Financial Management

Challenges in Meeting Requirements of the Improper Payments Information Act Gao ID: GAO-05-417 March 31, 2005

Fiscal year 2004 marked the first year that federal agencies governmentwide were required to report improper payment information under the Improper Payments Information Act of 2002 (IPIA). The increasing scope of reporting over the past several years has demonstrated that improper payments are a significant and widespread problem in federal agencies, and in the past a limited number of agencies reported in their Performance and Accountability Reports (PAR) annual payment accuracy rates and estimated improper payment amounts. Because of your continued interest in addressing the governmentwide improper payments issue, you asked GAO to report on (1) the extent to which agencies have performed the required assessments to identify programs and activities that are susceptible to significant improper payments and (2) the annual amount estimated for improper payments by the agencies.

The federal government made progress in identifying programs susceptible to the risk of improper payments in response to the new IPIA requirements. The fiscal year 2004 PARs for 29 of 35 federal agencies that are significant to the U.S. government's consolidated financial statements show that even with the enhanced emphasis on improper payment reporting fueled by the new legislation, 6 agencies reported that they did not perform risk assessments of all their programs. The magnitude of the governmentwide improper payment problem is still unknown, because agencies have not yet prepared estimates of improper payments for all of their programs. In the 29 agency PARs included in GAO's fiscal year 2004 review, 17 agencies reported over $45 billion of improper payments in 41 programs governmentwide. This represented almost a $10 billion, or 27 percent, increase in the amount of improper payments reported by agencies in fiscal year 2003. This increase was primarily attributable to changes in the method for estimating and reporting improper payment amounts in one major program. Looking forward, future estimates are likely to trend higher because the governmentwide estimate did not include 12 programs with outlays of $248.7 billion in fiscal year 2004 that were required to annually report improper payments under OMB Circular No. A-11 during the past 3 years. This included some of the largest risksusceptible federal programs, such as the Department of Health and Human Services' Medicaid Program, with outlays exceeding $175 billion annually, or the Department of Education's Title I Program, with outlays of over $10 billion annually.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

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GAO-05-417, Financial Management: Challenges in Meeting Requirements of the Improper Payments Information Act This is the accessible text file for GAO report number GAO-05-417 entitled 'Financial Management: Challenges in Meeting Requirements of the Improper Payments Information Act' which was released on May 4, 2005. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. 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Report to the Chairman, Subcommittee on Government Management, Finance, and Accountability, Committee on Government Reform, House of Representatives: March 2005: Financial Management: Challenges in Meeting Requirements of the Improper Payments Information Act: GAO-05-417: GAO Highlights: Highlights of GAO-05-417, a report to the Chairman, Subcommittee on Government Management, Finance, and Accountability, Committee on Government Reform, House of Representatives: Why GAO Did This Study: Fiscal year 2004 marked the first year that federal agencies governmentwide were required to report improper payment information under the Improper Payments Information Act of 2002 (IPIA). The increasing scope of reporting over the past several years has demonstrated that improper payments are a significant and widespread problem in federal agencies, and in the past a limited number of agencies reported in their Performance and Accountability Reports (PAR) annual payment accuracy rates and estimated improper payment amounts. Because of your continued interest in addressing the governmentwide improper payments issue, you asked GAO to report on (1) the extent to which agencies have performed the required assessments to identify programs and activities that are susceptible to significant improper payments and (2) the annual amount estimated for improper payments by the agencies. What GAO Found: The federal government made progress in identifying programs susceptible to the risk of improper payments in response to the new IPIA requirements. The fiscal year 2004 PARs for 29 of 35 federal agencies that are significant to the U.S. government's consolidated financial statements show that even with the enhanced emphasis on improper payment reporting fueled by the new legislation, 6 agencies reported that they did not perform risk assessments of all their programs. The magnitude of the governmentwide improper payment problem is still unknown, because agencies have not yet prepared estimates of improper payments for all of their programs. In the 29 agency PARs included in GAO's fiscal year 2004 review, 17 agencies reported over $45 billion of improper payments in 41 programs governmentwide. This represented almost a $10 billion, or 27 percent, increase in the amount of improper payments reported by agencies in fiscal year 2003. This increase was primarily attributable to changes in the method for estimating and reporting improper payment amounts in one major program. Looking forward, future estimates are likely to trend higher because the governmentwide estimate did not include 12 programs with outlays of $248.7 billion in fiscal year 2004 that were required to annually report improper payments under OMB Circular No. A-11 during the past 3 years. This included some of the largest risk-susceptible federal programs, such as the Department of Health and Human Services' Medicaid Program, with outlays exceeding $175 billion annually, or the Department of Education's Title I Program, with outlays of over $10 billion annually. Number of Agencies and Amounts of Improper Payments Reported (Fiscal Years 1999-2004): Fiscal year: 1999; Number of agencies reporting improper payments[A]: 8; Reported amounts of improper payments (in billions): $20.7. Fiscal year: 2000; Number of agencies reporting improper payments[A]: 8; Reported amounts of improper payments (in billions): $19.6. Fiscal year: 2001; Number of agencies reporting improper payments[A]: 8; Reported amounts of improper payments (in billions): $20.9. Fiscal year: 2002; Number of agencies reporting improper payments[A]: 7; Reported amounts of improper payments (in billions): $19.5. Fiscal year: 2003; Number of agencies reporting improper payments[A]: 13; Reported amounts of improper payments (in billions): $35.7. Fiscal year: 2004; Number of agencies reporting improper payments[A]: 17; Reported amounts of improper payments (in billions): $45.4. Source: GAO. [A] Other agencies acknowledged making improper payments in their PARs but did not disclose dollar amounts. [End of table] What GAO Recommends: GAO is making three recommendations to the Office of Management and Budget (OMB) to help ensure successful implementation of the IPIA requirements. OMB commented that its management emphasis and inspector general oversight offer sufficient incentives to ensure agencies meet IPIA requirements. www.gao.gov/cgi-bin/getrpt?GAO-05-417. To view the full product, including the scope and methodology, click on the link above. For more information, contact McCoy Williams at (202) 512-6906 or williamsm1@gao.gov. [End of section] Contents: Letter: Results in Brief: Background: Progress Made but Challenges Remain in Assessing Programs for Risk of Significant Improper Payments: Magnitude of Improper Payments Is Still Unknown: Conclusions: Recommendations for Executive Action: Agency Comments and Our Evaluation: Appendixes: Appendix I: Scope and Methodology: Appendix II: Agencies and Related Programs for Which OMB Circular No. A- 11 Required Erroneous Payment Information: Appendix III: Agencies and Related Programs Included in Our Review of Fiscal Year 2004 PARs: Appendix IV: Improper Payment Estimates Reported in Agency Fiscal Years 2003 and 2004 PARs: Appendix V: Comments from the Office of Management and Budget: Appendix VI: GAO Contacts and Staff Acknowledgments: Table: Table 1: Programs Required to Report under A-11 and Projected Year of Improper Payment Estimates: Abbreviations: CFO: Chief Financial Officer: IPIA: Improper Payments Information Act of 2002: MD&A: Management Discussion and Analysis: OMB: Office of Management and Budget: PAR: Performance and Accountability Report: PMA: President's Management Agenda: Letter March 31, 2005: The Honorable Todd R. Platts: Chairman: Subcommittee on Government Management, Finance, and Accountability: Committee on Government Reform: House of Representatives: Dear Mr. Chairman: Federal agencies expended a record $2.3 trillion through thousands of programs and activities to address the needs of the American people in fiscal year 2004. As the steward of taxpayer dollars, the federal government is accountable for how its agencies and grantees spent this money, including the safeguarding of federal funds from improper payments. Our work over the past several years has demonstrated that improper payments are a significant and widespread problem in the federal government, with only a limited number of agencies reporting in their Performance and Accountability Reports (PAR) the annual payment accuracy rates and estimated improper payment amounts. Fiscal year 2004 marked the first year that federal agencies governmentwide were required to report improper payment information under the Improper Payments Information Act of 2002 (IPIA).