State have completed the planned analysis and the draft report is being prepared for leadership review and clearance. DHS estimated that the report will be completed by September 30, 2020. To fully address the recommendation, State and USCIS should jointly conduct regular fraud risk assessments across USRAP.

Recommendation: To provide reasonable assurance that USRAP applicant fraud prevention and detection controls are adequate and effectively implemented, the Secretaries of Homeland Security and State should conduct regular joint assessments of applicant fraud risk across USRAP.

Agency: Department of State
Status: Open

Comments: We reported that the Department of State and DHS's U.S. Citizenship and Immigration Services (USCIS) have not jointly assessed applicant fraud risks across the U.S. Refugee Admissions Program (USRAP), consistent with federal internal control standards and leading practices for fraud risk management. Specifically, we reported that although State and USCIS perform a number of fraud risk management activities and have responded to individual instances of applicant fraud in the program, these efforts do not position State and USCIS to assess fraud risks program-wide for USRAP or know if their controls are appropriately targeted to the areas of highest risk in the program. Therefore, we recommended that the Secretaries of Homeland Security and State conduct regular joint assessments of applicant fraud risk across USRAP. USCIS concurred with our recommendation. In response, State reported that it will work together with USCIS to conduct joint risk assessments by jointly developing a risk assessment framework. According to DHS and State documentation, the departments finalized a joint framework in January 2018. In February 2019, DHS and State provided us with the interim progress report on their efforts to conduct an assessment of applicant fraud risk across USRAP. In June 2019, USCIS reported that DHS and State have completed the planned analysis and the draft report is being prepared for leadership review and clearance. DHS estimated that the report will be completed by September 30, 2020. To fully address the recommendation, State and USCIS should jointly conduct regular fraud risk assessments across USRAP.

Recommendation: To address control weaknesses and related program-integrity risks we identified in Lifeline, the Chairman of FCC should require Commissioners to review and approve, as appropriate, spending above the budget in a timely manner.

Agency: Federal Communications Commission
Status: Open

Comments: On November 16, 2017, FCC adopted a Notice of Proposed Rulemaking that proposed to adopt a self-enforcing budget mechanism for the Lifeline program. However, as of January 2020, FCC has not yet adopted a decision on this proposal.

Recommendation: To address control weaknesses and related program-integrity risks we identified in Lifeline, the Chairman of FCC should establish time frames to evaluate compliance plans and develop instructions with criteria for FCC reviewers how to evaluate these plans to meet Lifeline's program goals.

Agency: Federal Communications Commission
Status: Open

Comments: According to the FCC as of January 28, 2020, the agency does not currently have a schedule to implement this recommendation.

Recommendation: To address control weaknesses and related program-integrity risks we identified in Lifeline, the Chairman of FCC should develop an enforcement strategy that details what violations lead to penalties and apply this as consistently as possible to all Lifeline providers to ensure consistent enforcement of program violations; the strategy should include a rationale and method for resource prioritization to help maximize the effectiveness of enforcement activities.

Agency: Federal Communications Commission
Status: Open

Comments: FCC's enforcement must remain flexible in order to be responsive to the ever changing variants that Universal Service Fund violations may take. According to the FCC, as with all Commission matters, the Chairman may indicate agency priorities in terms of subject matter, but the Chairman does not dictate which cases the Enforcement Bureau pursues. The Office of the Chairman, in consultation with the Enforcement Bureau, has articulated priorities with respect to enforcement activities in the Lifeline area including, but not limited to: 1. Detection and elimination of willful attempts to defraud the Lifeline Program by claiming support subsidies for ineligible or fictitious subscribers. 2. Detection and elimination of unlawful claims for enhanced support for Tribal areas. 3. Detection and elimination of carrier collections of multiple support subsidies for duplicative subscribers, regardless of the source of duplications. 4. Detection and elimination of carrier failures to de-enroll inactive or ineligible subscribers. The Enforcement Bureau has focused its enforcement efforts in line with these priorities and has taken a number of actions since the publication of GAO-17-538.

Recommendation: To address our findings regarding the USF, the Chairman of FCC should take action to respond to USAC requests for guidance and address pending requests concerning USF contribution requirements to ensure the contribution factor is based on complete information and that USF pass-through charges are equitable.

Agency: Federal Communications Commission
Status: Open

Comments: According to the FCC, the FCC is scheduled to complete implementing this recommendation in December 2021.

Recommendation: To further align efforts to address appeals workload and improve timeliness of decisions, and reduce the risk that efforts will not go as planned, the Secretary of Veterans Affairs should direct the Under Secretary for Benefits; the Chairman, Board of Veterans' Appeals; and the Chief Information Officer, as appropriate, to develop a schedule for IT updates that explicitly addresses when and how any process reform will be integrated into new systems and when Caseflow will be ready to support a potential streamlined appeals process at its onset.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred in principle with this recommendation. Moreover, since our March 2017 report, Congress passed the Veterans Appeals Improvement and Modernization Act of 2017, which required VA to develop a comprehensive appeals plan that included, among other things, descriptions of modifications to, cost estimates of and timelines for information technology that the agency needs to carry out appeals reform. However, more than a year after implementation of appeals reform, VA's February 2020 updated plan and FY 2021 budget request indicate that Caseflow has "minimal functionality", with many functionalities yet to be implemented. Further, VA's February 2020 updated plan and its FY 2021 budget request do not include specific steps or goals related to achieving overall functionality, integrated testing, or IT training for staff on new functionality still to be implemented in 2020 or beyond. While the VA's use of the agile process for IT development can help mitigate risks and avoid cost overruns and delays, VA's plans do not signal when Caseflow will support all of the Board's workflow needs for processing appeals under the new process. Such longer-term planning also could help ensure that all potential changes are anticipated in the plans of various VA components. For example, VA's February 2020 updated plan states that VHA cannot use Caseflow to efficiently and effectively manage its appeals workload. Longer-term planning could also ensure more transparency around additional resources needed to fully implement Caseflow versus other appeals-related technologies enterprise wide. We will consider closing this recommendation when VA has produced a longer-term plan for developing, implementing and integrating Caseflow functionality in support of a streamlined appeals process, including clear definitions of initial/minimal operating capability and full operational capability.

