PATIENT 

PROTECTION AND 

AFFORDABLE CARE 

ACT

Procedures for 

Reporting Certain 

Financial 

Management 

Information Should Be 

Improved

Report to Congressional Requesters

September 2014

GAO-14-697

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-697, a report to 

congressional requesters

September 2014

PATIENT PROTECTION AND AFFORDABLE

CARE ACT 

Procedures for Reporting Certain Financial 

Management Information Should Be Improved

Why GAO Did This Study

PPACA makes significant changes in

the way health insurance in the United 

States is provided, including changes 

to private health insurance coverage. 

GAO was asked to examine the 

resources that CCIIO used and 

expects to use in implementing the 

private health insurance provisions of 

PPACA. GAO’s objective was to

identify resources that CCIIO received, 

used, and expects to use from 

enactment of PPACA through fiscal 

year 2014, including certain categories 

of expenditures, the sources of 

funding, and the total number of staff, 

along with the number of staff 

reassigned from other units. 

To perform this work GAO obtained the 

information requested and compared it 

to available supporting documentation, 

reviewed available related policies and 

procedures, and interviewed CMS 

officials. 

What GAO Recommends

GAO recommends that CMS identify 

and evaluate options to facilitate 

reporting CCIIO-related financial 

management information that is 

independently verifiable in a timely 

manner, and develop and implement 

policies and procedures to document

the preparation, review, and approval 

of information produced for nonroutine 

requests. 

HHS did not concur with GAO’s 

recommendations. In its view, CMS’s 

existing procedures are adequate to 

respond to nonroutine information 

requests. However, as discussed in 

this report, GAO continues to believe 

that enhancements to CMS’s 

procedures are needed and that the

recommendations are valid.

What GAO Found

The Department of Health and Human Service’s (HHS) Centers for Medicare 

and Medicaid Services (CMS) provided GAO with most of the requested data 

regarding financial resources that the Center for Consumer Information and 

Insurance Oversight (CCIIO) and other CMS offices received, used, and expect 

to use to implement the private health insurance and health insurance exchange 

provisions of the Patient Protection and Affordable Care Act (PPACA) for which 

CCIIO is responsible from its enactment in March 2010 through fiscal year 2014. 

However, CMS did not provide estimates of fiscal year 2014 obligations for 

certain categories of CCIIO-related transactions, such as advertising and other 

public relations activities. In addition, CMS provided data on CCIIO’s staffing 

levels as of September 30, 2013, but did not provide complete staffing 

reassignment data. 

GAO was unable to consistently verify the reliability of the data received from 

CMS. Specifically: 

• GAO was able to determine the reliability of CMS’s estimates for total 

obligations for fiscal year 2014, which was $3.7 billion; the number of staff as 

of September 30, 2013, which was 347; and total salary expenditures from 

March 2010 through fiscal year 2013, which were $79.8 million. 

• GAO could not determine the reliability of any of the other financial 

information CMS provided because CMS’s core financial system did not 

produce totals for much of the CCIIO-related information requested. For 

example, the system did not produce expenditure totals for CCIIO-related 

polling, focus groups, or advertising and other public relations activities 

because of how these activities are captured in the system. Similarly,

information related to reassignment of staff to CCIIO from other CMS and 

HHS units was not readily available. Consequently, the staff reassignment 

information provided to GAO was not complete, was not supported by 

documentary evidence, and could not be verified. 

GAO identified several issues that contributed to CMS’s inability to provide 

complete information that is independently verifiable in a timely manner. First, 

CMS does not have an effective means of identifying CCIIO-related information. 

While CMS had policies and procedures for its standard financial operations, it

did not have documented policies and procedures for responding to nonroutine

information requests. Instead, CMS relied on ad hoc manual procedures that 

were labor intensive and time consuming. As a result, CMS required an extended 

period of time to provide most of the information GAO requested, in some cases 

taking several months. Second, CMS does not have documented procedures to 

ensure that data requests are reviewed and approved for accuracy. CMS officials 

told GAO that the information they provided had been subject to review and 

approval at several levels, including review by subject matter experts. However, 

these procedures were not documented. Consequently, GAO was not able to 

independently verify that they had been properly performed. Because CMS’s 

processes are inconsistent with certain federal accounting and internal control 

standards, Congress and other decision makers may not have access to timely 

and reliable CCIIO-related information that they may need to make resource 

allocation decisions and assessments of program performance. 

View GAO-14-697. For more information, 

contact Beryl H. Davis at (202) 512-2623 or

davisbh@gao.gov. 
Page i GAO-14-697 CCIIO Financial Management Information 

Letter 1

Background 3

Limitations in CMS’s Policies and Procedures Impeded Efforts 

to Determine the Reliability of Most of the CCIIO-Related 

Resources That CMS Reported It Received and Used 6

Conclusions 17

Recommendations for Executive Action 17

Agency Comments and Our Evaluation 18

Appendix I Objective, Scope, and Methodology 21

Appendix II Comments from the Department of Health and 

Human Services 23

Appendix III GAO Contact and Staff Acknowledgments 26

Tables

Table 1: Reliability Could Be Determined for Center for Consumer 

Information and Insurance Oversight (CCIIO) Related 

Estimated Total Obligations and Salary Obligations, Fiscal 

Year 2014 9

Table 2: Reliability Could Not Be Determined for Center for 

Consumer Information and Insurance Oversight (CCIIO) 

Related Total Obligations and Expenditures, March 2010 

through Fiscal Year 2013 11

Table 3: Reliability Could Not Be Determined for Center for 

Consumer Information and Insurance Oversight (CCIIO) 

Related Salary and Travel Expenditures by Funding 

Source and Travel Expenditures in Total, March 2010 

through Fiscal Year 2013 12

Table 4: Reliability Could Not Be Determined for Center for 

Consumer Information and Insurance Oversight (CCIIO) 