[Footnote 1] The IPIA raised improper payments to a new level of importance by requiring agency heads, based on guidance from the Office of Management and Budget (OMB),[Footnote 2] to identify programs and activities susceptible to improper payments, estimate the amount of their improper payments, and report on the amount of and their actions to reduce their improper payments. An improper payment is defined by the IPIA as an amount that should not have been paid or was paid for an incorrect amount. Specifically, improper payments include inadvertent errors, such as duplicate payments and calculation errors; payments for unsupported or inadequately supported claims; payments for services not rendered or rendered to ineligible beneficiaries; and payments resulting from fraud and abuse. The OMB implementation guidance requires that estimates, and if applicable, a corrective action report, be included in federal agencies' PARs beginning with fiscal year 2004. Prior to the IPIA, OMB Circular No. A-11, Preparation and Submission of Budget Estimates, Section 57, "Information on Erroneous Payments,"[Footnote 3] required 46 programs in 15 agencies to annually report improper payment information. Last year we testified on the federal agencies that reported under OMB Circular No. A-11.[Footnote 4] We noted that federal agency fiscal year 2003 PARs typically contained limited amounts of improper payment information. Historically, relatively few federal agencies and their components have publicly reported improper payment information. Estimates reported for fiscal year 2003 were about $36 billion annually for major federal benefit programs required to report under OMB Circular No. A-11. These programs managed payments in excess of $1.2 trillion annually. Importantly, this estimate did not account for payments made by all federal programs and activities, which totaled over $2.1 trillion in fiscal year 2003. Not only did the enactment of the IPIA expand the range of agencies, it also expanded the programs agencies are required to assess for improper payments to include all federal programs and payments. Because of your continued interest in addressing the governmentwide improper payments issue, you asked us to report on the progress being made by agencies in complying with certain requirements of the IPIA. This report summarizes (1) the extent to which agencies have performed the required assessments to identify programs and activities that are susceptible to significant improper payments and (2) the annual amount estimated for improper payments by the agencies. To respond to your request, we conducted a review of improper payment information reported by agencies in their fiscal year 2004 PARs. We further reviewed OMB guidance on implementation of the IPIA and its report on the results of agency-specific reports, significant findings, agency accomplishments, and remaining challenges. We did not assess the effectiveness of the agencies' efforts or independently validate the data that they or OMB reported. The results of our review are detailed in this report. We conducted our work from November 2004 through February 2005 in accordance with U.S. generally accepted government auditing standards. Appendix I contains further details on our scope and methodology. OMB provided written comments on a draft of this report that are reprinted in appendix V. Results in Brief: In response to the new IPIA requirements, agencies overall made progress in identifying programs susceptible to the risk of improper payments. At the same time, our reviews of the fiscal year 2004 PARs for 29 of 35 federal agencies[Footnote 5] that are significant to the U.S. government's consolidated financial statements show that even with the enhanced emphasis on improper payment reporting fueled by the new legislation, certain agencies did not perform risk assessments of all their programs. Specifically, 23 of the 29 agencies we reviewed reported that they had completed risk assessments for all programs and activities. The magnitude of the governmentwide improper payment problem is still unknown because, in addition to not assessing all programs, the agencies had not yet prepared estimates of significant improper payments for all of the programs that they determined were susceptible to the risk of improper payments. In the 29 agency PARs included in our fiscal year 2004 review, 17 agencies reported over $45 billion of improper payments in 41 programs. This represented almost a $10 billion, or 27 percent, increase in the dollar amount of improper payments reported by agencies in fiscal year 2003. However, we determined that this increase was primarily attributable to changes in the method for estimating and reporting improper payment amounts in one program. Further, the governmentwide estimate did not include 12 programs with total outlays of $248.7 billion in fiscal year 2004 that were required to annually report improper payments under OMB Circular No. A-11 during the past 3 years. This included some of the largest risk-susceptible federal programs, such as the Department of Health and Human Services' Medicaid Program, with outlays exceeding $175 billion annually, or the Department of Education's Title I Program, with outlays of over $10 billion annually. Eight of these 12 programs reported that they would be able to estimate and report on improper payments sometime within the next 4 years, but the remaining 4 were silent as to when they would report estimates in the future. We are making three recommendations to OMB to help ensure successful implementation of IPIA requirements. In its comments, OMB emphasized that in fiscal year 2004, federal agencies established a strong foundation for measuring improper payments, identifying and implementing the necessary corrective actions, and tracking success over time. OMB also pointed out that there are already procedures in place for the 15 federal agencies under the new President's Management Agenda (PMA) initiative to meet the objectives of our recommendations and sufficient incentives and disincentives for ensuring that agencies meet the necessary IPIA requirements. However, our recommendations focus on all federal agencies meeting the IPIA requirements and are directed at any agency that does not do so or agencies that may benefit from incentives such as gain sharing to fund efforts to reduce improper payments. Background: The PMA issued in 2001 targeted improper payments as an area with opportunities for improvement. The PMA included five governmentwide initiatives--one of which is improved financial management, which expressly addresses improper payments as a priority. This initiative called for the administration to establish a baseline on the extent of erroneous payments. Under it, agencies were to include in their 2003 budget submissions to OMB information on improper payment rates, including actual and target rates where available, for benefit and assistance programs over $2 billion. The PMA also noted that using this information, OMB will work with agencies to establish goals to reduce improper payments identified in their programs. In July 2001, as part of its efforts to advance the PMA initiative, OMB revised Circular No. A-11 to require 16 federal agencies (15 of the then 24 Chief Financial Officer's (CFO) Act agencies and the Railroad Retirement Board) to submit improper[Footnote 6] payment data, assessments, and action plans for about 50 programs to OMB with their initial budget submissions. Specifically, the circular required that agencies submit information including estimated improper payment rates, target rates for future reductions in these payments, the types and causes of these payments, and variances from targets or goals established. In addition, agencies were to provide a description and assessment of the current methods for measuring the rate of improper payments and the quality of data resulting from these methods. Agencies were to first include this improper payment information in their initial fiscal year 2003 budget submissions. A June 2002 revision to the circular removed the Agency for International Development from the list and reduced the number of programs for which improper payment information was required to 46. (App. II lists the agencies and programs.) In November 2002, the Congress passed the IPIA. The law requires agency heads to annually review all programs and activities that they administer and identify those that may be susceptible to significant improper payments.