Recommendation: To better understand whether appeals process reform, in conjunction with other efforts, has improved timeliness, the Secretary of Veterans Affairs should direct the Under Secretary for Benefits; the Chairman, Board of Veterans' Appeals; and the Chief Information Officer, as appropriate to develop a strategy for assessing process reform--relative to the current process--that ensures transparency in reporting to Congress and the public on the extent to which VA is improving veterans' experiences with its disability appeals process.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred in principle with this recommendation. Moreover, since our March 2017 report, Congress passed the Veterans Appeals Improvement and Modernization Act of 2017, which required VA to produce a comprehensive appeals plan that required VA, among other things, to periodically publish a range of metrics, including timeliness, related to the processing of appeals under the new and legacy system. As of February 2019, VA implemented appeals reform; however VA has not indicated how it will assess whether or the extent to which the new process, which also allows for multiple appeal opportunities, will achieve final resolution of veterans' appeals sooner, on average, than the legacy process. We will consider closing this recommendation when the Board establishes timeliness goals for all new appeals options and VA has produced a plan for analyzing whether the new process is an improvement. Closure of this recommendation is related to recommendation 2 in GAO-18-352.

Recommendation: To improve management and oversight of the SAVE program, the director of USCIS should develop and implement a mechanism to oversee agencies' completion of training on additional verification in accordance with SAVE MOA provisions and program policies.

Agency: Department of Homeland Security: United States Citizenship and Immigration Services
Status: Open

Comments: In March 2017, we found that USCIS does not track or monitor whether SAVE users have completed training and therefore does not have reasonable assurance that users have mastered SAVE policies and procedures prior to accessing the system. We recommended that USCIS develop and implement a mechanism to oversee agencies' completion of training on additional verification in accordance with SAVE provisions and program policies. The USCIS Verification Division reported that it planned to address providing additional training for SAVE users developed by December 31, 2017. The SAVE Program would then offer training events for agencies on the new material reflecting the agency user requirements for additional verification as well as system enhancements. In September 2017, the Verification Division implemented part one of this recommendation, a monthly webinar training session on user agency responsibilities and additional verification. This training can also be delivered to user agencies upon request. For part two of this recommendation, the SAVE program also developed training features to oversee agencies' completion of training. These training features are a system enhancement that will be incorporated into SAVE's overall modernization effort and was expected to be completed by September 30, 2019. In the interim, SAVE is implementing several other enhancements that will reduce the number of cases sent to additional verification, including the completion of modernized matching logic and initial verification screens and retiring less efficient access methods. In September 2019, SAVE officials told us that SAVE has reduced the number of cases sent to additional verification by retiring inefficient access methods and completing modernization of SAVE matching logic and initial verification screens. However, SAVE officials said they also determined that they must update the SAVE tutorial platform and content to account for these and other changes. Officials said that while SAVE is updated, the program continues to provide training, resources, and other support to user agencies to help ensure they are performing additional verification in accordance with SAVE MOA provisions and program policies. The new estimated completion date is February 28, 2021.

Recommendation: To preserve the balance between the importance of repaying federal student loan debt and protecting a minimum level of Social Security benefits put in place by the Debt Collection Improvement Act of 1996, Congress should consider modifying Social Security administrative offset provisions, such as by authorizing the Department of the Treasury to annually index the amount of Social Security benefits exempted from administrative offset to reflect changes in the cost of living over time.

Agency: Congress
Status: Open

Comments: As of December 2018, Congress has not yet taken action on this matter.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should inform affected borrowers of the suspension of offset and potential consequences if the borrower does not take action to apply for a TPD discharge. Such information could include notification that interest continues to accrue and that offsets may resume once their disability benefits are converted to retirement benefits.

Agency: Department of Education
Status: Open

Comments: The Department of Education does not currently notify borrowers of the suspension of offset, but plans to implement a process to do so in the future using a new mailing sent to affected borrowers by their default servicer. The current budget situation does not allow for this type of enhancement, and it is not clear when that will change. In the interim, the agency is exploring alternative notification approaches that could be put in place prior to the implementation of an automated solution. Although Education reported in December 2018 that it has implemented this recommendation, we will consider closing it when we receive documentation that this effort has been completed. As of October 2020, Education's website includes information about the suspension of offset. However, affected borrowers may not know to check the website and the agency has not provided documentation that it has directly alerted affected borrowers.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should revise forms sent to borrowers already approved for a TPD discharge to clearly and prominently state that failure to provide annual income verification documentation during the 3-year monitoring period will result in loan reinstatement.

Agency: Department of Education
Status: Open

Comments: The FUTURE Act (H.R. 5363), signed into law on Dec. 19, 2019, requires the Department of Education (Education) to automate the income monitoring process for borrowers whose loans are discharged for total and permanent disability. As a result of automating the process, borrowers will no longer need to receive Education's forms requesting the borrower to individually provide their income verification documentation during the 3-year monitoring period.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should inform borrowers about the financial hardship exemption option and application process on the agency's website, as well as the notice of offset sent to borrowers.

Agency: Department of Education
Status: Open

Comments: The Department of Education agrees with the recommendation and said that they will include this change in upcoming revisions to the agency's web content. The agency reported that the Notice of Offset to borrowers is sent by Treasury and that they will share this recommendation with Treasury and discuss possible changes to the notice. As of October 2020, Education's website notes that borrowers can request a review of their offset , but it does not specifically note that they may do so because of a financial hardship. Although Education reported in December 2018 that it has implemented this recommendation, we will consider closing it when we receive documentation that the agency has notified borrowers about the financial hardship exemption process on its website and the notice of offset sent to borrowers.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should implement an annual review process to ensure that only eligible borrowers are exempted from offset for financial hardship on an ongoing basis.

Agency: Department of Education
Status: Open

Comments: The Department of Education reported that it plans to fully automate their process for tracking hardships and other exceptions from offset. However, due to competing priorities and funding limitations, full implementation of these improvements have not been scheduled. As they fully implement this process, they will review complementary strategies to assist borrowers in complying with annual reporting requirements. As of December 2018, Education reported that it is in the process of re-designing the student loan financial services environment, which will lead to major improvements such as offset exceptions. They are conducting market research on the new environment, then plan to develop requirements and timelines in support of a procurement with a projected completion in September 2020. We will consider closing this recommendation when we receive documentation that the agency has implemented an annual review process.