Related Expenditures for Advertising and Other Public 

Relations Activities, Polling and Focus Groups, and 

Conferences, March 2010 through Fiscal Year 2013 14

Contents
Page ii GAO-14-697 CCIIO Financial Management Information 

Abbreviations

CCIIO Center for Consumer Information and Insurance Oversight

CMS Centers for Medicare and Medicaid Services

HCERA Health Care and Education Reconciliation Act of 2010

HHS Department of Health and Human Services

HIGLAS Healthcare Integrated General Ledger Accounting System

IPA independent public accountant

OCIIO Office of Consumer Information and Insurance Oversight

OMB Office of Management and Budget

PCIP Pre-Existing Condition Insurance Plan

PPACA Patient Protection and Affordable Care Act

SOP standard operating procedure

Treasury Department of the Treasury

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Page 1 GAO-14-697 CCIIO Financial Management Information 

441 G St. N.W.

Washington, DC 20548

September 22, 2014

The Honorable Dave Camp

Chairman

Committee on Ways and Means

House of Representatives

The Honorable Charles Boustany

Chairman

Subcommittee on Oversight

Committee on Ways and Means

House of Representatives

The Patient Protection and Affordable Care Act (PPACA),1 which was 

enacted in March 2010, includes provisions to expand access to public 

and private health insurance—including through the creation of health 

insurance exchanges—and made a number of changes affecting the 

provision of private health insurance.2

 1

Pub. L. No. 111-148 (Mar. 23, 2010), as amended by the Health Care and Education 

Reconciliation Act of 2010 (HCERA), Pub. L. No. 111-152 (Mar. 30, 2010). In this report, 

references to PPACA include any amendments made by HCERA.

Responsibility for implementation 

of the act’s provisions regarding private health insurance and 

establishment of health insurance exchanges was originally assigned by 

the Secretary of Health and Human Services to the Office of Consumer 

Information and Insurance Oversight (OCIIO), within the Office of the 

Secretary, under the Department of Health and Human Services (HHS). 

In January 2011, this responsibility was transferred by the Secretary to 

HHS’s Centers for Medicare and Medicaid Services (CMS), which created 

a new office, the Center for Consumer Information and Insurance 

2

Health insurance exchanges are marketplaces where eligible individuals may compare 

and select among insurance plans offered by participating private issuers of health 

coverage. PPACA directed states to establish state-based exchanges by January 1, 2014. 

In states electing not to establish and operate such exchanges, PPACA requires the 

federal government to establish and operate exchanges in the states, referred to as the 

federally facilitated exchanges.
Page 2 GAO-14-697 CCIIO Financial Management Information 

Oversight (CCIIO), to assume the responsibility, and OCIIO was 

disestablished.3

You asked us to examine the financial and staff resources used or 

expected to be used by CMS in implementing the private health insurance 

provisions of PPACA from its enactment through fiscal year 2014. Our 

objective was to identify the CCIIO-related resources that CMS received, 

used, and expects to use to implement PPACA from enactment though 

fiscal year 2014, including certain categories of expenditures; the source 

of the funding; the number of CCIIO staff and CMS staff working on 

CCIIO-related activities as of September 30, 2013; and the number of 

staff reassigned from other units.

To achieve our objective, we contacted responsible officials at CMS to 

request information on (1) data concerning total CCIIO-related 

obligations4 and expenditures from the enactment of PPACA in March 

2010 through fiscal year 2013,5

 3

CMS created CCIIO to oversee the implementation of the PPACA provisions related to 

private health insurance and health insurance exchanges. While CCIIO is the primary 

office responsible for implementation, other CMS offices and centers also perform 

services in support of the implementation of these provisions, and the related amounts are 

included in this report. In this report, “CCIIO-related” refers to all CMS obligations and 

expenditures for implementing PPACA’s private health insurance and exchange 

provisions. 

including amounts related to salaries, 

travel, advertising and other public relations activities, polling and focus 

groups, and conferences; (2) CMS’s estimates of obligations in total and 

in each of these categories for fiscal year 2014; and (3) the number of 

full- and part-time CCIIO staff as of September 30, 2013, including the

number reassigned from other CMS and HHS units. We also requested 

available supporting documentation for the information provided to assist 

in determining its reliability and reviewed policies and procedures and 

internal controls in place intended to help to ensure the reliability of the 

4

Obligations are legal liabilities of an agency to pay for goods and services ordered or 

received. An agency incurs an obligation, for example, when it places an order, signs a 

contract, awards a grant, purchases a service, or takes other actions that require the 

government to make payments to the public or from one government account to another. 

Expenditures are the actual spending of money through the issuance of checks, 

disbursement of cash, or electronic transfer of funds made to liquidate an obligation.

5

Prior to the establishment of CCIIO within CMS, OCIIO obligations and expenditures 

were recorded in the Unified Financial Management System within the Office of the 

Secretary. 
Page 3 GAO-14-697 CCIIO Financial Management Information 

information and to assess its applicability to our audit objectives and 

conformance with Standards for Internal Control in the Federal 

Government.6 In order to determine whether the information provided was 

reliable,7

We conducted this performance audit from January 2013 to September 

2014 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

we also analyzed the information we received, conducted followup inquiries with agency officials to ensure that we had received what we 

requested, and compared the information to available supporting 

documentation. As discussed in the report, we were not able to determine 

the reliability of most of the information. In addition, we met with officials 

from the Office of Inspector General of HHS and the independent auditor 

of the fiscal year 2013 and 2012 CMS financial statements to determine 

whether they were aware of any issues pertinent to our objectives that we 

should consider in designing our audit procedures. For further details of 

our scope and methodology, see appendix I.

HHS is one of several federal agencies collectively responsible for 

implementing the provisions of PPACA related to private health insurance 

and health insurance exchanges.8

 6

GAO, Standards for Internal Control in the Federal Government, 

Within HHS, CMS is the primary 

component responsible for PPACA implementation. In 2011, CMS 

created CCIIO, one of six centers under CMS, to oversee implementation 

of PPACA’s private health insurance and health insurance exchange 

GAO/AIMD-00-21.3.1.

(Washington, D.C.: November 1999).

7

For financial information to be considered reliable, it must be determined to be 

(1) complete (includes all applicable information), (2) accurate (free of material error or 

fraud), and (3) valid (includes only financial information that accurately represents the 

substance of the nature of the underlying financial activity). 

8

Other federal agencies involved in the implementation of the private health insurance

provisions of PPACA include the Employee Benefits Security Administration under the 

Department of Labor and the Internal Revenue Service under the Department of the 

Treasury.