[Footnote 7] Once agencies identify their susceptible programs, the act requires them to estimate and report on the annual amount of improper payments in those programs and activities. For programs for which estimated improper payments exceed $10 million, agencies are to report annually to the Congress on the actions they are taking to reduce those payments. The report is also to include a discussion of the causes of the improper payments identified, actions taken to correct those causes, and the results of the actions taken to address those causes. The act further requires OMB to prescribe guidance for federal agencies to use in implementing the act. OMB issued this guidance in Memorandum M-03-13 in May 2003. It requires use of a systematic method to annually review and identify those programs and activities that are susceptible to significant improper payments. OMB guidance defines significant improper payments as annual improper payments in any particular program exceeding both 2.5 percent of program payments and $10 million. The OMB guidance then requires agencies to estimate the annual amount of improper payments using statistically valid techniques for each susceptible program or activity. For those agency programs determined to be susceptible to significant improper payments and with estimated annual improper payments greater than $10 million, the IPIA and related OMB guidance require each agency to report the results of its improper payment efforts in the Management Discussion and Analysis (MD&A) section of its PAR for fiscal years ending on or after September 30, 2004. The IPIA requires the following information in their reports: * a discussion of the causes of the improper payments identified, actions taken to correct those causes, and results of the actions taken to address those causes; * a statement of whether the agency has the information systems and other infrastructure it needs in order to reduce improper payments to the agency's targeted levels; * if the agency does not have such systems and infrastructure, a description of the resources the agency has requested in its most recent budget submission to obtain the necessary information systems and infrastructure; and: * a description of the steps the agency has taken and plans to take to ensure that agency managers (including the agency head) are held accountable for reducing improper payments. OMB's guidance in M-03-13 requires that three additional things be included in the report: * a discussion of the amount of actual erroneous payments that the agency expects to recover and how it will go about recovering them; * a description of any statutory or regulatory barriers that may limit the agency's corrective actions in reducing erroneous payments; and: * provided the agency has estimated a baseline erroneous payment rate for the program, a target for the program's future erroneous payment rate that is lower than the agency's most recent estimated error rate. On July 22, 2004, OMB, working with the CFO Council's Improper Payments Committee, issued a standardized reporting format, or framework, for reporting IPIA information. This framework was included as Attachments 2 and 3 to OMB Memorandum M-04-20, "Fiscal Year 2004 Performance and Accountability (PAR) and Reporting Requirements for the Financial Report of the United States Government." To satisfy the reporting requirements of the IPIA for fiscal year 2004, the framework instructed agencies to provide a brief summary of both what they have accomplished and what they plan to accomplish in the MD&A portion of the fiscal year 2004 PAR. All other required reporting details are to be included in an appendix to the PAR. The framework for the information reported in the appendix incorporates the requirements set forth in the law and further illustrates the reporting format required in OMB's implementation guidance. Under accelerated financial reporting requirements of the PMA, agency fiscal year 2004 PARs were due November 15, 2004. Accordingly, the first set of reports representing the results of agencies' assessing improper payments for all federal programs in accordance with the IPIA and OMB guidance were due in November 2004. In August 2004, OMB established Eliminate Improper Payments as a new program-specific initiative.[Footnote 8] With this new program initiative, agencies are to measure their improper payments annually, develop improvement targets and corrective actions, and track the results annually to ensure the corrective actions are effective. This initiative is also to have its own scorecard requirements and rating beginning with fiscal year 2005. With the establishment of this new program-specific initiative, agency efforts to address improper payment issues will no longer be tracked under the governmentwide initiative, Improved Financial Performance. In our December 2004 report on the U.S. government's consolidated financial statements for the fiscal years ended September 30, 2004 and 2003, which includes our associated opinion on internal control, we reported that while most agencies acknowledged the IPIA reporting requirements in their PARs, they did not always indicate whether they had completed agencywide assessments, and they did not estimate improper payments for all of their susceptible[Footnote 9] programs. Progress Made but Challenges Remain in Assessing Programs for Risk of Significant Improper Payments: In response to the new requirements of the IPIA, agencies overall made progress in identifying programs susceptible to the risk of improper payments. At the same time, our reviews of the fiscal year 2004 PARs for 29 of 35 federal agencies[Footnote 10] that are significant to the U.S. government's consolidated financial statements suggest that even with the enhanced emphasis on improper payment reporting fueled by the new legislation, certain agencies have not yet performed risk assessments of all their programs. Appendix III lists the agencies included in this review. In its guidance on implementing the IPIA, OMB required agencies to institute a systematic method of inventorying all programs and activities and identifying those the agency believes are susceptible to the risk of significant error. OMB further instructed agencies to describe, in their PARs, the risk assessments performed. We determined that 23 of the 29 agencies reviewed reported that they had completed risk assessments for all programs and activities. Of the 15 agencies with prior reporting requirements under OMB Circular No. A- 11, 12 reported that they had performed comprehensive inventories and assessed the risk of improper payments for all their programs and activities. Three of the 15 agencies stated that their risk assessments were not complete for all programs and activities. Of those 14 agencies without prior reporting requirements, 11 agencies reported that they had completed risk assessments for all programs and activities, whereas 3 agencies reported that they had not. Recognizing weaknesses in agency risk assessments, three agency auditors cited noncompliance with the IPIA in their annual auditor's reports included in the agency PARs. For example, two agency auditors each reported that their agency's risk assessment did not consider all payment types or programs. Another auditor reported the agency did not institute a systematic method of reviewing all programs and identifying those it believed were susceptible to significant erroneous payments. Magnitude of Improper Payments Is Still Unknown: Once agencies have identified programs that may be susceptible to significant improper payments, developing statistically valid estimates of the amounts of improper payments for their programs and activities has been a further challenge. Appendix IV lists the 29 agencies and 70 programs for which we reviewed fiscal year 2004 PARs for improper payment reporting. In the 29 agency PARs included in our review, 17 agencies reported over $45 billion of improper payments in 41 programs. This represented almost a $10 billion, or 27 percent, increase in the dollar amount of improper payments reported by agencies in fiscal year 2003. However, we determined that this increase was primarily attributable to changes in the method for estimating and reporting improper payment amounts in the Department of Health and Human Services' Medicare Program. The 24 agency programs with no prior reporting requirements reported improper payment estimates that did not significantly increase the governmentwide total. As discussed earlier, OMB Circular No. A-11 has required certain agencies to report selected improper payment information on 46 programs to OMB beginning 3 years ago with their fiscal year 2003 budget submissions. We found that for 34 of the programs, agencies reported estimates in their fiscal year 2004 PARs or stated that improper payment amounts were insignificant. As shown in table 1, the governmentwide estimate did not include the remaining 12 programs with total outlays of $248.7 billion in 2004. This included some of the largest risk-susceptible federal programs, such as the Department of Health and Human Services' Medicaid Program, with outlays exceeding $175 billion annually, or the Department of Education's Title I Program, with outlays of over $10 billion annually. Table 1: Programs Required to Report under A-11 and Projected Year of Improper Payment Estimates: Program: Department of Agriculture-Agriculture Marketing and Assistance; Fiscal year 2004 outlays (in billions): $8.8; Target fiscal year for estimate: 2005. Program: Department of Health and Human Services-Foster Care-Title IV-E; Fiscal year 2004 outlays (in billions): $4.7; Target fiscal year for estimate: 2005. Program: Department of Health and Human Services-State Children's Insurance Program; Fiscal year 2004 outlays (in billions): $4.6; Target fiscal year for estimate: 2005. Program: Department of Health and Human Services-Child Care and Development Fund; Fiscal year 2004 outlays (in billions): $4.8; Target fiscal year for estimate: 2005. Program: Small Business Administration-7(a) Business Loan Program; Fiscal year 2004 outlays (in billions): $.7; Target fiscal year for estimate: 2005. Program: Department of Health and Human Services-Medicaid; Fiscal year 2004 outlays (in billions): $175.3; Target fiscal year for estimate: 2006. Program: Department of Agriculture-School Programs; Fiscal year 2004 outlays (in billions): $8.4; Target fiscal year for estimate: 2007. Program: Department of Agriculture-Women, Infants, and Children Program; Fiscal year 2004 outlays (in billions): $4.8; Target fiscal year for estimate: 2008. Program: Department of Labor-Workforce Investment Act; Fiscal year 2004 outlays (in billions): $3.1; Target