Recommendation: To help ensure quality information is conveyed to servicemembers about how the Servicemembers Civil Relief Act (SCRA) interest rate cap applies to student loans, the Secretary of Defense should direct the secretaries of each service branch, and work with other secretaries as appropriate, to ensure that all information about the SCRA interest rate cap for student loans is accurate when provided to servicemembers and to those who work with servicemembers to help them obtain SCRA benefits, including information contained in outreach materials.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) disagreed with this recommendation believing it to be unnecessary because it is already providing accurate information. Specifically, DOD noted that the information provided in several documents GAO reviewed is accurately based on statute whereas Education's updated requirement to automatically apply the cap is based on policy that could change in the future. Moreover, the automated process applies only to federal and commercial FFEL student loans in contrast to other types of debt. DOD said that providing information based on statute rather than policy would cause less confusion and was a better approach than what we recommend. However, our report noted that Education formalized the automated process through federal regulations, effective July 2016, which legally require servicers to use this process for all federal and commercial FFEL loans. In addition, DOD said it was unable to verify whether DOD's Military OneSource website inaccurately states that the SCRA rate cap does not apply to commercial FFEL loans. However, our searches of the website still turned up this inaccuracy. DOD said it would look into a means of verifying website information but that in the meantime, it is satisfied that its training provides correct information. Given that Military OneSource is a key source of information for servicemembers and that some documents DOD provided state that the SCRA rate cap does not apply to student loans, we continue to believe that servicemembers are not always receiving accurate and up-to-date information. In August 2018, DOD reiterated that it continues to disagree with this recommendation based on the rationale above. DOD did not provide an update for 2020.

Recommendation: To ensure that all eligible servicemembers with student loans receive the SCRA interest rate cap, the Attorney General should direct the Department of Justice to consider modifying its proposed changes to SCRA to require use of the automatic eligibility check for private student loans.

Agency: Department of Justice: Office of the Attorney General
Status: Open

Comments: The Department of Justice (DOJ) stated that its current package of proposed legislative changes provides benefits to servicemembers with all kinds of loans, including private student loans. Rather than requiring servicemembers to submit written notice and a copy of military orders, they need only give oral or written notice of eligibility for the cap to their creditors. Creditors would then have to search the Department of Defense's records to verify the servicemembers' military service and apply the SCRA interest rate cap, when applicable. DOJ believes that these changes would significantly benefit all servicemembers with loans while providing a uniform standard for all types of creditors. The department added that it will consider its proposed changes to SCRA in future legislative proposals and plans to obtain feedback from stakeholders on how to improve SCRA's protections for servicemembers. However, as stated in our report, servicemembers with private student loans would still need to be aware of the rate cap in order to give notice, whether written or oral. Therefore, we encourage DOJ to consider updating its current proposal to require use of the automatic eligibility check by all student loan lenders and servicers. Not only would this ensure that servicemembers with private student loans receive a benefit for which they are eligible, but also that the interest rate cap is applied consistently across all types of student loans. DOJ did not provide an update for 2020.

Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: The Consumer Financial Protection Bureau (CFPB) stated that it is committed to working with the Department of Justice (DOJ) and federal financial regulators, when possible, to facilitate oversight of SCRA compliance and that it will support all relevant federal agencies in using their respective authorities to identify and address SCRA violations as efficiently and effectively as possible. While CFPB coordinates with DOJ and other federal regulators in general, there is still no single agency authorized to enforce SCRA compliance among nonbank private student loan lenders and servicers, and no entity is conducting onsite supervisory reviews of these lenders and servicers. In addition, while CFPB may refer complaints from servicemembers about the SCRA rate cap for private student loans to DOJ and other financial regulators, we believe this does not constitute routine, proactive oversight and also presumes servicemembers are aware of the SCRA rate cap. GAO will consider closing this recommendation when the bureau has provided evidence of actions it has taken to facilitate routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. CFPB did not provide an update for 2020.

Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

Agency: Department of Justice: Office of the Attorney General
Status: Open

Comments: The Department of Justice (DOJ) believes that it is in full compliance with this recommendation and that the four federal financial regulators do not have statutory authority to examine nonbank private student loan lenders and servicers unaffiliated with a depository institution. DOJ stated that it already coordinates extensively with the Consumer Financial Protection Bureau (CFPB) and the financial regulators concerning SCRA compliance through such mechanisms as referrals from CFPB for any SCRA-related violations and access to its consumer complaint database, and regular meetings with CFPB, and that it will continue to be built upon these efforts. While these mechanisms are commendable, GAO believes they do not constitute exercising routine oversight of nonbank private student loan lenders and servicers who are not affiliated with a depository institution. We believe that additional interagency coordination, including working with CFPB to seek additional statutory authority, as needed, is necessary to ensure routine SCRA compliance. DOJ did not provide an update for 2020.

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: In fiscal year 2020, the Senate passed S.4104, which included language to address the recommendation. In the context of the Do Not Pay (DNP) working system, the bill, if enacted, would authorize comparison of the Social Security Administration's (SSA) full death file with personally identifiable information reviewed through the working system and would allow redisclosure of such comparison of information to any federal or state agency authorized to use the working system. As of July 15, 2020, the House has not introduced a related bill for fiscal year 2020. Additionally, in February 2020, the administration released its President's 2021 Budget, which proposes legislation to allow the DNP Business Center full access to the SSA full death file. This proposal would include the Department of the Treasury and the SSA working together to determine the most efficient manner to make full death information available for use in preventing improper payment and fraud. We will continue to monitor congressional legislation to address 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: OMB 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. In fiscal year 2019, OMB provided us a status update on July 31, 2019, stating that Treasury does this monitoring and reports updates to OMB on a quarterly basis and that monitoring will occur in conjunction with the President's Management Agenda. In August 2020, Treasury provided us examples of reports that it provides to OMB to assist OMB with evaluating agency use of the DNP working system. We plan to meet with OMB to discuss how it uses these reports and will continue to monitor OMB's actions to address 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: The Office of Management and Budget (OMB) 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 working system is reliable. OMB provided us a status update on July 1, 2019, stating that OMB will work with Treasury to determine feasibility of doing this review and establishing a process during fiscal year 2019. As of February 2020, OMB has not provided any new status updates for this recommendation. We will continue to monitor the agency's actions to address 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: The Office of Management and Budget (OMB) 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. In fiscal year 2019, OMB provided us a status update on July 1, 2019, stating that this recommendation was addressed in OMB's Circular A-136. Additionally, we met with OMB officials on July 31, 2019. During the meeting, OMB officials informed us that the OMB Circular A-136, Section II.4.5 (bullet 3) (dated June 28, 2019) states that "Agencies should provide a brief narrative of the reduction in improper payments that is attributable to the DNP Initiative, as applicable. See OMB Circular A-123, Appendix C, Part V for a thorough overview of the roles and responsibilities of agencies to use centralized data sources such as the Treasury Working System and other government databases to prevent improper payments." We have reviewed OMB Circular A-136 and confirmed that the circular does contain the statements above. However, we do not believe that the OMB Circular A-136 meets the intent of our recommendation. GAO issued its recommendation, in part, because GAO found that OMB guidance does not indicate whether agencies should report on all uses of the DNP working system, including those outside payment integration that the DNP working system does not track. For this reason, GAO report concluded that without complete and reliable data and clear guidance on what information agencies should report, OMB cannot effectively monitor and evaluate the use of the DNP working system. Therefore, we do not believe that the OMB Circular A-136 sufficiently clarifies whether agencies should report on their uses of all of the functionalities of the DNP working system in their agency financial reports. As of February 2020, OMB has not provided any new status updates for this recommendation. We will continue to monitor OMB's actions to address this recommendation.