Background
Page 4 GAO-14-697 CCIIO Financial Management Information 

provisions.9 PPACA provided much of the funding used by CMS to 

implement the CCIIO-related private health insurance and health 

insurance exchange provisions it contains.10 Most such funding provided 

by PPACA is dedicated to funding these CCIIO-related provisions and 

cannot be used for any other CMS activities.11 However, CMS also used 

funding provided by other legislation that was not specifically dedicated to 

the private health insurance and health insurance exchange provisions of 

PPACA and thus was also available to fund other CMS activities. This 

includes CMS’s annual Program Management appropriation, which 

provides funding for CMS’s administrative activities and the Health 

Insurance Reform Implementation Fund.12 Funding for CCIIO-related 

activities represents a relatively small portion of the total funding used by 

CMS and recorded in its core financial system, the Healthcare Integrated 

General Ledger Accounting System (HIGLAS). For example, for fiscal 

year 2013, CMS reported that it incurred obligations totaling $1.16 trillion 

of which $5.72 billion (0.49 percent) was for CCIIO-related transactions 

according to data provided by CMS.13

 9

In addition, CMS has 15 operational offices responsible for other functions, including 

aspects of the Medicare and Medicaid programs. 

10PPACA provided appropriations for implementation of the Consumer Assistance 

Program ($30 million), Rate Reviews ($250 million), Pre-Existing Condition Insurance Plan 

(PCIP) ($5 billion), Employee Retirement Reinsurance Plan ($5 billion), Consumer 

Operated and Oriented Plan ($6 billion, $3.9 billion of which was subsequently rescinded), 

and Affordable Insurance Exchange Grants (an indefinite amount to be determined 

annually by the Secretary of HHS). For exchanges being operated directly by the federal 

government, the user fees paid by issuers participating in the exchanges are also included 

in CMS’s CCIIO-related funding. In addition, as allowed under the PPACA PCIP provision, 

CMS also collects premiums from PCIP enrollees that CMS uses to fund the cost of the 

program.

11CMS has also drawn on appropriations provided under PPACA for the Prevention and 

Public Health Fund for other CMS activities. From enactment through fiscal year 2013, 

these accounted for about 2.6 percent of total appropriated funds obligated by CMS for 

PPACA CCIIO-related purposes. All other CCIIO-related appropriations provided under 

PPACA were dedicated to CCIIO-related activities only.

12The Health Insurance Reform Implementation Fund was established by section 1005 of 

the Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152 (Mar. 30, 

2010), appropriating $1 billion to HHS for federal administrative expenses to carry out both 

that act and PPACA.

13CMS’s obligations incurred include amounts related to the Medicare and Medicaid 

programs.
Page 5 GAO-14-697 CCIIO Financial Management Information 

CMS’s accounting for CCIIO-related transactions is significantly affected 

by the manner in which transactions are funded and recorded in HIGLAS, 

which is used by all of CMS’s 21 offices and centers, including CCIIO. 

Appropriated funds are recorded in HIGLAS using separate appropriation 

accounts established by the Department of the Treasury (Treasury).14

Each fiscal year from 2010 through 2013, CMS’s financial statements, 

which were derived from its core financial system, were audited by an 

independent public accountant (IPA). In each of these years, the IPA 

concluded that CMS’s financial balance sheets—and statements of net 

costs, changes in net position, and budgetary resources—were free of 

material misstatement.

Each year, CMS uses funding from these appropriation accounts to 

support its activities, including the implementation of the CCIIO-related 

private health insurance provisions of PPACA. HIGLAS accounts for 

financial transactions by appropriation account to ensure that funds are 

obligated and expended in accordance with applicable appropriations law. 

Accordingly, the appropriation accounts in HIGLAS correspond to the 

related budgetary funding sources that gave rise to them, rather than to 

the CMS office responsible for implementing the specific activities for 

which the funding was provided. Consequently, appropriation accounts 

that were created based on legislation that funds only CCIIO-related 

activities will include only CCIIO-related transactions, and appropriation 

accounts that were created based on legislation that funds both CCIIOrelated and non-CCIIO-related CMS activities will include both types of 

transactions.

15 This provides assurance that totals produced by 

HIGLAS constitute reliable evidence of the nature of the underlying 

transactions and their total dollar amount.

 14Treasury appropriation accounts are assigned by Treasury, in collaboration with the 

Office of Management and Budget (OMB) and the affected agency, to each individual 

appropriation, receipt, or other fund account. Financial transactions of the federal 

government are classified by appropriation account for reporting to Treasury and OMB.

15Because of significant uncertainties primarily related to the achievement of the projected 

reductions in Medicare cost growth reflected in the fiscal years 2010, 2011, 2012, and 

2013 Statements of Social Insurance and Statements of Changes in Social Insurance 

Amounts, CMS’s independent auditor was unable to express an opinion on these financial 

statements. However, these issues did not affect CCIIO-related transactions or the 

integrity of HIGLAS totals. 
Page 6 GAO-14-697 CCIIO Financial Management Information 

CMS provided most of the CCIIO-related information we requested, but 

limitations in its policies and procedures made the process of obtaining it 

difficult and time consuming, and we could not determine the reliability of 

most of the amounts CMS provided. For several reasons, CMS’s core 

financial system—HIGLAS—did not produce CCIIO-specific totals for 

much of the financial information we requested, and CMS did not have an 

efficient alternate approach for identifying the information. Expenditure 

totals for certain activities—for example, advertising—could not be 

distinguished from other transactions because CMS had not assigned 

identifying codes to identify the CMS office or the nature of the activity in 

HIGLAS. Also, HIGLAS does not produce totals of CCIIO-related travel 

and salary transactions in total or by funding source. In addition, 

information regarding staff reassignments to CCIIO from other CMS and 

HHS units was not readily available, and the related information CMS 

provided was incomplete and not supported by documentary evidence. 

CMS did not have policies and procedures for responding to nonroutine 

information requests such as ours. Consequently, CMS employed an ad 

hoc manual process to identify the information requested, which was 

labor intensive and time consuming. In addition, CMS’s procedures for 

identifying and obtaining the information and its review and approval were 

not documented, so we also could not verify that these procedures had 

been properly performed.