fiscal year for estimate: Did not report. Program: Department of Education-Title I; Fiscal year 2004 outlays (in billions): $10.3; Target fiscal year for estimate: Did not report. Program: Department of Health and Human Services-Temporary Assistance for Needy Families; Fiscal year 2004 outlays (in billions): $17.7; Target fiscal year for estimate: Did not report. Program: Department of Housing and Urban Development-Community Development Block Grant; Fiscal year 2004 outlays (in billions): $5.5; Target fiscal year for estimate: Did not report. Total; Fiscal year 2004 outlays (in billions): $248.7; Target fiscal year for estimate: 2005: 5; Target fiscal year for estimate: 2006: 1; Target fiscal year for estimate: 2007: 1; Target fiscal year for estimate: 2008: 1; Did not report: 4. Sources: Cited agencies' fiscal year 2004 PARs and OMB. [End of table] The table further shows that of these 12 programs, 8 reported that they would be able to estimate and report on improper payments sometime within the next 4 years, but could not do so now. The other 4 programs in 4 agencies did not estimate improper payment amounts for their programs and were silent as to whether they would report estimates in future reports. As a result, improper payments for several large risk- susceptible programs will not become transparent for several or an undetermined number of years, although these agencies were required to report such information since their fiscal year 2003 budget submissions. Moreover, by only looking at those agencies significant to the U.S. consolidated financial statements, this estimate does not include all of the agencies subject to the IPIA. OMB reported that in certain risk-susceptible programs, agencies were unable to determine the rate or amount of improper payments due to measurement challenges as well as time and resource constraints, which OMB expects to be resolved in the future. Although OMB reported that the $45 billion in improper payments will be used as a baseline on which short-and long-term program improvements and strategies will be based, it recognizes that fiscal year 2005 reductions in improper payments will be affected by outlay changes as well as the identification of new improper payments as additional programs are measured and methodologies for currently measured programs are enhanced. Conclusions: Measuring improper payments and designing and implementing actions to reduce or eliminate them are not simple tasks. The ultimate success of the governmentwide effort to reduce improper payments depends, in part, on each federal agency's continuing diligence and commitment to comply fully with the requirements of the act and the related OMB guidance. The level of importance each agency, the administration, and the Congress place on the efforts to implement the act will determine its overall effectiveness and the level to which agencies reduce improper payments and ensure that federal funds are used efficiently and for their intended purposes. Without such efforts, the likelihood of designing and implementing actions governmentwide to reduce or eliminate improper payments is doubtful. Fulfilling the requirements of the IPIA will require sustained attention to implementation and oversight to monitor whether desired results are being achieved. Recommendations for Executive Action: We are making three recommendations to help ensure the successful implementation of the Improper Payments Information Act of 2002 and its goal of enhancing the accuracy and integrity of federal payments. Specifically, we recommend that the Director of OMB: * Require those agencies that did not address the IPIA requirements or did not perform risk assessments of all of their programs and activities to establish time frames and identify resources needed to perform risk assessments and satisfy reporting requirements. * Develop a plan to address the resource needs of those agencies that did not perform risk assessments or satisfy reporting requirements. * Consider as part of the budget process, for any agency that OMB deems to have not taken the IPIA requirements seriously or that has lagged behind, the feasibility of disincentives for poor performance, such as reductions in funds for the program involved or adding incentives such as gain sharing for making substantive progress. Agency Comments and Our Evaluation: In its written comments on a draft of this report, which are enclosed in appendix V, OMB emphasized that in fiscal year 2004, federal agencies established a strong foundation for measuring improper payments, identifying and implementing the necessary corrective actions, and tracking success over time. OMB's response further discussed key findings included in its report, Improving the Accuracy and Integrity of Federal Payments, which was issued on January 25, 2005. With regard to our first recommendation that agencies establish time frames and identify resources needed to perform risk assessments and satisfy reporting requirements, OMB stated that pursuant to the PMA initiative called Eliminate Improper Payments, federal agencies are already required to submit relevant time frames and account for the resources necessary to complete planned actions. Further, OMB stated that the remaining risk assessments to be completed correlate to programs with relatively small outlays. While we view the PMA initiative as a positive action, it applies to 15 agencies, 3 of which we found had not yet assessed all their programs. Three other agencies- -the Farm Credit System Insurance Corporation, the National Credit Union Administration, and the Pension Benefit Guaranty Corporation-- which are not included in the PMA initiative and therefore are not required to establish time frames and account for needed resources, have outlays that are significant to the U.S. government's consolidated financial statements and were silent with respect to IPIA requirements in their fiscal year 2004 PARs. In addition to these three agencies, the PMA initiative would also not cover those agencies that while not significant to the U.S. government's consolidated financial statements, are subject to the IPIA. Our recommendation is directed to the broader range of agencies. Regarding our second recommendation that OMB develop a plan to address resource needs of agencies that did not perform risk assessments or satisfy reporting requirements, OMB stated that agency plans for addressing IPIA reporting requirements are closely considered in identifying agency resource needs and preparing the President's Budget. While we agree with OMB on that point, as discussed in our response to OMB's comments on the first recommendation, certain agencies are not required to submit plans that include time frames and resource needs to OMB. As a result, resource needs may not be addressed in the budget process. With respect to our third recommendation that it consider using incentives and disincentives, as applicable, for quick and timely action for meeting the IPIA requirements, OMB offered the view that the requirements of the PMA and inspector general reviews of agency IPIA activities provide sufficient incentive for ensuring that agencies meet the necessary requirements. We agree that these requirements will help ensure that agencies take the IPIA seriously. Our recommendation is directed at any agency that does not do so or agencies that may benefit from incentives such as gain sharing to fund efforts to reduce improper payments. Again, as discussed above, while the major 15 agencies are covered by the PMA, 3 of these had not yet assessed all their programs and a number of agencies not covered under the PMA initiative, but significant to the U.S. government's consolidated financial statements, were silent with respect to the IPIA requirements. OMB's written comments and our evaluation of one comment not addressed above are presented in appendix V. As agreed with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days from its date. At that time, we will send copies of the report to interested congressional committees. We will also be sending copies to the Director of the Office of Management and Budget and the heads of the agencies included in our scope of review. We will make copies available to others upon request. In addition, the report will be available at no charge on the GAO Web site at [Hyperlink, http://www.gao.gov]. Should you or your staff have any questions on matters discussed in this report, please contact me at (202) 512-6906 or [Hyperlink, williamsm1@gao.gov]. Additional contacts and major contributors to this report are provided in appendix VI. Sincerely yours, Signed by: McCoy Williams, Director, Financial Management and Assurance: [End of section] Appendixes: Appendix I: Scope and Methodology: This report is based on our review of agency fiscal year 2004 Performance and Accountability Reports (PAR). We reviewed the fiscal year 2004 PARs of 29 of 35 agencies[Footnote 11] that are significant to the U.S. government's consolidated financial statements to obtain information on the status of their implementation of the Improper Payments Information Act of 2002 (IPIA) and the related Office of Management and Budget (OMB) implementation guidance. We paid particular attention to the 15 agencies with prior improper payment reporting requirements for 46 of their programs under OMB Circular No. A-11, Section 57. A list of the agencies with prior reporting requirements is presented in appendix II. In addition, we reviewed relevant agency documents, including strategic plans, agency performance plans and reports, agency audit reports, and reports from agency program partners.