Recommendation: To help ensure that practitioners who may be ineligible do not possess a controlled substance registration and that practitioners who pose an increased risk of illicit diversion are identified, the Acting Administrator of DEA should take additional actions to strengthen verification controls. Specifically, the Acting Administrator of DEA should develop policies and procedures to validate SSNs and apply the policies and procedures to all new and existing SSNs in the CSA2; such an approach could involve collaborating with SSA to assess the feasibility of checking registrants' SSNs against the Enumeration Verification System.

Agency: Department of Justice: Drug Enforcement Administration
Status: Open

Comments: In April 2018, DEA told us that it assessed the feasibility of directly collaborating with SSA to check registrants' SSNs against any SSA systems, including the Enumeration Verification System (EVS), and is unable to implement a data verification process to validate SSNs against EVS without legislative authority. Specifically, DEA said that access to SSA's systems would require passage of new legislation to authorize DEA to fully participate in a data exchange agreement with SSA, which DEA said was also confirmed by Senate staff. In June 2020, DEA provided documentation of SSA's response to DEA's request to access EVS which stated that SSA was unable to enter into a data exchange under the conditions DEA initially proposed. However, it also stated that SSA would explore granting DEA access if DEA requested number-holder's consent. Therefore, we continue to believe there is a possible path forward in using SSA's service. Additionally, DEA told us that it would use information from the Federation of State Medical Boards (FSMB) to validate SSNs. However, as of August 2020, DEA has not provided any documentation to support how or if this has been implemented. Further, as noted in our report, FSMB is limited to information for medical doctors, osteopathic doctors and some physician assistants, which make up only a portion of DEA's registrants. As we noted in our report, validating SSNs will help establish registrants' identities which will better ensure DEA has the information necessary to implement its existing controls and to identify other registrations held by each individual, including past adverse actions taken against previous registrations. As such, we continue to believe that DEA should take steps to validate the information it receives. We will continue to monitor the agency's progress in this area.

Recommendation: To help ensure that practitioners who may be ineligible do not possess a controlled substance registration and that practitioners who pose an increased risk of illicit diversion are identified, the Acting Administrator of DEA should take additional actions to strengthen verification controls. Specifically, the Acting Administrator of DEA should identify and implement a cost-effective approach to monitor state licensure and disciplinary actions taken against its registrants; such an approach could include using data sources that contain this information, such as the National Practitioner Data Bank or the Federation of State Medical Boards.

Agency: Department of Justice: Drug Enforcement Administration
Status: Open

Comments: In July 2018, DEA provided a copy of its purchase order award to the Federation of State Medical Boards (FSMB); however, as of August 2020, DEA has not provided documentation to demonstrate how use of FSMB will be implemented. Also, in April 2018, DEA said it was exploring how to establish a cost-effective system to obtain National Practitioner Data Bank (NPDB) information and will reevaluate the need to obtain NPDB information after DEA has had the opportunity to process the FSMB information. In June 2020, DEA stated it will not be taking additional action on obtaining NPDB. We will continue to monitor DEA's progress in implementing this recommendation.

Recommendation: The Secretary of Veterans Affairs should direct the Under Secretary for Health to monitor the full amount of time newly enrolled veterans wait to be seen by primary care providers, starting with the date veterans request they be contacted to schedule appointments. This could be accomplished, for example, by building on the data collection efforts currently being implemented under the "Welcome to VA" program.

Agency: Department of Veterans Affairs
Status: Open
Priority recommendation

Comments: In March 2016, GAO recommended that VA monitor the full amount of time newly enrolled veterans wait to be seen by primary care providers, starting with the date veterans request they be contacted to schedule appointments. VA concurred with this recommendation, and in June 2017, reported to GAO that it had taken actions to address it. Specifically, VA indicated that it revised an internal report to help identify and document all newly enrolled veterans and monitor their appointment request status. The report is intended to enable VHA and its medical centers to oversee the enrollment and appointment process by tracking the following timeframes: (1) application to enrollment, (2) enrollment to initial contact, (3) initial contact to primary care appointment, and (4) total time from application to primary care appointment. However, VA also indicated in its response that it did not have data that captures application dates for all newly enrolled veterans. As such, the report could not be used to consistently monitor the full amount of time these veterans wait to be seen by primary care providers. In January 2018, VA reported developing and implementing technical enhancements to its electronic systems that will enable it to capture the application date for all newly enrolled veterans. In April 2018 and December 2018, VA reported making continued efforts to implement technical enhancements to its electronic system. In its February 2020 update, VA identified several steps that the agency was completing to fully implement the revised internal report and noted that following a successful piloting of the report, the agency would implement it system-wide. VA reported that it expects to fully address this recommendation by October 2020.

Recommendation: To better oversee the efficacy of PPACA's enrollment control process; to better monitor costs, risk, and program performance; to assist with tax compliance; to strengthen the eligibility determination process; to provide applicants with improved customer service and up-to-date information about submission of eligibility documentation; and to better document agency activities, the Secretary of Health and Human Services should direct the Acting Administrator of CMS to track the value of advance premium tax credit and cost-sharing reduction (CSR) subsidies that are terminated or adjusted for failure to resolve application inconsistencies, and use this information to inform assessments of program risk and performance. (See related recommendation 7.)

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: In April 2016, HHS reported it considers this recommendation closed because it expanded the use of analytics to analyze the value of premium tax credit and CSR subsidies that are eliminated or adjusted for 2015 actions at the policy level, and that CMS continues to analyze the data to develop future operations changes. In May 2016, we requested documentation of these actions, including (1) information produced using the capability described; (2) ways in which this information is being used for analysis for purposes such as program operations, monitoring, risk assessment, or fraud cleaning; and (3) a description of the future operational changes contemplated based on the analyses done. However, as of December 2018, HHS officials had not provided GAO with evidence that the agency had implemented this recommendation. GAO said it would continue to monitor the agency's progress in this area. In March 2019, CMS reversed its initial concurrence with the recommendation, citing inability to obtain necessary data from another agency and a legal opinion on CSR subsidies. GAO kept the recommendation open, saying the developments HHS cited were irrelevant. In December 2019, after HHS reiterated its non-concurrence, GAO continued to maintain the recommendation as open.