Statement of Federal Financial Accounting Standards No. 4, Managerial 

Cost Accounting Standards and Concepts,

16 and Statement of Federal 

Financial Accounting Concepts No.1, Objectives of Federal Financial 

Reporting,

17 highlight the importance of reliable and timely information to 

key stakeholders, such as managers, executives, and Congress, to 

support informed resource allocation decisions and assessments of 

program performance and the need for it to be verifiable. In addition, 

Standards for Internal Control in the Federal Government requires that 

internal control be clearly documented and that the documentation be 

readily available for examination.18

 16Federal Accounting Standards Advisory Board, Statement of Federal Financial 

Accounting Standards No. 4: Managerial Cost Accounting Standards and Concepts, 

(Washington, D.C.: July 31, 1995).

Because CMS was not able to provide 

17Federal Accounting Standards Advisory Board, Statement of Federal Financial 

Accounting Concepts No. 1: Objectives of Federal Financial Reporting, (Washington, 

D.C.: Sept. 2, 1993).

18GAO/AIMD-00-21.3.1.

Limitations in CMS’s 

Policies and 

Procedures Impeded 

Efforts to Determine 

the Reliability of Most 

of the CCIIO-Related 

Resources That CMS 

Reported It Received 

and Used
Page 7 GAO-14-697 CCIIO Financial Management Information 

timely CCIIO-related information whose reliability could be independently 

determined, Congress and other decision makers may not have timely 

and reliable CCIIO-related financial management information, which could 

hamper efforts to make informed resource allocation decisions and 

assessment of program performance.

CMS provided most of the CCIIO-related financial management 

information we requested, which consisted of (1) total CCIIO-related 

obligations and expenditures from the enactment of PPACA through fiscal 

year 2013; (2) estimates of total CCIIO-related obligations for 

expenditures for fiscal year 2014; (3) the number of full-time CCIIO staff 

as of September 30, 2013;19

• Estimates of fiscal year 2014 CCIIO-related obligations (1) for staff 

salaries funded by legislation that also funds salaries related to other 

non-CCIIO related CMS activities or (2) related to the Prevention and 

Public Health Fund, travel, advertising and other public relations 

activities, polling and focus groups, and conferences. CMS did not 

provide estimates of fiscal year 2014 obligations for these specific 

categories because it did not prepare related estimates at this level of 

detail.

and (4) total CCIIO-related expenditures 

from the enactment of PPACA through fiscal year 2013 for salaries, 

travel, advertising and other public relations activities, polling and focus 

groups, and conferences. However, CMS did not provide complete 

information regarding the following:

• Reassignments of staff to CCIIO from Medicare, Medicaid, or other 

CMS or HHS divisions and offices. CMS did not provide complete 

staff reassignment information because according to CMS officials, 

obtaining it would require review of each staff member’s personnel 

file, which would be labor intensive and time consuming.

As discussed in the following section, although CMS was able to provide 

most of the information we requested, the reliability of most of it could not 

be determined.

 19CMS informed us it did not have any CCIIO staff who were working only part-time. 

CMS Provided Most of the 

Requested Information
Page 8 GAO-14-697 CCIIO Financial Management Information 

Because of limitations in CMS’s policies and procedures, we could not 

determine the reliability of most of the CCIIO-related financial 

management information that CMS provided. Specifically, CMS did not 

record and retain the information in a manner that facilitated its retrieval in 

a form that lent itself to independent verification of reliability. CMS 

extracted most of the requested data from HIGLAS based on transaction 

codes and provided it to us on manually prepared spreadsheets. 

However, CMS’s core financial system—HIGLAS, which is the basis of its 

audited financial statements—did not produce corresponding totals. As a 

result, there were no HIGLAS totals to which the CMS-provided 

spreadsheet amounts could be compared for purposes of determining 

whether they included all appropriate data that were contained in HIGLAS 

and could therefore be considered complete. Also, certain expenditures 

had not been assigned identifying transaction codes in HIGLAS, so the 

system was unable to produce related totals. In addition, the staff 

reassignment information provided by CMS was not supported by 

documentary evidence and therefore its reliability could also not be 

determined.

We determined that CMS’s estimates of total obligations for expenditures 

for fiscal year 2014—both in total and by funding source—were reliable. 

Also, estimates of salary expenditures funded by appropriation accounts 

that fund only CCIIO-related activities were reliable. To make these 

determinations, we reconciled CMS’s estimates to the President’s Budget 

and reviewed the logic underlying subsequent updates to the estimates, 

which we determined to be reasonable. These data, which we determined 

to be reliable, are shown in table 1.

Reliability of Most of the 

Information CMS Provided 

Could Not Be Determined

Some of the Information CMS 

Provided Was Determined to 

Be Reliable
Page 9 GAO-14-697 CCIIO Financial Management Information 

Table 1: Reliability Could Be Determined for Center for Consumer Information and Insurance Oversight (CCIIO) Related 

Estimated Total Obligations and Salary Obligations, Fiscal Year 2014

Dollars in thousands

Funding source Total estimated 

obligations for 

FY 2014

Estimated staff 

salary obligations 

for FY 2014 a

Amounts funded by appropriation accounts that fund only CCIIO-related activities

b

Consumer Assistance Program Grants $0 $0

Grants to states for premium review 0 N/A

Pre-Existing Condition Insurance Plan 358,134 5,000

Early Retiree Reinsurance Program 8,140 1,000

Affordable Insurance Exchanges Grants to States 1,342,521 8,000

Consumer Operated and Oriented Plan Program Account 16,900 5,000

Exchange user fees 200,000 0 

Subtotal $1,925,695 $19,000

Amounts funded by appropriation accounts that fund CCIIO-related and non-CCIIO related activities

Health Insurance Reform Implementation Fund $20,000 N/P

Department of Health and Human Services general departmental management 0 N/P

Program Management 1,326,302 N/P

Secretary’s transfer authority 109,432 N/P

Nonrecurring Expenses Fund 352,982 N/P

Prevention and Public Health Fund 0 N/P

Subtotal $1,808,716 N/P

Grand total for all funding sources $3,734,411 N/P

Source: GAO analysis of Centers for Medicare and Medicaid Services data. | GAO-14-697

Legend: FY = fiscal year; N/A = not applicable; N/P = none prepared.

a

According to the Centers for Medicare and Medicaid Services (CMS), these amounts represent 

CMS’s most recent estimates of total obligations for fiscal year 2014 as of June 30, 2014.

b

The fiscal year 2014 salary obligations estimates were reported in the CMS President’s Budget as of 

April 10, 2013. CMS developed estimates of staff salaries for each funding source using an HHS-wide 

methodology. CMS prepares estimates of staff salaries for funding sources that are used exclusively 

for private health insurance and health insurance exchange activities and are attributable to CCIIO. 

