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Open Recommendations

Child Welfare: HHS Should Clarify Guidance on State Spending for Congregate Care
GAO-26-107592
Mar 03, 2026
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1 Open Recommendations
Agency Affected Recommendation Status
Department of Health and Human Services The Secretary of Health and Human Services should direct the Administration for Children and Families to clarify its guidance on the appropriate use of Title IV-E funds for youth in facilities designated as settings "providing high-quality residential care and supportive services to children and youth who have been found to be, or are at risk of becoming, sex trafficking victims." (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Adoption Tax Credit: IRS Needs a Comprehensive Educational Outreach Plan
GAO-25-107429
Aug 11, 2025
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1 Open Recommendations
Agency Affected Recommendation Status
Internal Revenue Service The Commissioner of Internal Revenue should direct the Acting Chief of Communications and Liaison and the Chief Taxpayer Experience Officer to develop a comprehensive educational outreach plan for the adoption tax credit that aligns with our Leading Practices for Consumer Education Planning, including identifying key stakeholders and developing clear, consistent messaging. (Recommendation 1)
Open
In September 2025, IRS officials stated that they are drafting a comprehensive educational outreach plan for the adoption tax credit. Officials expected to complete the plan by November 2025 in advance of the 2026 filing season. An educational outreach plan for the adoption tax credit would help IRS ensure that adoptive families know about the credit, their eligibility, and other requirements, as well as help taxpayers avoid costly mistakes in either failing to claim the credit or doing so inappropriately. Such a plan is particularly important in light of changes to the credit that were enacted in July 2025.

Whistleblowers: VA Should Assess Data and Monitor Settlement Agreements to Better Ensure Protections
GAO-25-106780
Jul 31, 2025
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4 Open Recommendations
Agency Affected Recommendation Status
Department of Veterans Affairs The Secretary of Veterans Affairs should ensure that OAWP consistently collects information on corrective actions VA takes on behalf of whistleblowers during the whistleblower retaliation investigation process. (Recommendation 1)
Open
VA agreed with this recommendation. OAWP plans to modify its tracking system and its standard operating procedures to collect and document any corrective actions taken for the whistleblower before a retaliation investigation is completed. Additionally, VA told us OAWP has drafted a revised directive that would require management to respond to non-disciplinary recommendations and other corrective actions, allowing OAWP to track all corrective actions. We await further progress on these efforts.
Office of Special Counsel The Special Counsel of the Office of Special Counsel should coordinate with the Secretary of Veterans Affairs to ensure that VA whistleblower retaliation settlement agreements that arise from cases filed with OSC are accurately tracked. (Recommendation 2)
Open
OSC disagreed with this recommendation. OSC stated that exchanging settlement information with VA would place an administrative burden on its small staff, without clear benefit to the agency's effectiveness in addressing whistleblower retaliation. OSC also noted that it is not a data collection or data management agency. We maintain, however, that OSC could enhance the value of the data it already collects for its regular operations by using existing coordination meetings with VA to incorporate information-sharing on settlement agreement tracking. OSC also expressed concern that adopting this recommendation could lead to broader requests for reciprocal data-sharing across agencies. However, our report noted that VA accounts for a significant proportion of OSC's caseload. Also, OSC identified 90 relevant VA whistleblower retaliation settlement agreements from FY19-FY23. However, this did not include 11 additional agreements from FY19-FY23 that OAWP identified as settled. This discrepancy underscores the potential benefit of the improved agency collaboration we recommend.
Department of Veterans Affairs The Secretary of Veterans Affairs should coordinate with the Special Counsel of the Office of Special Counsel to ensure that VA whistleblower retaliation settlement agreements that arise from cases filed with OSC are accurately tracked. (Recommendation 3)
Open
VA agreed with this recommendation. VA stated that OAWP has drafted a revised directive that would require management to respond to non-disciplinary recommendations and other corrective actions, allowing OAWP to track all corrective actions. We will consider closing this recommendation when this effort is complete.