[Footnote 12] We completed reviews of fiscal year 2004 PARs for 29 agencies identifying 70 key programs. Appendix III lists the agencies and programs included in this review. To supplement our review and analysis, we contacted agencies to clarify responses, requested additional information, and updated the initial responses. We did not determine the validity of representations made or the documentation provided. We performed our work in Washington, D.C., from November 2004 through February 2005 in accordance with U.S. generally accepted government auditing standards. [End of section] Appendix II: Agencies and Related Programs for Which OMB Circular No. A-11 Required Erroneous Payment Information: Agency: 1. Department of Agriculture; Program or Activity: 1. Food Stamps. Agency: 1. Department of Agriculture; Program or Activity: 2. Commodity Loan Program. Agency: 1. Department of Agriculture; Program or Activity: 3. National School Lunch and Breakfast . Agency: 1. Department of Agriculture; Program or Activity: 4. Women, Infants, and Children. Agency: 2. Department of Defense; Program or Activity: 5. Military Retirement. Agency: 2. Department of Defense; Program or Activity: 6. Military Health Benefits. Agency: 3. Department of Education; Program or Activity: 7. Student Financial Assistance. Agency: 3. Department of Education; Program or Activity: 8. Title I. Agency: 4. Department of Health and Human Services; Program or Activity: 9. Head Start. Agency: 4. Department of Health and Human Services; Program or Activity: 10. Medicare. Agency: 4. Department of Health and Human Services; Program or Activity: 11. Medicaid. Agency: 4. Department of Health and Human Services; Program or Activity: 12. Temporary Assistance for Needy Families. Agency: 4. Department of Health and Human Services; Program or Activity: 13. Foster Care-Title IV-E. Agency: 4. Department of Health and Human Services; Program or Activity: 14. State Children's Insurance Program. Agency: 4. Department of Health and Human Services; Program or Activity: 15. Child Care and Development Fund. Agency: 5. Department of Housing and Urban Development; Program or Activity: 16. Low Income Public Housing. Agency: 5. Department of Housing and Urban Development; Program or Activity: 17. Section 8 Tenant Based. Agency: 5. Department of Housing and Urban Development; Program or Activity: 18. Section 8 Project Based. Agency: 5. Department of Housing and Urban Development; Program or Activity: 19. Community Development Block Grants . Agency: 6. Department of Labor; Program or Activity: 20. Unemployment Insurance. Agency: 6. Department of Labor; Program or Activity: 21. Federal Employee Compensation Act. Agency: 6. Department of Labor; Program or Activity: 22. Workforce Investment Act. Agency: 7. Department of the Treasury; Program or Activity: 23. Earned Income Tax Credit. Agency: 8. Department of Transportation; Program or Activity: 24. Airport Improvement Program. Agency: 8. Department of Transportation; Program or Activity: 25. Highway Planning and Construction. Agency: 8. Department of Transportation; Program or Activity: 26. Federal Transit-Capital Investment Grants. Agency: 8. Department of Transportation; Program or Activity: 27. Federal Transit-Formula Grants. Agency: 9. Department of Veterans Affairs; Program or Activity: 28. Compensation. Agency: 9. Department of Veterans Affairs; Program or Activity: 29. Dependency and Indemnity Compensation. Agency: 9. Department of Veterans Affairs; Program or Activity: 30. Pension. Agency: 9. Department of Veterans Affairs; Program or Activity: 31. Insurance Programs. Agency: 10. Environmental Protection Agency; Program or Activity: 32. Clean Water State Revolving Funds. Agency: 10. Environmental Protection Agency; Program or Activity: 33. Drinking Water State Revolving Funds. Agency: 11. National Science Foundation; Program or Activity: 34. Research and Education Grants and Cooperative Agreements. Agency: 12. Office of Personnel Management; Program or Activity: 35. Retirement Program (Civil Service Retirement Systems and Federal Employees Retirement System). Agency: 12. Office of Personnel Management; Program or Activity: 36. Federal Employees Health Benefits Program. Agency: 12. Office of Personnel Management; Program or Activity: 37. Federal Employees' Group Life Insurance. Agency: 13. Railroad Retirement Board; Program or Activity: 38. Retirement and Survivors Benefits. Agency: 13. Railroad Retirement Board; Program or Activity: 39. Railroad Unemployment Insurance Benefits. Agency: 14. Small Business Administration; Program or Activity: 40. (7a) Business Loan Program. Agency: 14. Small Business Administration; Program or Activity: 41. 504 Certified Development Companies. Agency: 14. Small Business Administration; Program or Activity: 42. Disaster Assistance. Agency: 14. Small Business Administration; Program or Activity: 43. Small Business Investment Companies. Agency: 15. Social Security Administration; Program or Activity: 44. Old Age and Survivors' Insurance. Agency: 15. Social Security Administration; Program or Activity: 45. Disability Insurance. Agency: 15. Social Security Administration; Program or Activity: 46. Supplemental Security Income Program. Source: GAO. [End of table] [End of section] Appendix III: Agencies and Related Programs Included in Our Review of Fiscal Year 2004 PARs: Agency: 1. Agency for International Development; Program or activity: 1. All programs and activities. Agency: 2. Department of Agriculture; Program or activity: 2. Marketing Assistance Loan Program (previously Commodity Loan Program). Agency: 2. Department of Agriculture; Program or activity: 3. Food Stamp Program. Agency: 2. Department of Agriculture; Program or activity: 4. School Programs. Agency: 2. Department of Agriculture; Program or activity: 5. Women, Infants, and Children. Agency: 2. Department of Agriculture; Program or activity: 6. Child and Adult Care Food Program. Agency: 2. Department of Agriculture; Program or activity: 7. Wildland Fire Suppression Management. Agency: 2. Department of Agriculture; Program or activity: 8. Rental Assistance Program. Agency: 2. Department of Agriculture; Program or activity: 9. Federal Crop Insurance Corporation. Agency: 2. Department of Agriculture; Program or activity: 10. Farm Security and Rural Investment. Agency: 3. Department of Commerce; Program or activity: 11. All programs and activities. Agency: 4. Department of Defense; Program or activity: 12. Military Retirement Fund. Agency: 4. Department of Defense; Program or activity: 13. Military Health Benefits. Agency: 5. Department of Education; Program or activity: 14. Student Financial Assistance. Agency: 5. Department of Education; Program or activity: 15. Title I. Agency: 6. Department of Energy; Program or activity: 16. Payroll and Vendor Payments. Agency: 7. Environmental Protection Agency; Program or activity: 17. Clean Water State Revolving Funds. Agency: 7. Environmental Protection Agency; Program or activity: 18. Drinking Water State Revolving Fund. Agency: 8. Farm Credit System Insurance Corporation; Program or activity: 19. All programs and activities. Agency: 9. Federal Communications Commission; Program or activity: 20. Universal Service Fund‘s Schools and Libraries. Agency: 9. Federal Communications Commission; Program or activity: 21. High Cost Support Programs. Agency: 10. General Services Administration; Program or activity: 22. All programs and activities. Agency: 11. Department of Health and Human Services; Program or activity: 23. Medicaid. Agency: 11. Department of Health and Human Services; Program or activity: 24. Medicare. Agency: 11. Department of Health and Human Services; Program or activity: 25. Head Start. Agency: 11. Department of Health and Human Services; Program or activity: 26. Temporary Assistance for Needy Families. Agency: 11. Department of Health and Human Services; Program or activity: 27. Foster Care”Title IV-E. Agency: 11. Department of Health and Human Services; Program or activity: 28. State Children‘s Insurance Program. Agency: 11. Department of Health and Human Services; Program or activity: 29. Child Care and Development Fund. Agency: 12. Department of Homeland Security; Program or activity: 30. All programs and activities. Agency: 13. Department of Housing and Urban Development; Program or activity: 31. Low Income Public Housing. Agency: 13. Department of Housing and Urban Development; Program or activity: 32. Section 8 Tenant Based. Agency: 13. Department of Housing and Urban Development; Program or activity: 33. Section 8 Project Based. Agency: 13. Department of Housing and Urban Development; Program or activity: 34. Community Development Block Grant (Entitlement Grants, States/Small Cities). Agency: 13. Department of Housing and Urban Development; Program or activity: 35. FHA Single Family Acquired Asset Management System. Agency: 14. Department of the Interior; Program or activity: 36. All programs and activities. Agency: 15. Department of Justice; Program or activity: 37. All programs and activities. Agency: 16. Department of Labor; Program or activity: 38. Unemployment Insurance. Agency: 16. Department of Labor; Program or activity: 39. Federal Employees‘ Compensation Act. Agency: 16. Department of Labor; Program or activity: 40. Workforce Investment Act. Agency: 17. National Aeronautics and Space Administration; Program or activity: 41. All programs and activities. Agency: 18. National Credit Union Administration; Program or activity: 42. All programs and activities. Agency: 19. National Science Foundation; Program or activity: 43. Research and Education Grants and Cooperative Agreements. Agency: 20. Nuclear Regulatory Commission; Program or activity: 44. All programs and activities. Agency: 21. Office of Personnel Management; Program or activity: 45. Retirement Program (Civil Service Retirement System and Federal Employees Retirement System). Agency: 21. Office of Personnel Management; Program or activity: 46. Federal Employees Health Benefits Program. Agency: 21. Office of Personnel Management; Program or activity: 47. Federal Employees Group Life Insurance. Agency: 22. Pension Benefit Guaranty Corporation; Program or activity: 48. All programs and activities. Agency: 23. Railroad Retirement Board; Program or activity: 49. Retirement and Survivors Benefits. Agency: 23. Railroad Retirement Board; Program or activity: 50. Railroad Unemployment Insurance Benefits. Agency: 24. Small Business Administration; Program or activity: 51. 