Recommendation: To better oversee the efficacy of PPACA's enrollment control process; to better monitor costs, risk, and program performance; to assist with tax compliance; to strengthen the eligibility determination process; to provide applicants with improved customer service and up-to-date information about submission of eligibility documentation; and to better document agency activities, the Secretary of Health and Human Services should direct the Acting Administrator of CMS to, in the case of CSR subsidies that are terminated or adjusted for failure to resolve application inconsistencies, consider and document, in conjunction with other agencies as relevant, whether it would be feasible to create a mechanism to recapture those costs, including whether additional statutory authority would be required to do so; and for actions determined to be feasible and reasonable, create a written plan and schedule for implementing them.

Agency: Department of Health and Human Services
Status: Open

Comments: As of December 2018, CMS officials said the Department of Health and Human Services (HHS) had received a legal opinion from the U.S. Attorney General regarding validity of CSR payments, which prompted the agency to halt the payments as of October 2017. CMS officials said that if the recommendation were to be implemented, it would amount to creating new rules and a process for a program feature that no longer exists. However, in January 2019, HHS indicated that the administration supports a legislative solution that would appropriate CSR payments, and GAO continues to monitor for relevant legislative action. If funding becomes available to restore CSR payments, then implementing this recommendation would aid CMS in reducing improper payments. In December 2019, CMS reversed its initial concurrence with the recommendation, citing the legal opinion. GAO, however, continued to maintain the recommendation as open.

Recommendation: To better oversee the efficacy of PPACA's enrollment control process; to better monitor costs, risk, and program performance; to assist with tax compliance; to strengthen the eligibility determination process; to provide applicants with improved customer service and up-to-date information about submission of eligibility documentation; and to better document agency activities, the Secretary of Health and Human Services should direct the Acting Administrator of CMS to identify and implement procedures to resolve Social Security number inconsistencies where the Marketplace is unable to verify Social Security numbers or applicants do not provide them.

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: In April 2016, HHS reported that it considered this recommendation open and was working on implementing functionality for updating consumers' Social Security numbers (SSN) and their eligibility based on the correct SSN. HHS reported that is it targeting deployment of the SSN update functionality in 2017. However, as of December 2018, HHS officials had not provided GAO with evidence that the agency had implemented this recommendation. In December 2019, HHS told GAO it continues to evaluate steps necessary to implement the recommendation, and expects close-out by October 2020. We will continue to monitor the agency's progress in this area.

Recommendation: To better oversee the efficacy of PPACA's enrollment control process; to better monitor costs, risk, and program performance; to assist with tax compliance; to strengthen the eligibility determination process; to provide applicants with improved customer service and up-to-date information about submission of eligibility documentation; and to better document agency activities, the Secretary of Health and Human Services should direct the Acting Administrator of CMS to reevaluate CMS's use of Prisoner Update Processing System (PUPS) incarceration data and make a determination to either (a) use the PUPS data, among other things, as an indicator of further research required in individual cases, and to develop an effective process to clear incarceration inconsistencies or terminate coverage, or (b) if no suitable process can be identified to verify incarceration status, accept applicant attestation on status in all cases, unless the attestation is not reasonably compatible with other information that may indicate incarceration, and forego the inconsistency process.

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: In April 2016, HHS reported it considers this recommendation closed because in 2015, it made the determination to no longer require application filers to submit documentation regarding incarceration status. We were aware of that determination, but the recommendation was to reevaluate use of PUPS from the specific standpoint of using the data as it was intended to be used as in indicator of further research and then draw a conclusion on the use of the data. In May 2016, we requested documentation demonstrating that in the period since we made this recommendation, CMS has undertaken the reevaluation in the fashion that we indicated. As of December 2018, HHS officials had not provided GAO with evidence that the agency had implemented this recommendation. In December 2019, HHS told GAO it continues to evaluate steps necessary to implement the recommendation, and expects close-out by October 2021. We will continue to monitor the agency's progress in this area.

Recommendation: To better oversee the efficacy of PPACA's enrollment control process; to better monitor costs, risk, and program performance; to assist with tax compliance; to strengthen the eligibility determination process; to provide applicants with improved customer service and up-to-date information about submission of eligibility documentation; and to better document agency activities, the Secretary of Health and Human Services should direct the Acting Administrator of CMS to create a written plan and schedule for providing Marketplace call center representatives with access to information on the current status of eligibility documents submitted to CMS's documents processing contractor.

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: In April 2016, HHS reported that since May 2015, call center representatives have received daily updates on the status of eligibility documentation. HHS reported that it is working to provide call center representatives with real-time data. HHS reported it considers this February 2016 recommendation to be closed. In May 2016, GAO noted that its February 2016 recommendation was focused on providing such real-time capability and requested (1) confirmation that call center representatives currently have on-demand, real-time access to up-to-date, application-level document status; and documentation showing development and implementation of this capability; or (2) a written plan and schedule for providing this capability as recommended. However, as of December 2018, HHS officials had not provided GAO with evidence that the agency has implemented this recommendation. In December 2019, the agency provided new evidence in support of closure, for which GAO requested supporting information. We will continue to monitor the agency's progress in this area.

Recommendation: To better oversee the efficacy of PPACA's enrollment control process; to better monitor costs, risk, and program performance; to assist with tax compliance; to strengthen the eligibility determination process; to provide applicants with improved customer service and up-to-date information about submission of eligibility documentation; and to better document agency activities, the Secretary of Health and Human Services should direct the Acting Administrator of CMS to fully document prior to implementation, and have readily available for inspection thereafter, any significant decision on qualified health plan enrollment and eligibility matters, with such documentation to include details such as policy objectives, supporting analysis, scope, and expected costs and effects.

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: In April 2016, HHS reported it considers this recommendation closed because CMS prepares an annual Marketplace and Related Programs Cycle Memo to fulfill reporting requirements for internal control. The Memo describes all significant eligibility and enrollment policy and process changes, including new internal key controls associated with these changes, and the 2015 Memo was released in September 2015. In May 2016, we notified HHS that its actions do not close the recommendation. Information contained in the Memos is after-the-fact and while useful, does not meet the full range of documentation contemplated by our recommendation, especially development and analysis of changes prior to implementation. As of December 2018, HHS officials had not provided GAO with evidence that the agency has implemented this recommendation. In December 2019, HHS reversed its initial concurrence with the recommendation and said it would provide additional information on that decision. We will continue to monitor the agency's progress in this area.