However, for the appropriation accounts that are used for private health insurance and health 

insurance exchange activities as well as other activities, CMS did not prepare separate estimates of 

salary expenditures. Salary expenditure estimates are also included in the related CMS’s budget 

request amounts for fiscal year 2014.

In addition, data provided by CMS on the total CCIIO salary expenditures 

from March 2010 through September 30, 2013, which was $79.8 million, 
Page 10 GAO-14-697 CCIIO Financial Management Information 

as well as the related number of full-time CCIIO staff as of September 30, 

2013, which was 347, were determined to be reliable.20

Because CMS’s core financial system (HIGLAS) does not produce totals 

for a portion of the CCIIO-related obligations and expenditures in total or 

by their funding sources, we could not determine whether these amounts 

were complete, which is a major factor in determining reliability. A portion 

of CCIIO-related expenditures are funded from appropriation accounts 

that also fund non-CCIIO related CMS activities and therefore include 

both CCIIO-related and non-CCIIO-related CMS transactions. In such 

cases, HIGLAS does not produce CCIIO-related totals for these 

obligations and expenditures. Consequently, there were no CCIIO-related 

totals produced by HIGLAS to which we could compare the amounts 

provided by CMS for the purpose of determining their completeness. 

Information provided by CMS indicated that from PPACA’s enactment 

through September 30, 2013, a total of $2.1 billion in CCIIO-related 

obligations and $714 million of CCIIO-related expenditures were included 

in appropriation accounts that also funded CMS activities unrelated to 

CCIIO, as detailed in table 2. However, because we were unable to 

determine whether these amounts were complete, we do not have any 

assurance whether these amounts are reliable and whether the actual 

amounts are larger.

To make this 

determination, we estimated total CCIIO salary expenditures based on 

the number of full-time staff assigned to CCIIO over this period and their 

salary levels, compared our estimate to the total CCIIO salary 

expenditures provided by CMS, and found the difference to be 

reasonable.

 20As discussed later and shown in table 3, we could not determine whether salary 

expenditure amounts by funding source were reliable. 

Reliability Could Not Be 

Determined for CCIIO-Related 

Amounts Partially Funded by 

Appropriation Accounts That 

Also Fund Non-CCIIO 

Activities
Page 11 GAO-14-697 CCIIO Financial Management Information 

Table 2: Reliability Could Not Be Determined for Center for Consumer Information and Insurance Oversight (CCIIO) Related 

Total Obligations and Expenditures, March 2010 through Fiscal Year 2013

Dollars in millions

Funding source Total obligations

March 2010 

through FY 2013

Total expenditures 

March 2010 

through FY 2013 a

Amounts funded by appropriation accounts that fund only CCIIO-related activitiesb

Consumer Assistance Program Grants $28 $25

Grants to states for premium review 221 54

Pre-Existing Condition Insurance Plan 4,971 4,744

Early Retiree Reinsurance Program 4,980 4,961

Affordable Insurance Exchanges Grants to States 4,171 881

Consumer Operated and Oriented Plan Program Account 873 319

Exchange user fees N/A N/A

Subtotal $15,244 $10,984

Amounts funded by appropriation accounts that fund CCIIO-related and non-CCIIO related activities

Health Insurance Reform Implementation Fund $314 $162

Department of Health and Human Services general departmental management 98 92

Program Management 771 393

Secretary’s transfer authority 114 2

Nonrecurring Expenses Fund 300 63

Prevention and Public Health Fund 454 2

Subtotal $2,051 $714

Grand total for all funding sources $17,295 $11,698

Source: GAO analysis of Centers for Medicare and Medicaid Services data. | GAO-14-697

Legend: FY = fiscal year; N/A = not applicable.

a

These amounts reflect the total of obligations incurred during fiscal years 2010, 2011, 2012, and 

2013, whether they are still outstanding or have been liquidated.

b

Because these amounts are funded by appropriation accounts that fund only CCIIO-related activities, 

the Healthcare Integrated General Ledger Accounting System (HIGLAS) produces related totals, and 

we were able to determine that they are complete. However, the grand totals into which they are 

accumulated also include activity funded by appropriation accounts that fund both CCIIO-related and 

non-CCIIO related activities for which HIGLAS does not produce totals. As a result, we could not 

verify the completeness of the grand totals for all funding sources.

Because HIGLAS does not produce totals of CCIIO-related salary or 

travel expenditures, we also could not determine whether the amounts 

that CMS provided for CCIIO-related salary or travel expenditures by 

funding source, or travel expenditures in total, were reliable. CMS officials 

provided salary and travel expenditure amounts that they had extracted 

from HIGLAS and placed on manually prepared spreadsheets. However, 

there were no HIGLAS totals for salary or travel expenditures to which we 

Reliability Could Not Be 

Determined for CCIIO-Related 

Salary or Travel Expenditures 

by Funding Source or for 

Travel Expenditures in Total
Page 12 GAO-14-697 CCIIO Financial Management Information 

could compare the related amounts provided by CMS to determine if they 

were complete, as detailed in table 3. As noted above, total salary 

expenditures of $79.8 million from March 2010 through fiscal year 2013 

were determined to be reliable.