7(a) Business Loan Program. Agency: 24. Small Business Administration; Program or activity: 52. 504 Certified Development Companies. Agency: 24. Small Business Administration; Program or activity: 53. Disaster Assistance. Agency: 24. Small Business Administration; Program or activity: 54. Small Business Investment Companies. Agency: 25. Social Security Administration; Program or activity: 55. Old Age and Survivors‘ Insurance. Agency: 25. Social Security Administration; Program or activity: 56. Disability Insurance. Agency: 25. Social Security Administration; Program or activity: 57. Supplemental Security Income Program. Agency: 26. Department of State; Program or activity: 58. International Narcotic and Law Enforcement Affairs-Narcotics Program. Agency: 26. Department of State; Program or activity: 59. International Information Program-U.S. Speaker and Specialist Program. Agency: 26. Department of State; Program or activity: 60. Vendor Payments. Agency: 27. Department of Transportation; Program or activity: 61. Airport Improvement Program. Agency: 27. Department of Transportation; Program or activity: 62. Highway Planning and Construction. Agency: 27. Department of Transportation; Program or activity: 63. Federal Transit”Capital Investment Grants. Agency: 27. Department of Transportation; Program or activity: 64. Federal Transit”Formula Grants. Agency: 28. Department of the Treasury; Program or activity: 65. Earned Income Tax Credit. Agency: 29. Department of Veterans Affairs; Program or activity: 66. Compensation. Agency: 29. Department of Veterans Affairs; Program or activity: 67. Dependency and Indemnity Compensation. Agency: 29. Department of Veterans Affairs; Program or activity: 68. Education Programs. Agency: 29. Department of Veterans Affairs; Program or activity: 69. Pension. Agency: 29. Department of Veterans Affairs; Program or activity: 70. Insurance Programs. Source: GAO. [End of table] [End of section] Appendix IV: Improper Payment Estimates Reported in Agency Fiscal Years 2003 and 2004 PARs: Agency: 1. Agency for International Development; Program or activity: 1. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 2. Department of Agriculture; Program or activity: 2. Marketing Assistance Loan Program (previously Commodity Loan Program); Improper payments reported: 2003: (in millions): $153.0; Improper payments reported: 2004: (in millions): $0.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 2. Department of Agriculture; Program or activity: 3. Food Stamp Program; Improper payments reported: 2003: (in millions): $1,419.0[A]; Improper payments reported: 2004: (in millions): $1,613.4; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 2. Department of Agriculture; Program or activity: 4. School Programs; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 2. Department of Agriculture; Program or activity: 5. Women, Infants, and Children; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 2. Department of Agriculture; Program or activity: 6. Child and Adult Care Food Program; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 2. Department of Agriculture; Program or activity: 7. Wildland Fire Suppression Management; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 2. Department of Agriculture; Program or activity: 8. Rental Assistance Program; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0[B]; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 2. Department of Agriculture; Program or activity: 9. Federal Crop Insurance Corporation; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $125.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 2. Department of Agriculture; Program or activity: 10. Farm Security and Rural Investment; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0[B]; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 3. Department of Commerce; Program or activity: 11. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 4. Department of Defense; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 4. Department of Defense; Program or activity: 12. Military Retirement Fund; Improper payments reported: 2003: (in millions): $33.1; Improper payments reported: 2004: (in millions): $34.1; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 4. Department of Defense; Program or activity: 13. Military Health Benefits; Improper payments reported: 2003: (in millions): $33.2[A]; Improper payments reported: 2004: (in millions): $100.1; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 5. Department of Education; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 5. Department of Education; Program or activity: 14. Student Financial Assistance; Improper payments reported: 2003: (in millions): $482.5; Improper payments reported: 2004: (in millions): $797.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 5. Department of Education; Program or activity: 15. Title I; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0[B]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 6. Department of Energy; Program or activity: 16. All programs and activities; Improper payments reported: 2003: (in millions): $13.7[A]; Improper payments reported: 2004: (in millions): $20.3; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 7. Environmental Protection Agency; Program or activity: 17. Clean Water State Revolving Funds; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $10.3; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 7. Environmental Protection Agency; Program or activity: 18. Drinking Water State Revolving Funds; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0[C]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 8. Farm Credit System Insurance Corporation[D]; Program or activity: 19. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 9. Federal Communications Commission; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 9. Federal Communications Commission; Program or activity: 20. Universal Service Fund's Schools and Libraries; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 9. Federal Communications Commission; Program or activity: 21. High Cost Support Programs; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 10. General Services Administration; Program or activity: 22. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 11. Department of Health and Human Services; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 11. Department of Health and Human Services; Program or activity: 23. Medicaid; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 11. Department of Health and Human Services; Program or activity: 24. Medicare; Improper payments reported: 2003: (in millions): $11,600.0; Improper payments reported: 2004: (in millions): $21,700.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 11. Department of Health and Human Services; Program or activity: 25. Head Start; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $255.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 11. Department of Health and Human Services; Program or activity: 26. Temporary Assistance for Needy Families; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0[B]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 11. Department of Health and Human Services; Program or activity: 27. Foster Care--Title IV-E; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 11. Department of Health and Human Services; Program or activity: 28. State Children's Insurance Program; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 11. Department of Health and Human Services; Program or activity: 29. Child Care and Development Fund; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 12. Department of Homeland Security; Program or activity: 30. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 13. Department of Housing and Urban Development; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 13. Department of Housing and Urban Development; Program or activity: 31. Low Income Public Housing; Improper payments reported: 2003: (in millions): $650.0; Improper payments reported: 2004: (in millions): $356.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 13. Department of Housing and Urban Development; Program or activity: 32. Section 8 Tenant Based; Improper payments reported: 2003: (in millions): $1,215.0; Improper payments reported: 2004: (in millions): $840.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 13. Department of Housing and Urban Development; Program or activity: 33. Section 8 Project Based; Improper payments reported: 2003: (in millions): $662.0; Improper payments reported: 2004: (in millions): $511.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 13. Department of Housing and Urban Development; Program or activity: 34. Community Development Block Grant (Entitlement Grants, States/Small Cities); Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0[B]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 13. Department of Housing and Urban Development; Program or activity: 35. Federal Housing Administration's Single Family Acquired Asset Management System; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $26.1; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 14. Department of the Interior; Program or activity: 36. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 15. Department of Justice; Program or activity: 37. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 16. Department of Labor; Program or activity: All programs and activities; Improper payments reported: 2003: (in millions): $[Empty]; Improper payments reported: 2004: (in millions): $[Empty]; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 16. Department of Labor; Program or activity: 38. Unemployment Insurance; Improper payments reported: 2003: (in millions): $4,225.0; Improper payments reported: 2004: (in millions): $3,861.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 16. Department of Labor; Program or activity: 39. Federal Employees' Compensation Act; Improper payments reported: 2003: (in millions): $9.1; Improper payments reported: 2004: (in millions): $6.4; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 16. Department of Labor; Program or activity: 40. Workforce Investment Act; Improper payments reported: 2003: (in millions): $3.1; Improper payments reported: 2004: (in millions): $0.0[B]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 17. National Aeronautics and Space Administration; Program or activity: 41. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 18. National Credit Union Administration[D]; Program or activity: 42. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 19. National Science Foundation; Program or activity: 43. Research and Education Grants and Cooperative Agreements; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $4.4; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 20. Nuclear Regulatory Commission; Program or activity: 44. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: Yes; Will estimate within the next 6 years: No. Agency: 21. Office of Personnel Management; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 21. Office of Personnel Management; Program or activity: 45. Retirement Program (Civil Service Retirement System and Federal Employees Retirement System); Improper payments reported: 2003: (in millions): $177.3; Improper payments reported: 2004: (in millions): $197.7; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 21. Office of Personnel Management; Program or activity: 46. Federal Employees Health Benefits Program; Improper payments reported: 2003: (in millions): $28.2; Improper payments reported: 2004: (in millions): $86.1; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 21. Office of Personnel Management; Program or activity: 47. Federal Employees Group Life Insurance; Improper payments reported: 2003: (in millions): $0.4; Improper payments reported: 2004: (in millions): $2.1; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 22. Pension Benefit Guaranty Corporation[D]; Program or activity: 48. All programs and activities; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Unknown. Agency: 23. Railroad Retirement Board; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 23. Railroad Retirement Board; Program or activity: 49. Retirement and Survivors Benefits; Improper payments reported: 2003: (in millions): $168.3; Improper payments reported: 2004: (in millions): $172.8; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 23. Railroad Retirement Board; Program or activity: 50. Railroad Unemployment Insurance Benefits; Improper payments reported: 2003: (in millions): $2.8; Improper payments reported: 2004: (in millions): $3.3; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 24. Small Business Administration; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 24. Small Business Administration; Program or activity: 51. 7(a) Business Loan Program; Improper payments reported: 2003: (in millions): $13.0; Improper payments reported: 2004: (in millions): $0.0[B]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: Yes. Agency: 24. Small Business Administration; Program or activity: 52. 504 Certified Development Companies; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.0[E]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 24. Small Business Administration; Program or activity: 53. Disaster Assistance; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $1.1; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 24. Small Business Administration; Program or activity: 54. Small Business Investment Companies; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $129.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 25. Social Security Administration; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 25. Social Security Administration; Program or activity: 55. Old Age and Survivors' Insurance; Improper payments reported: 2003: (in millions): $600.0; Improper payments reported: 2004: (in millions): $1,707.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 25. Social Security Administration; Program or activity: 56. Disability Insurance; Improper payments reported: 2003: (in millions): $340.0; Improper payments reported: 2004: (in millions): $0.0[C]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 25. Social Security Administration; Program or activity: 57. Supplemental Security Income Program; Improper payments reported: 2003: (in millions): $2,740.0; Improper payments reported: 2004: (in millions): $2,639.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 26. Department of State; Program or activity: All programs and activities; Improper payments reported: 2003: (in millions): $[Empty]; Improper payments reported: 2004: (in millions): $[Empty]; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 25. Social Security Administration; Program or activity: 58. International Narcotic and Law Enforcement Affairs-Narcotics Program; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $1.7; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 25. Social Security Administration; Program or activity: 59. International Information Program-U.S. Speaker and Specialist Program; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $1.4; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 25. Social Security Administration; Program or activity: 60. Vendor Payments; Improper payments reported: 2003: (in millions): $0.0; Improper payments reported: 2004: (in millions): $0.8; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 27. Department of Transportation; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 27. Department of Transportation; Program or activity: 61. Airport Improvement Program; Improper payments reported: 2003: (in millions): $14.0; Improper payments reported: 2004: (in millions): $0.0[F]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 27. Department of Transportation; Program or activity: 62. Highway Planning and Construction; Improper payments reported: 2003: (in millions): $1.4; Improper payments reported: 2004: (in millions): $0.0[E]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 27. Department of Transportation; Program or activity: 63. Federal Transit--Capital Investment Grants; Improper payments reported: 2003: (in millions): $32.0; Improper payments reported: 2004: (in millions): $0.0[E]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 27. Department of Transportation; Program or activity: 64. Federal Transit--Formula Grants; Improper payments reported: 2003: (in millions): $64.0; Improper payments reported: 2004: (in millions): $0.0[E]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 28. Department of the Treasury; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 28. Department of the Treasury; Program or activity: 65. Earned Income Tax Credit; Improper payments reported: 2003: (in millions): $10,500.0; Improper payments reported: 2004: (in millions): $9,650.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 29. Department of Veterans Affairs; Program or activity: All programs and activities; A-11: No; Agency reported it had assessed all programs: Yes; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 29. Department of Veterans Affairs; Program or activity: 66. Compensation; Improper payments reported: 2003: (in millions): $256.0[A]; Improper payments reported: 2004: (in millions): $238.