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

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 yet conducted a systematic review of federal eligibility determinations. In July 2017, HHS issued its final rule on the Payment Error Rate Measurement (PERM) program, and stated that it would include reviews of federal eligibility determinations in states that have delegated that authority. In December 2017, HHS provided information noting that the first cycle of the revised PERM includes two states where there were federal eligibility determinations. However, as HHS confirmed in December 2019, the random sample of eligibility determinations reviewed in the first cycle of the revised PERM did not include any federal eligibility determinations. As such, the PERM has not systematically reviewed federal determinations, and we maintain that further reviews are needed to help ensure that only individuals eligible for Medicaid are receiving benefits. We will continue to monitor HHS to determine if HHS is ascertaining the accuracy of federal eligibility determinations and taking corrective action where necessary.

Recommendation: To ensure that the Defense Civilian Personnel Advisory Service (DCPAS) and DOD components are determining LQA eligibility consistently with DOD's LQA Instruction, the DSSR, and OPM compensation claim decisions, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to require the Deputy Assistant Secretary of Defense for Civilian Personnel Policy or DCPAS, as delegated, to monitor reviews of LQA eligibility determinations conducted by DOD components.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this action, and as of December 2019, had taken steps to improve oversight of LQA determinations by DOD components; however, it had not issued guidance that requires the Deputy Assistant Secretary of Defense for Civilian Personnel Policy or DCPAS to monitor reviews of LQA eligibility determinations by DOD components. At the direction of DCPAS, DOD components completed reviews and submitted reports of overseas allowances paid to a sampling of overseas employees for calendar years 2015, 2016, and 2017. According to DCPAS officials, in DOD's 2017 review of overseas allowances, one employee was identified as having erroneously received LQA. This number is lower than the three employees identified during the 2016 review and lower than the 11 employees identified in the 2015 review. Additionally, in September 2019, the Deputy Assistant Secretary of Defense for Civilian Personnel Policy issued a memorandum requesting DOD components to complete a review of overseas allowances and differentials, including LQA, paid to overseas employees during calendar year 2018. In January 2018, the Under Secretary of Defense for Personnel and Readiness issued a memorandum that clarified LQA eligibility requirements as applied and interpreted in recent Office of Personnel Management compensation claim decisions and the Department of State Standardized Regulations. The memorandum also required components to screen relevant records and determine if there are any employees who are no longer eligible to receive LQA based on the compensation claim decisions and Department of State Standardized Regulations. Finally, according to DCPAS officials, in December 2019, DOD was revising DOD's LQA instruction to incorporate the new LQA guidance from the January 2018 memorandum. However, it is unclear whether the revised instruction once issued will require the Office of the Deputy Assistant Secretary or DCPAS to monitor the reviews conducted by DOD components to identify any potentially inconsistent eligibility determinations and ensure corrective action is taken, as was the intent of GAO's recommendation.

Recommendation: The FCC should conduct a program evaluation to determine the extent to which the Lifeline program is efficiently and effectively reaching its performance goals of ensuring the availability of voice service for low-income Americans while minimizing the contribution burden on consumers and businesses.

Agency: Federal Communications Commission
Status: Open

Comments: In a 2016 Lifeline modernization order, which FCC adopted March 31, 2016, FCC instructed the Universal Service Administrative Company (USAC) to hire an outside, independent third-party evaluator to complete a program evaluation of the modernized Lifeline program. FCC noted that the program evaluation would enable FCC and the public to have better information about the operation and effectiveness of the Lifeline program. Such an evaluation will likely address our recommendation. FCC's order stipulated that USAC must submit the evaluation's findings to FCC by December 2020. In July 2020, FCC officials told us the evaluation should be complete by October 2020. We will update the status of this recommendation after we receive additional information from FCC.

Recommendation: To improve SBA's administration and oversight of the HUBZone program and reduce the risk that firms that no longer meet program eligibility criteria receive HUBZone contracts, the Administrator of SBA should establish a mechanism to better ensure that firms are notified of changes to HUBZone designations that may affect their participation in the program, such as ensuring that all certified firms and newly certified firms are signed up for the broadcast e-mail system or including more specific information in certification letters about how location in a redesignated area can affect their participation in the program

Agency: Small Business Administration
Status: Open

Comments: In response to this recommendation, SBA improved its notifications to newly certified firms but not to other certified firms. For example, SBA's certification letter to firms with principal offices in a redesignated area specifically states that the firm is in a redesignated area, explains the implications of the designation, and notes when the redesignated status will expire. However, we found in March 2016 that SBA had not yet implemented changes to better ensure that all currently certified firms would be notified of changes that could affect their program eligibility. It is important that all certified firms potentially affected by such changes receive information about the changes or are made aware in a timely fashion of any effects on their program eligibility. As of February 2017, SBA had begun to improve its notifications to all firms. According to SBA officials, the agency has started sending program notices to all the firms in its portfolio. They told us that for its most recent notice in February 2017, the agency copied all the e-mail addresses in its HUBZone database and placed them in the e-mail distribution system. In March 2018, SBA officials informed us that they obtain monthly lists of certified firms generated by an Oracle system process and that analysts compare the new list to the prior list and add any new firms to the list. In July 2019, SBA officials told us that they informed HUBZone firms of their responsibility to stay up to date on HUBZone geographical designations and program eligibility, through updated language in its HUBZone certification letters and two notices issued to HUBZone firms. While it is helpful that SBA now includes language in its certification letters notifying firms located in a redesignated area of the implications of that designation, SBA's current process does not inform firms when their status may change.

Recommendation: To improve SBA's administration and oversight of the HUBZone program and reduce the risk that firms that no longer meet program eligibility criteria receive HUBZone contracts, the Administrator of SBA should conduct an assessment of the recertification process and implement additional controls, such as developing criteria and guidance on using a risk-based approach to requesting and verifying firm information, allowing firms to initiate the recertification process, and ensuring that sufficient staff will be dedicated to the effort so that a significant backlog in recertifications does not recur.