Table 3: Reliability Could Not Be Determined for Center for Consumer Information and Insurance Oversight (CCIIO) Related 

Salary and Travel Expenditures by Funding Source and Travel Expenditures in Total, March 2010 through Fiscal Year 2013

Dollars in thousands

Funding source Salary expenditures 

from March 2010 

through FY 2013

Travel expenditures 

from March 2010 

through FY 2013 

Amounts funded by appropriation accounts that fund only CCIIO-related activities

Consumer Assistance Program Grants $416 $3

Grants to states for premium review 0 0

Pre-Existing Condition Insurance Plan Program 4,588 150

Early Retiree Reinsurance Program 1,836 9

Affordable Insurance Exchanges Grants to States 12,055 308

Consumer Operated and Oriented Plan Program Account 2,467 33

Exchange user fees 0 0

Subtotal $21,362 $503

Amounts funded by appropriation accounts that fund CCIIO-related and non-CCIIO related activities

Health Insurance Reform Implementation Fund $11,494 $245

Department of Health and Human Services general departmental 

management

8,900 49

Program Management 38,087 259

Secretary’s transfer authority 0 0

Nonrecurring Expenses Fund 0 0

Prevention and Public Health Fund 0 0

Subtotal $58,481 $553

Grand total for all funding sources $79,843 $1,056 a

Source: GAO analysis of Centers for Medicare and Medicaid Services data. | GAO-14-697

Legend: FY = fiscal year; N/A = not applicable.

a

We determined that total salary expenditures provided by the Centers for Medicare and Medicaid 

Services (CMS) were reliable based on analytical comparison of the amount provided by CMS with 

related salary levels of individual CCIIO staff members, rather than Healthcare Integrated General 

Ledger Accounting System information. However, we could not determine the reliability of the 

underlying subtotals by funding source.
Page 13 GAO-14-697 CCIIO Financial Management Information 

HIGLAS does not produce totals of CCIIO-related expenditures for 

advertising and other public relations activities, polling and focus groups, 

and conferences because CMS has not assigned these activities 

identifying transaction codes that identify the nature of the activity and the 

related CMS office so that they can be separately identified and tracked in 

HIGLAS. Consequently, HIGLAS cannot distinguish them from other 

transactions or produce related totals. Also, because there are no codes 

identifying these types of transactions, CMS staff could not identify them 

in HIGLAS as being CCIIO-related transactions and extract them as they 

had with the CCIIO-related portions of total obligations, total 

expenditures, salaries, and travel expenditures. Instead, CMS staff 

identified these expenditures by manually reviewing individual underlying 

contracts. Because HIGLAS does not produce totals for these CCIIOrelated expenditures to which we could compare CMS-provided amounts 

for purposes of determining their completeness, we could not determine 

their reliability, as detailed in table 4.

Reliability Could Not Be 

Determined for Expenditures 

for Advertising and Other 

Public Relations Activities, 

Polling and Focus Groups, and 

Conferences
Page 14 GAO-14-697 CCIIO Financial Management Information 

Table 4: Reliability Could Not Be Determined for Center for Consumer Information and Insurance Oversight (CCIIO) Related 

Expenditures for Advertising and Other Public Relations Activities, Polling and Focus Groups, and Conferences, March 2010 

through Fiscal Year 2013

Dollars in thousands

Funding source Advertising and 

other public 

relations activities

Expenditures

Polling and 

focus groups

Expenditures

Conferences

Expenditures

Amounts funded by appropriation accounts that fund only CCIIO-related activities

Consumer Assistance Program Grants $0 $0 $0

Grants to states for premium review 0 0 0

Pre-Existing Condition Insurance Plan Program 309 0 0

Early Retiree Reinsurance Program 0 0 0

Affordable Insurance Exchanges Grants to States 0 0 166

Consumer Operated and Oriented Plan program account 0 0 164

Exchange user fees 0 0 0

Subtotal $309 $0 $330

Amounts funded by appropriation accounts that fund CCIIO-related and non-CCIIO related activities

Health Insurance Reform Implementation Fund $0 $2,432 $368

Department of Health and Human Services general departmental management 0 0 0

Program Management 22,291 1,707 3,635

Secretary’s transfer authority 0 0 0

Nonrecurring Expenses Fund 0 0 0

Prevention and Public Health Fund 255 0 0

Subtotal $22,546 $4,139 $4,003

Grand total for all funding sources $22,855 $4,139 $4,333

Source: GAO analysis of Centers for Medicare and Medicaid Services data. | GAO-14-697

The information CMS provided regarding reassignment of staff to CCIIO 

from other CMS or other HHS offices was not complete and was based 

on personal recollection unsupported by documentary evidence, as 

previously discussed. Consequently, we could not determine if it was 

reliable. CMS officials indicated that this information was not readily 

available and obtaining it would have required labor-intensive and timeconsuming review of each staff member’s individual personnel file. Of the 

347 full-time CCIIO staff as of September 30, 2013, CMS provided 

information based on personal recollection that indicated that 92 staff had 

been reassigned from other CMS or HHS offices, including 5 who had 

been reassigned from the Medicare or Medicaid programs. CMS also 

informed us that 24 staff were assigned to CCIIO on temporary detail 

Reliability Could Not Be 

Determined for Reassignment 

of Staff Information
Page 15 GAO-14-697 CCIIO Financial Management Information 

from other CMS or HHS offices as of September 30, 2013. According to 

CMS officials, 4 of these staff were detailed from the Medicare program, 

and 8 were detailed from offices that support the Medicare and Medicaid 

programs. However, we could not determine if these data were reliable. 

CMS did not provide any information regarding the previous assignments

of the 255 other full-time CCIIO staff as of September 30, 2013.

CMS officials informed us that although they have established policies 

and procedures governing CMS’s standard financial operations, they do 

not have established policies and procedures for responding to 

nonroutine information requests, such as those that might originate from 

Congress or other oversight bodies. Instead, CMS used ad hoc, largely 

manual procedures that consisted of either extracting CCIIO-related 

transactions from HIGLAS using transaction codes to identify them as 

CCIIO related or, for certain categories of expenditures that did not have 

such codes, manually reviewing underlying individual contracts. CMS 

used similar manual transaction identification and extraction procedures 

to produce its quarterly Status of Funds Report, which reflects CCIIOrelated obligations and expenditure information that CMS management 

routinely uses to help support CCIIO-related budgetary and spending 

decisions. CMS officials informed us that HIGLAS possesses a “query”

feature enabling users to produce custom reports to meet information 

needs not covered by existing standard reports. However, they also 

indicated that in part because of competing demands and resource 

constraints, they had been unable to develop and employ this 

functionality.