Department of Veterans Affairs The Secretary of Veterans Affairs should ensure that OAWP is delegated the authority to monitor and then monitors whistleblower retaliation settlement agreement implementation, including tracking of relevant settlement agreement data. (Recommendation 4)
Open
VA agreed with this recommendation. The agency expressed willingness to work with OSC on negotiating a memorandum of agreement to enable secure data sharing about settlements and for its Office of General Counsel and OAWP to prepare appropriate documentation from the Secretary of VA for OAWP to monitor settlement implementation. VA also noted that OAWP has already updated its tracking to track all relevant settlement agreement data, including both agency and complainant obligations. We await further progress on these efforts.

Temporary Assistance for Needy Families: Additional Actions Needed to Strengthen Fraud Risk Management
GAO-25-107290
Jan 28, 2025
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6 Open Recommendations
Agency Affected Recommendation Status
Department of Health and Human Services The Secretary of HHS should finalize its key guidance documents on fraud risk management—the Fraud Risk Management Implementation Plan and the Fraud Risk Assessment Portal Methodology—and clearly establish a process for conducting fraud risk assessments for HHS programs, including TANF, at regular intervals and when there are changes to the program or its operating environment. (Recommendation 1)
Open
In July 2025, HHS told GAO that it anticipates finalizing the Fraud Risk Management Implementation Plan and Fraud Risk Assessment Portal User Guide at the end of fiscal year 2025. It also planned to disseminate these updated documents and provide training and technical assistance to HHS divisions and programs to ensure these documents are implemented effectively. HHS also told GAO that it planned to monitor and report on fraud risk management practices across HHS. In February 2026, HHS stated that it began reviewing and assessing its Fraud Risk Management program in September 2025. As part of this review and assessment, HHS said that it decided to implement a temporary pause on previously planned HHS Fraud Risk Management activities, including making updates to its Fraud Risk Management Implementation Plan, Fraud Risk Assessment Portal User Guide, Fraud Risk Assessment Portal, Fraud Risk Assessment Portal Risk Registry inventory, and a Fraud Risk Management guidance document. HHS said that it identified opportunities to enhance the approach of its Fraud Risk Management program to further align with GAO's Fraud Risk Management Framework, other requirements, and HHS-level needs. As part of this updated approach, HHS said that it will meet with leadership during the second quarter of fiscal year (FY) 2026 to discuss HHS proposed activities, initiatives, and resources. Once this approach is approved by HHS leadership, HHS said that it anticipates providing additional fraud risk management resources for HHS staff during FY 2026. GAO will continue to monitor HHS's work in this area. HHS following through with these efforts will help it clearly establish a standard process for conducting fraud risk assessments for all divisions and programs across HHS, including TANF, and at regular intervals and when there are changes to a division's program or operating environment.
Department of Health and Human Services The Secretary of HHS should develop and document standard operating procedures for conducting regular fraud risk assessments tailored to TANF. This should include the roles and responsibilities of HHS entities involved in the process. (Recommendation 2)
Open – Partially Addressed
In July 2025, HHS provided GAO with a copy of the Administration for Children and Families' (ACF) standards of operating procedures for conducting fraud risk assessments for ACF programs, which would include TANF. These procedures were drafted in April 2025 and include roles and responsibilities for ACF entities involved in the process. However, these procedures are still pre-decisional and do not include a process for the direct and regular communication with state and local agencies, and their respective Offices of Inspectors General (OIGs) or auditors, about fraud risks. Such an approach would include soliciting information from these entities as GAO recommended in recommendation 3. GAO will continue to monitor HHS's work in this area. Finalizing these procedures and including a standard process for the direct and regular communication with state and local agencies, and their respective OIGs or auditors, about fraud risks can allow ACF programs, including TANF, to more comprehensively understand the ways that fraud could occur.