Agency: Small Business Administration
Status: Open

Comments: In response to this recommendation, SBA officials told us that they began automating the process to notify firms that were due for recertification. According to the officials, since September 2015, notification e-mails have been sent daily (compared with the former cycle of two times a year). Each firm due for recertification within the next 30 days would receive the notice. SBA sends a second e-mail to firms that have not responded within 45 days of the first notification. According to SBA officials, as of February 2017, this change has not yet eliminated the backlog. SBA officials informed GAO in May 2017 that they have developed risk-based guidance for conducting recertification reviews and requesting supporting documentation. According to SBA, any certified HUBZone small business concern that has received $1 million or more in HUBZone contract dollars since its initial certification (or its most recent recertification) must submit the following: (a) a list of all current employees, identifying the name of the employee, the employee's address, the number of hours worked per month, and the location where the employee performs his/her work; and (b) payroll documentation. While SBA officials stated that they had completed a risk assessment of their HUBZone recertification process, SBA had not provided GAO with documentation on when SBA performed the risk assessment, which risks were identified and considered, or what analysis established the $1 million threshold as of August 2018. In July 2019, SBA provided a rationale for its risk-based approach to recertification, but the analysis for establishing the $1 million threshold remained unclear. SBA officials told us that the agency plans to conduct a risk assessment in accordance with GAO guidance for all government contracting and business development programs, including the HUBZone program. GAO continues to believe that such a risk assessment of the recertification process would help inform a risk-based approach to reviewing and verifying information from firms that appear to pose the most risk to the program.

Recommendation: To improve management and oversight of the WOSB program, and to help ensure the effective oversight of third-party certifiers, the Administrator of SBA should establish and implement comprehensive procedures to monitor and assess performance of certifiers in accord with the requirements of the third-party certifier agreement and program regulations.

Agency: Small Business Administration
Status: Open

Comments: In response to this recommendation, SBA has taken some actions. For example, SBA created a standard operating procedure stating that third-party certifiers are subject to a compliance review by SBA at any time, and SBA has completed a review of the four authorized third-party certifiers. We continue to monitor SBA actions to address this recommendation.

Recommendation: To improve management and oversight of the WOSB program, and to provide reasonable assurance that only eligible businesses obtain WOSB set-aside contracts, the Administrator of SBA should enhance examination of businesses that register to participate in the WOSB program, including actions such as: (1) promptly completing the development of procedures to conduct annual eligibility examinations and implementing such procedures; (2) analyzing examination results and individual businesses found to be ineligible to better understand the cause of the high rate of ineligibility in annual reviews, and determine what actions are needed to address the causes; and (3) implementing ongoing reviews of a sample of all businesses that have represented their eligibility to participate in the program.

Agency: Small Business Administration
Status: Open

Comments: In response to this recommendation, SBA has created a standard operating procedure that includes some procedures for annual eligibility examinations. We continue to monitor SBA actions to address this recommendation.

Recommendation: To ensure that the Family Caregiver Program is able to meet caregivers' demand for its services, the Secretary of the Department of Veterans Affairs should expedite the process for identifying and implementing an IT system that fully supports the program and will enable VHA program officials to comprehensively monitor the program's workload, including data on the status of applications, appeals, home visits, and the use of other support services, such as respite care.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with our recommendation and the Veterans Health Administration (VHA) and the Office of Information and Technology (OIT) have been working jointly on projects since 2015 to improve and replace the IT system for the Family Caregiver Program. However, two of these projects were terminated without delivering viable software improvements or a replacement system. According to two independent assessments, these prior efforts lacked both effective leadership and implementation of the processes needed for requirements management. In March 2019, VA began a third project, the Caregiver Record Management Application (CARMA), in which OIT and VHA began to acquire and implement a commercial product to replace the program's existing IT system. In February 2020, VA reported that to support the administrative needs of the Family Caregiver Program it had transitioned from its previous IT system to CARMA, its new IT system, in two stages: 1) In October 2019, VA deployed an initial release of CARMA for data entry of veterans and caregivers newly participating in the program, and 2) On December 2, 2019 the transition of existing veterans and caregivers to CARMA occurred. VA also reported in February 2020 that further enhancements and improvements to CARMA would be released over the coming months. However, the department has not yet fully committed to a date by which it will certify that CARMA fully supports the program. As of July 2020, this recommendation remains open pending further updates.

Recommendation: The Secretary of the Department of Veterans Affairs should direct the Undersecretary for Health to use data from the IT system, once implemented, as well as other relevant data to formally reassess how key aspects of the program are structured and to identify and implement modifications as needed to ensure that the program is functioning as envisioned so that caregivers can receive the services they need in a timely manner.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation. VA transitioned in late 2019 to a new IT system, the Caregiver Record Management Application (CARMA). However, the Department has not yet certified the readiness of CARMA to fully support the needs of the Program of Comprehensive Assistance for Family Caregivers (Family Caregiver Program). Prior to the transition to CARMA, VA had developed manual processes to obtain and monitor key data points, allowing it to reassess policies and procedures for the Family Caregiver Program. In its September 2019 update, VA reported that it anticipates being able to certify the IT system when proposed regulatory changes to enable the expansion of the Family Caregiver Program are finalized and the necessary changes which have an impact on IT are implemented. VA also reported that following certification, IT development will continue on IT requirements that do not directly impact VA's ability to expand the program, such as improving the program's ability to track and report on clinical appeals. As of July 2020, this recommendation remains open pending further updates on how VA plans to use data from the IT system to monitor and assess the program's performance.

Recommendation: To ensure that the Corps meets the statutory requirements related to deauthorization of projects, the Secretary of Defense should direct the Secretary of the Army to direct the Chief of Engineers and Commanding General of the U.S. Army Corps of Engineers to determine what projects are eligible for deauthorization, transmit the list to Congress, and publish projects that are deauthorized in the Federal Register once the new database includes all authorized projects.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. The Corps developed a list of projects for deauthorization in accordance with the Water Resources Development Act (WRDA) of 1986, Section 1001, and provided the list to OMB for clearance on January 26, 2018. Additionally, on December 9, 2019, the Corps reported that it provided a list of projects eligible for deauthorization in FY 2020 to the Assistant Secretary of the Army for Civil Works for review. Upon approval, the list will be sent to OMB for clearance. After receiving OMB clearance, according to the Corps, the list will be provided to Congress and the public in accordance with WRDA. As of July 2020, we are continuing to monitor the Corps' progress in implementing the recommendation.