The largely manual, ad hoc process CMS employed was labor intensive 

and time consuming, and it often required an extended period of time to 

respond to our requests, in some cases several months. For example:

• In March 2013, we requested information regarding expenditures 

related to polling and focus groups, advertising and other public 

relations, and conferences. CMS did not provide us this information 

until about a year later, in March 2014.

• In March 2013, we requested a listing of CCIIO employees who had 

been reassigned to CCIIO from other HHS or CMS offices when 

CCIIO was created in 2011 and the offices from which they had been 

reassigned. However, CMS did not provide this information until about 

4 months later, in July 2013. As discussed above, this information was 

not complete.

CMS Did Not Have 

Adequate Policies and 

Procedures for Identifying 

CCIIO-Related Financial 

Management Information
Page 16 GAO-14-697 CCIIO Financial Management Information 

Statement of Federal Financial Accounting Concepts No. 1, Objectives of 

Federal Financial Reporting,

21 recognizes that if financial reports are to be 

useful, they must be issued soon enough to affect decisions, and that the 

passage of time usually diminishes the usefulness that the information 

otherwise would have had. Statement of Federal Financial Accounting 

Standards No. 4, Managerial Cost Accounting Standards and Concepts,

22

observes that cost information that is timely as well as reliable helps 

government managers ensure that resources are spent to achieve 

expected results and outputs and alerts them to waste and inefficiency. 

This concept also applies to other forms of financial management 

information. Standards for Internal Control in the Federal Government 

also recognizes that information should be recorded and communicated 

to management and others in a form and within a time frame that enables 

them to carry out their internal control and other responsibilities.23

We also found that CMS also did not have policies and procedures that 

required documented review and approval of the information provided in 

response to nonroutine requests to help ensure the reliability of financial 

management information. Although CMS officials informed us that the 

CCIIO-related financial management information we were provided was 

subject to multiple levels of review and approval before we received it, 

including review by subject matter experts, its review and approval of the 

CCIIO-related information provided to us were not documented. 

Consequently, we were unable to independently verify that these reviews 

and approvals had taken place. Our concern also applies to CMS’s Status 

of Funds Report, which is a standard quarterly report that CMS uses to 

assist in making budgetary and spending decisions. According to CMS, 

this report was also prepared using a similar largely manual process, and 

review and approval of this report were also not documented. Such 

reviews and approvals are important internal control activities that can 

help provide reasonable assurance that information is reliable.

Standards for Internal Control in the Federal Government requires that 

internal control be clearly documented and that the documentation be 

 21Federal Accounting Standards Advisory Board, Statement of Federal Financial 

Accounting Concepts No. 1, Objectives of Federal Financial Reporting.

22Federal Accounting Standards Advisory Board, Statement of Federal Financial 

Accounting Standards No. 4, Managerial Cost Accounting Standards and Concepts.

23GAO/AIMD-00-21.3.1.
Page 17 GAO-14-697 CCIIO Financial Management Information 

readily available for examination.24

In order to make informed decisions regarding matters affecting the 

financial aspects of operations and the performance of programs, it is 

critical that decision makers have available timely and reliable 

information. This is particularly true as it relates to programs that have 

been subject to the significant degree of public and congressional scrutiny 

that has characterized the implementation of PPACA, including the 

CCIIO-related private health insurance and health insurance exchange

provisions. However, CMS does not have documented policies and 

procedures governing responses to nonroutine information requests, such 

as those that may originate from oversight bodies. CMS’s reliance on 

manual procedures and personal recollection resulted in an inefficient and 

time-consuming process to provide the requested information. In addition, 

because of the manner in which CMS accounts for and retains CCIIOrelated financial management information, we could not determine the 

reliability of most of it. Also, because its process for obtaining the 

information and its review and approval of the information provided were 

not documented, there is no assurance that such procedures have been 

properly performed. Collectively, these issues increase the risk that 

significant errors may not be prevented or detected and corrected before 

information is provided in response to requests from Congress and other 

decision makers. Consequently, such users of these data may not have 

timely and reliable CCIIIO-related financial management information, 

which could hamper their efforts to make informed resource allocation 

decisions and assessments of program performance.

Not documenting the review and 

approval of financial management information increases the risk that 

these procedures may not be performed effectively and that as a result 

significant errors may not be prevented or be detected and corrected in a 

timely manner, adversely affecting the reliability of the information 

provided to key stakeholders.

We recommend that the Secretary of Health and Human Services direct 

the Administrator of the Centers for Medicare and Medicaid Services to 

take the following actions:

 24GAO/AIMD-00-21.3.1.

Conclusions

Recommendations for 

Executive Action
Page 18 GAO-14-697 CCIIO Financial Management Information 

• identify and evaluate options to facilitate more timely and 

independently verifiable reporting of CCIIO-related financial 

management information, such as enhancing HIGLAS’s standard 

reporting or custom reporting capabilities, and

• develop and implement policies and procedures for responding to 

nonroutine CCIIO-related financial management information requests, 

including procedures for documenting the preparation process and the 

review and approval of the results.

We provided a draft of this report to HHS for comment. In its written 

comments, reprinted in appendix II, HHS did not concur with our two 

recommendations. HHS also provided technical comments, which we 

incorporated as appropriate.

HHS did not concur with our recommendation that it identify and evaluate 

options to facilitate more timely and independently verifiable reporting of 

CCIIO-related financial management information, such as enhancing 

HIGLAS’s standard reporting or custom reporting capabilities. HHS 

indicated that in response to our requests, it gave us supporting data to 

permit validation and verification of the information it provided, including 

numerous summary tables and detailed transaction-level reports from 

HIGLAS. We disagree with HHS’s response. As discussed in our report, 

CMS was able to provide us with CCIIO-related obligation and 

expenditure amounts from appropriation accounts that exclusively funded 

CCIIO-related activities. For these accounts, we were able to assess 

completeness by comparing the amounts provided to summary totals in 

HIGLAS. However, for appropriation accounts that funded both CCIIOrelated and non-CCIIO-related activities, CMS utilized a time-consuming 

manual process to extract the obligation and expenditure activity from 

HIGLAS, and the accounting code structure did not allow CMS to provide 

related HIGLAS summary totals. Without the ability to compare the 

information provided by CMS for all accounts with CCIIO-related activity 

to summary totals in HIGLAS, we were unable to determine that the total 

amounts of CCIIO-related obligations and expenditures CMS provided 

were complete, which is a major factor in determining reliability.