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 29. Department of Veterans Affairs; Program or activity: 67. Dependency and Indemnity Compensation; Improper payments reported: 2003: (in millions): $0.0[C]; Improper payments reported: 2004: (in millions): $0.0[]; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 29. Department of Veterans Affairs; Program or activity: 68. Education Programs; Improper payments reported: 2003: (in millions): $52.0[A]; Improper payments reported: 2004: (in millions): $55.0; A-11: No; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 29. Department of Veterans Affairs; Program or activity: 69. Pension; Improper payments reported: 2003: (in millions): $284.0; Improper payments reported: 2004: (in millions): $262.0; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Agency: 29. Department of Veterans Affairs; Program or activity: 70. Insurance Programs; Improper payments reported: 2003: (in millions): $0.3; Improper payments reported: 2004: (in millions): $0.4; A-11: Yes; Agency reported it had assessed all programs: No; Programs that the agency reported were not susceptible to significant: improper payments: No; Will estimate within the next 6 years: No. Totals; Improper payments reported: 2003: (in millions): $35,772.4; Improper payments reported: 2004: (in millions): $45,407.5; A-11: 46; Agency reported it had assessed all programs: 23; Programs that the agency reported were not susceptible to significant: improper payments: 10; Will estimate within the next 6 years: 10. Source: GAO's analysis of cited agencies' fiscal year 2004 PARs. [A] Fiscal year 2003 estimates were updated to the revised estimates reported in the fiscal year 2004 PARs. [B] Agency did not report an annual improper payment estimate. [C] Agency combined with the above program. [D] Agency did not address improper payments or the IPIA requirements for this program in its fiscal year 2004 PAR. [E] Agency reported that its annual improper payment estimate was zero. [F] Agency reported an annual improper payment estimate, but it was an insignificant amount that rounded to zero for purposes of this table. [End of table] [End of section] Appendix V: Comments from the Office of Management and Budget: EXECUTIVE OFFICE OF THE PRESIDENT: OFFICE OF MANAGEMENT AND BUDGET: DEPUTY DIRECTOR FOR MANAGEMENT: WASHINGTON, D.C. 20503: MAR 25 2005: Mr. McCoy Williams: Director: Financial Management and Assurance: Government Accountability Office: 441 G Street, NW: Washington, DC 20548: Dear Mr. Williams: Thank you for the opportunity to comment on the GAO draft report entitled, "Financial Management: Challenges in Meeting Requirements of the Improper Payments Information Act" (GAO-05-417). Eliminating improper payments in the Federal Government continues to be a central focus of this Administration. Through the government-wide efforts to improve financial management under the President's Management Agenda (PMA), as well as the new PMA Eliminating Improper Payments initiative in particular, we are striving to eliminate improper payments within all agency programs and activities. GAO remains an integral partner in this endeavor, and we appreciate the ongoing feedback and guidance that you have provided. In Fiscal Year (FY) 2004, Federal agencies established a strong foundation for measuring improper payments, identifying and implementing the necessary corrective actions, and tracking success over time. These agency efforts are detailed in the OMB report, Improving the Accuracy and Integrity of Federal Payments, which was issued on January 25, 2005. The report on improper payments represents a critical step in meeting the goals of the Improper Payments Information Act (IPIA) of 2002, as it establishes a baseline from which short-and long-term program improvement strategies and priorities will be based. Several of the key findings of the OMB report include the following: * Federal agencies determined that 60% of all Federal outlays in FY 2004 ($1.4 trillion out of $2.3 trillion) were risk susceptible for a significant level of improper payments; * Federal agencies were able to establish improper payment rates (and amounts) for programs that account for more than 80% of risk susceptible dollars; * Seven programs alone account for approximately 95% of the improper payments reported in FY 2004; and: * The improper payments total reported in FY 2004 is expected to decline when reported in FY 2005, based on agency established reduction targets supported by process and control improvements to the payment process. This OMB report may be found at http://www.whitehouse.gov/omb/financial/fia/ipia_gov-wide_report.pdf With regard to the GAO draft report, OMB has the following comments: * OMB recognizes that a small number of risk assessments are not complete and that improper payment measurements are needed for certain programs. However, it is important to note that the remaining risk assessments to be completed: correlate to programs with relatively small outlay amounts that, if found to be risk susceptible, are not expected to add significantly to the government-wide total. Moreover, Federal agencies reported an improper payment amount for 80% of risk susceptible dollars. Once an improper payment amount is reported for Medicaid-which is expected to begin with the FY 2005 reporting cycle-Federal agencies will then be reporting an improper payment amount for 94% of risk susceptible dollars. * While improved detection methods may raise the government-wide improper payments estimate in future years, OMB notes that Federal agencies are actively implementing control and process improvements. It is expected that these actions will result in corresponding reductions for those improper payments already identified. * Pursuant to the PMA Eliminating Improper Payments initiative, Federal agencies are currently required to submit completed risk assessments and error measurement plans for OMB review and approval. Such deliverables must include relevant timeframes and account for the resources necessary to complete planned actions. Agency plans for addressing IPIA reporting requirements are closely considered in identifying agency resource needs and preparing the President's Budget. * While it is recommended that OMB consider using disincentives (such as reduced program funding) in cases where agencies fail to meet IPIA reporting requirements, the requirements of the PMA, in addition to the Inspector General review of agency IPIA activities, currently provide sufficient incentive for ensuring that agencies meet the necessary requirements. * OMB notes that the Environmental Protection Agency and the National Science Foundation completed risk assessments in FY 2004. OMB will continue to work with Federal agencies, as well as the Chief Financial Officer's Council, to direct the necessary attention and resources toward efforts to eliminate improper payments. Thank you for the opportunity to review and comment on your draft report on this important issue. Sincerely, Signed by: Clay Johnson III: The following is GAO's comment on OMB's letter dated March 25, 2005. GAO Comment: 1. In our review of these agencies' fiscal year 2004 PARs, we determined that assessments were not completed for all programs and activities. [End of section] Appendix VI: GAO Contacts and Staff Acknowledgments: GAO Contacts: Carla Lewis, (202) 512-6915; Alana Stanfield, (202) 512-3197: Acknowledgments: In addition to those named above, Lisa Crye, Bonnie McEwan, and Donell Ries made important contributions to this report. (195060): FOOTNOTES [1] Pub. L. No. 107-300, 116 Stat. 2350 (Nov. 26, 2002). [2] OMB Memorandum M-03-13, "Improper Payments Information Act of 2002 (Public Law 107-300)," May 21, 2003. [3] Section 57 was eliminated from OMB Circular No. A-11. See OMB Circular No. A-11, Transmittal Memorandum #77, July 25, 2003. App. I lists the 15 agencies and 46 programs previously cited in Section 57. [4] GAO, Financial Management: Fiscal Year 2003 Performance and Accountability Reports Provide Limited Information on Governmentwide Improper Payments, GAO-04-631T (Washington, D.C.: Apr. 15, 2004). [5] See Treasury Financial Manual, vol. 1, part 2, ch. 4700, for a list of the 35 agencies. Six of the 35 agencies had not issued PARs as of our fiscal year 2004 audit report on the U.S. government's consolidated financial statements, dated December 14, 2004; therefore, these agencies were not included in our review. [6] OMB's guidance uses the term erroneous payments rather than improper payments. We consider the terms synonymous. [7] The law defines "payment" as any payment (including a commitment for future payment, such as a loan guarantee) that is (1) made by a federal agency, a federal contractor, or a governmental or other organization administering a federal program or activity and (2) derived from federal funds or other federal resources or that will be reimbursed from federal funds or other federal resources. The law defines an "improper payment" as (1) any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements and (2) any payment to an ineligible recipient, any payment for an ineligible service, any duplicate payment, payment for services not received, and any payment that does not account for credit for applicable discounts. [8] The PMA issued in 2001 included nine program initiatives, including reform of food aid programs. When OMB issued this August 2004 report to federal employees, the reform of food aid program initiative was the only initiative not carried forward from the 2001 PMA. OMB also added two new program initiatives--(1) Strengthen Real Property Management and Optimize the Use of Federal Property and (2) Eliminate Improper Payments. As a result to these changes, 10 program-specific initiatives are currently in place under the PMA. [9] In determining which programs are susceptible to significant improper payments, OMB defines significant erroneous payments as those annual erroneous payments in a program exceeding both 2.5 percent of program payments and $10 million. [10] See Treasury Financial Manual, vol. 1, part 2, ch. 4700, for a list of the 35 agencies. [11] See Treasury Financial Manual, vol. 1, part 2, ch. 4700, for a list of the 35 agencies. Six of the 35 agencies had not issued PARs as of our fiscal year 2004 audit report on the U.S. government's consolidated financial statements, dated December 14, 2004; therefore, these agencies were not included in our review. [12] Program partners can include other agencies or intermediaries responsible for carrying out different aspects of the program and might include federal agencies, states or localities, grant recipients, participating financial institutions, regulated bodies, and contractors. GAO's Mission: The Government Accountability Office, the investigative arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. GAO examines the use of public funds; evaluates federal programs and policies; and provides analyses, recommendations, and other assistance to help Congress make informed oversight, policy, and funding decisions. 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