Recommendation: To ensure that the Corps meets the statutory requirements related to deauthorization of incomplete water resources studies, the Secretary of Defense should direct the Secretary of the Army to direct the Chief of Engineers and Commanding General of the U.S. Army Corps of Engineers to determine what studies are eligible for deauthorization and transmit the list to Congress.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and as of December 2016, a task order has been awarded for a contractor to prepare a comprehensive inventory of studies authorized by statute. The Corps reported that once the comprehensive inventory of studies is complete, the Corps will develop policies and procedures for the study deauthorization process and those policies and procedures will be used to carry out the process of deauthorizing studies. In March 2020, the Corps reported that it was working to develop a scheduled for providing us with a list of studies eligible for deathorization. As of July 2020, we are continuing to monitor the Corps' progress in implementing the 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 U.S. Department of Agriculture agreed with this recommendation at the time of our report but, as of April 2020, has not acted to implement it because of the sensitive nature of questioning accountants' and attorneys' professional judgment. However, we believe doing so would reduce the potential for improper payments supported by taxpayers and would be an appropriate action for the agency to take.

Recommendation: To better ensure that requirements for tenant eligibility are met across the FLH portfolio, the Secretary of Agriculture should direct the Administrator of RHS to require its loan servicers to use the Systematic Alien Verification and Entitlements (SAVE) program administered by the Department of Homeland Security to verify tenant's residency status during supervisory reviews.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, according to officials, USDA has proposed revisions to its regulations that will incorporate the usage of Systematic Alien Verification and Entitlements (SAVE) program. The proposed rule is under interagency review with the Office of Management and Budget. Publication of the final rule is planned to occur in fiscal year 2022 according to USDA officials. We will continue to monitor USDA's progress in implementing our recommendation.

Recommendation: The Secretary of Agriculture should direct the Administrator of RHS to better utilize available data on demand for the FLH program--such as systematically reviewing local market analyses, further analyzing occupancy data on a statewide, regional, or national level, and retaining and analyzing application information--to help target available funding to areas of greatest need.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, according to officials, USDA has conducted an analysis of occupancy data and information retained in program applications, to determine how funding can be allocated to better meet market demand, and support community revitalization and affordable housing needs. Officials planned to use the results of this analysis to revise USDA's Farm Labor Housing Notice for Solicitation of Applications. The notice is currently undergoing an internal clearance process, which USDA anticipates completing by fiscal year 2022. We will continue to track the agency's progress on this recommendation.

Recommendation: To better understand the extent to which deployed DOD civilian employees have access to needed medical care, as appropriate, the Secretary of Defense should direct the Combatant Commander of U.S. Central Command to clarify the level of care that deployed DOD civilian employees can expect in theater, including their eligibility for routine care.

Agency: Department of Defense
Status: Open

Comments: DOD has not implemented this recommendation. In July 2019, DOD officials responsible for policy concerning deployed civilians clarified that DOD policy states deployed civilians are eligible for medical care at the same level and scope as military personnel. However, as of November 2019 they were unable to confirm whether policy in U.S. Central Command reflects this requirement. .

Recommendation: To improve IRS's guidance to its examiners auditing the real-estate tax deduction, the Commissioner of Internal Revenue should revise the guidance to indicate that evidence of deductibility should not rely on mortgage escrow statements, Forms 1098, and cancelled checks (which can be evidence of payment), and may require more than reliance on a real-estate tax bill.

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

Comments: No executive action taken. IRS had not addressed this action and had no plans to do so as of January 2020. IRS did not agree with GAO's May 2009 recommendation and the agency maintains that existing examination guidance provides examiners with sufficient information to properly examine this deduction. For tax years beginning after December 31, 2016, section 11042 of Public Law 115-97 caps the deduction for state and local taxes, including real estate taxes, at $10,000. In its 2009 review, GAO found that some examiners were not confirming that taxpayers were entitled to deduct real estate charges claimed, even in situations where their deductibility may have been in question. As a result, GAO maintains that examiners are continuing to rely on guidance that is inadequate to properly examine this deduction and that action should be taken to clarify the guidance.

Recommendation: To improve IRS's guidance to its examiners auditing the real-estate tax deduction, the Commissioner of Internal Revenue should revise the guidance to require examiners to ask taxpayers to substantiate the deductibility of the amounts claimed whenever they are examining the real-estate tax deduction and they have reason to believe that taxpayers have claimed nondeductible charges that are large, unusual, or questionable.

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

Comments: No executive action taken. IRS had not addressed this action and had no plans to do so as of January 2020. IRS did not agree with GAO's May 2009 recommendation and the agency maintains that existing examination guidance provides examiners with sufficient information to properly examine this deduction. For tax years beginning after December 31, 2016, section 11042 of Public Law 115-97 caps the deduction for state and local taxes, including real estate taxes, at $10,000. In its 2009 review, GAO found that some examiners were not confirming that taxpayers were entitled to deduct real estate charges claimed, even in situations where their deductibility may have been in question. As a result, GAO maintains that examiners are continuing to rely on guidance that is inadequate to properly examine this deduction and that action should be taken to clarify the guidance.

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 March 2020, Congress has expanded IRS's math error authority in certain circumstances, but not as broadly as GAO suggested in February 2010. Section 208 of division Q of the Consolidated Appropriations Act, 2016 (Public Law 114-113 enacted in December 2015) gave IRS the authority to use math error authority if (1) a taxpayer claimed the Earned Income Tax Credit, Child Tax Credit, or the American Opportunity Tax Credit (AOTC) during the period in which a taxpayer is not permitted to claim such credit as a consequence of either having made a prior fraudulent or reckless claim; or (2) a taxpayer omitted information required to be reported because the taxpayer made prior improper claims of the Child Tax Credit or the AOTC. While expanding math error authority is consistent with what GAO suggested in February 2010, GAO maintains that a broader authorization of math error authority with appropriate controls would enable IRS to correct obvious noncompliance, would be less intrusive and burdensome to taxpayers than audits, and would potentially help taxpayers who underclaim tax benefits to which they are entitled. If Congress decides to extend broader math error authority to IRS, controls may be needed to ensure that this authority is used properly such as requiring IRS to report on its use of math error authority. The Administration also requested that Congress expand IRS's math error authority as part of the Service's Congressional Budget Justification and Annual Performance Report and Plan for fiscal year 2019. Specifically, the Administration requested authority to correct a taxpayer's return in the following circumstances: 1) the information provided by the taxpayer does not match the information contained in government databases; 2) the taxpayer has exceeded the lifetime limit for claiming a deduction or credit; or 3) the taxpayer has failed to include with his or her return certain documentation that is required by statute. As of April 2019, the Congress had not provided IRS with such authority.