Department of Health and Human Services The Secretary of HHS should develop a process for direct and regular communication with state and local agencies, and their respective OIGs or auditors, about TANF fraud risks that includes an approach for soliciting information from these entities and document this process in its standard operating procedures for conducting fraud risk assessments tailored to TANF. (Recommendation 3)
Open
In July 2025, HHS provided GAO with a copy of the Administration for Children and Families' (ACF) standards of operating procedures for conducting fraud risk assessments for ACF programs, which would include TANF. These procedures were drafted in April 2025 and include roles and responsibilities for ACF entities involved in the process. However, these procedures are still pre-decisional and do not include a process for the direct and regular communication with state and local agencies, and their respective Offices of Inspectors General (OIGs) or auditors, about fraud risks. Such an approach would include soliciting information from these entities as GAO recommended. GAO will continue to monitor HHS's work in this area. Finalizing these procedures and including a standard process for the direct and regular communication with state and local agencies, and their respective OIGs or auditors, about fraud risks can allow ACF programs, including TANF, to more comprehensively understand the ways that fraud could occur.
Department of Health and Human Services The Secretary of HHS should update the design of HHS's Fraud Risk Assessment Portal to have the functionality to allow users to assess the likelihood and impact of each fraud risk identified in a program, such as TANF; determine the related fraud risk tolerance; and include those results in the portal as part of their fraud risk assessments. (Recommendation 4)
Open
As of July 2025, HHS continues to not concur with this recommendation. In July 2025, HHS told GAO that it planned to update its fraud risk management guidance in fiscal year 2025 to include, among other things, an improved categorization of new fraud risks facing HHS programs and additional instructions on prioritizing fraud risks more effectively outside the Fraud Risk Assessment Portal. GAO continues to believe that this recommendation is valid because users should be able to perform the likelihood, impact, and fraud risk tolerance assessment of each fraud risk identified in a HHS program, such as TANF, within HHS's centralized Fraud Risk Assessment Portal. As GAO reported in January 2025, according to HHS, the portal was built to allow users to create, maintain, and complete fraud risk assessments within the portal with the purpose of aggregating information from various sources to provide a holistic approach to addressing fraud risks across HHS's programs. Doing so can help HHS ensure that it maintains documentation in a centralized location for managers to use to prioritize risks when faced with limited resources and time. In February 2026, HHS stated that it began reviewing and assessing its Fraud Risk Management program in September 2025. As part of this review and assessment, HHS said that it decided to implement a temporary pause on previously planned HHS Fraud Risk Management activities, including making updates to its Fraud Risk Management Implementation Plan, Fraud Risk Assessment Portal User Guide, Fraud Risk Assessment Portal, Fraud Risk Assessment Portal Risk Registry inventory, and a Fraud Risk Management guidance document. HHS said that it identified opportunities to enhance the approach of its Fraud Risk Management program to further align with GAO's Fraud Risk Management Framework, other requirements, and HHS-level needs. As part of this updated approach, HHS said that it will meet with leadership during the second quarter of fiscal year 2026 to discuss HHS proposed activities, initiatives, and resources. Once this approach is approved by HHS leadership, HHS said that it anticipates providing additional fraud risk management resources for HHS staff during this fiscal year. GAO will continue to monitor HHS's efforts to address this recommendation.
Department of Health and Human Services As part of finalizing HHS's key guidance documents on fraud risk management, the Secretary of HHS should require users to assess the likelihood and impact of each fraud risk identified in a program, such as TANF; determine the related fraud risk tolerance; and include those results in the Fraud Risk Assessment Portal as part of their fraud risk assessments. (Recommendation 5)
Open
As of July 2025, HHS continues to not fully concur with this recommendation. In July 2025, HHS told GAO that it was refining its fraud risk management guidance to include directions for HHS divisions and programs to assess the likelihood and impact of each fraud risk outside the Fraud Risk Assessment Portal. According to HHS, these revisions were expected to be completed by the end of fiscal year 2025, with dissemination and implementation planned for fiscal year 2026. GAO continues to believe that this recommendation is valid as users should be required and able to perform the likelihood, impact, and fraud risk tolerance assessment of each fraud risk identified in an HHS program, such as TANF, within HHS's centralized Fraud Risk Assessment Portal and include those results in the portal as part of the fraud risk assessments performed. As GAO reported in January 2025, according to HHS, the portal was built to allow users to create, maintain, and complete fraud risk assessments within the portal for the purpose of aggregating information from various sources to provide a holistic approach to addressing fraud risks across all HHS programs. Doing so can help HHS ensure that it maintains documentation in a centralized location for managers to use to prioritize fraud risks when faced with limited resources and time. In February 2026, HHS stated that it began reviewing and assessing its Fraud Risk Management program in September 2025. As part of this review and assessment, HHS said that it decided to implement a temporary pause on previously planned HHS Fraud Risk Management activities, including making updates to its Fraud Risk Management Implementation Plan, Fraud Risk Assessment Portal User Guide, Fraud Risk Assessment Portal, Fraud Risk Assessment Portal Risk Registry inventory, and a Fraud Risk Management guidance document. HHS said that it identified opportunities to enhance the approach of its Fraud Risk Management program to further align with GAO's Fraud Risk Management Framework, other requirements, and HHS-level needs. As part of this updated approach, HHS said that it will meet with leadership during the second quarter of fiscal year 2026 to discuss HHS proposed activities, initiatives, and resources. Once this approach is approved by HHS leadership, HHS said that it anticipates providing additional fraud risk management resources for HHS staff during this fiscal year. GAO will continue to monitor HHS's work in this area. GAO will continue to monitor HHS's efforts to fully address this recommendation.
Department of Health and Human Services The Secretary of HHS should update the design of HHS's Fraud Risk Assessment Portal to have the functionality to allow for the regular assessment of any additional fraud risks facing TANF, including those identified by GAO. (Recommendation 6)
Open
In July 2025, HHS told GAO that it planned to enhance its Fraud Risk Assessment Portal in fiscal year 2025 to incorporate additional fraud risks beyond those listed in the portal's Fraud Risk Register, contingent on funding and the portal's development capabilities. HHS also said it planned to update instructions for agency employees to notify HHS's program integrity personnel of any potential fraud schemes and new and emerging fraud risks for inclusion in the portal's Fraud Risk Registry inventory. However, it is unclear if the three fraud risks GAO identified will be included in the portal's updated registry. HHS updating the design of HHS's Fraud Risk Assessment Portal to allow for and require users to fully assess any additional identified fraud risks that TANF faces--including those shared by state and local stakeholders and others, such as the three GAO identified and reported on in January 2025--would result in more informed, efficient, and effective assessments of TANF fraud risks. This fraud risk assessment effort includes fully documenting an assessment of all fraud risks that may affect a program, including those that HHS is willing to accept as a low risk of fraud for TANF. In February 2026, HHS stated that it began reviewing and assessing its Fraud Risk Management program in September 2025. As part of this review and assessment, HHS said that it decided to implement a temporary pause on previously planned HHS Fraud Risk Management activities, including making updates to its Fraud Risk Management Implementation Plan, Fraud Risk Assessment Portal User Guide, Fraud Risk Assessment Portal, Fraud Risk Assessment Portal Risk Registry inventory, and a Fraud Risk Management guidance document. HHS said that it identified opportunities to enhance the approach of its Fraud Risk Management program to further align with GAO's Fraud Risk Management Framework, other requirements, and HHS-level needs. As part of this updated approach, HHS said that it will meet with leadership during the second quarter of fiscal year 2026 to discuss HHS proposed activities, initiatives, and resources. Once this approach is approved by HHS leadership, HHS said that it anticipates providing additional fraud risk management resources for HHS staff during this fiscal year. GAO will continue to monitor HHS's work in this area. GAO will continue to monitor HHS's efforts in this area.
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