HHS also indicated that we could have determined the reliability of 

CCIIO-related obligations and expenditures by using the same 

procedures we used to determine that CMS's estimates of CCIIO-related 

total obligations for expenditures for fiscal year 2014 were reliable. 

However, we were able to verify the reliability of obligation estimates for 

Agency Comments 

and Our Evaluation
Page 19 GAO-14-697 CCIIO Financial Management Information 

fiscal year 2014 using budget data because estimates of future activity 

are not supported by past (actual) transaction activity. Therefore, our 

ability to verify these estimates was not affected by the lack of associated 

HIGLAS totals which affected our ability to verify the reliability of actual 

obligation and expenditure data for fiscal years 2010 through 2013. As 

discussed in our report, Statement of Federal Financial Accounting 

Standards No. 4, Managerial Cost Accounting Standards and Concepts, 

and Statement of Federal Financial Accounting Concepts No.1, 

Objectives of Federal Financial Reporting, highlight the importance of 

providing reliable and timely information to key stakeholders, including 

Congress, to support informed resource allocation decisions and 

assessments of program performance, and the need for such information 

to be verifiable. As discussed in our report, CMS sometimes took months 

to provide the information we requested and did not always provide 

CCIIO-related information whose reliability could be independently 

determined, thereby limiting the type and usefulness of information 

available to Congress and other decision makers for making informed 

decisions. HHS concluded its response with a statement that it will 

continue to evaluate options for enhancing HIGLAS’s “standard reporting 

and/or custom reporting capabilities.” We continue to believe that 

identifying and considering such options will help facilitate the timely 

response to stakeholder requests for reliable information on HHS 

programs, particularly for programs subject to a significant degree of 

public and congressional scrutiny. 

HHS also did not agree with our recommendation that it develop and 

implement policies and procedures for responding to nonroutine CCIIOrelated financial management information requests, including procedures 

for documenting the preparation process and the review and approval of 

the results. In its response, HHS stated that it has up-to-date and clearly 

documented standard operating procedures (SOP) for its normal day-today work processes and employs ad hoc teams and processes to 

address data requests for information that differs from HIGLAS standard 

reports. HHS also stated that the varying nature of data requests for 

nonroutine reports does not easily lend itself to utilizing one documented 

SOP. We agree that it would be difficult to develop an individual SOP for 

each specific CCIIO-related data request, but we continue to believe that 

regardless of the specifics of each request, common processes and 

controls that are necessary should be documented and required in written 

policies and procedures. For example, as discussed in the report, CMS 

did not have a policy or procedures that required documented review and 

approval of the information provided in response to nonroutine requests. 

Such documented review and approval would help ensure the reliability of 
Page 20 GAO-14-697 CCIIO Financial Management Information 

the information CMS provided, regardless of the specific data request. 

Although HHS stated that subject matter experts were involved in all 

steps of identifying a methodology, extracting data from multiple systems, 

and manually producing reports in order to meet the requests for 

customized displays of information and that it conducted multiple levels of 

review prior to providing the information, none of these steps or reviews 

were documented, as noted in our report. As a result, we were not able to 

independently verify that these steps and reviews actually took place. 

Similarly, absent documented review and approval, management lacks 

assurance that these important controls are in place, increasing the risk 

that errors may not be prevented or detected and corrected in a timely 

manner.

We are sending copies of this report to appropriate congressional 

committees, the Secretary of Health and Human Services, the 

Administrator of the Centers for Medicare and Medicaid Services, the 

Director of the Office of Management and Budget, and other interested 

parties. In addition, the report is available at no charge on the GAO 

website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-2623 or davisbh@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix III.

Beryl H. Davis

Director

Financial Management and Assurance
Appendix I: Objective, Scope, and 

Methodology

Page 21 GAO-14-697 CCIIO Financial Management Information 

Our objective was to identify the resources related to the Center for 

Consumer Information and Insurance Oversight (CCIIO) that the Centers 

for Medicare and Medicaid Services (CMS) received, used, and expects 

to use from enactment of the Patient Protection and Affordable Care Act 

(PPACA) though fiscal year 2014, including certain categories of 

expenditures; the source of the funding; the number of CCIIO staff as of 

September 30, 2013; and the number of staff reassigned from other units. 

The scope of our review encompassed the financial and staff resources 

provided to and used by CMS to help implement the private health 

insurance and health insurance exchange provisions of PPACA from 

enactment in March 2010 through fiscal year 2013 and the amounts CMS 

estimates it will use for fiscal year 2014.

To achieve our audit objective, we contacted responsible officials at CMS 

to request the (1) data concerning total CCIIO-related obligations and 

expenditures1 from the enactment of PPACA in March 2010 through fiscal 

year 2013, including amounts related to salaries, travel, advertising and 

other public relations activities, polling and focus groups, and 

conferences; (2) CMS’s estimates of obligations in total and in each of 

these categories for fiscal year 2014; and (3) the number of full- and parttime CCIIO staff as of September 30, 2013, including the number 

reassigned from other CMS and Department of Health and Human 

Services (HHS) units. We also requested available supporting 

documentation for the information requested to assist in determining its 

reliability. We reviewed policies and procedures—including internal 

controls in place to ensure the reliability of the information CMS 

provided—in order to assess the information’s applicability to our audit 

objectives and its conformance with internal control standards.2 In order 

to determine whether the information CMS provided was reliable,3

 1

Obligations are legal liabilities of an agency to pay for goods and services ordered or 

received. An agency incurs an obligation, for example, when it places an order, signs a 

contract, awards a grant, purchases a service, or takes other actions that require the 

government to make payments to the public or from one government account to another. 

Expenditures are the actual spending of money through the issuance of checks, 

disbursement of cash, or electronic transfer of funds made to liquidate an obligation.

we 

2

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

3

For financial information to be considered reliable, it must be determined to be 

(1) complete (includes all applicable information), (2) accurate (free of material error or 

fraud), and (3) valid (includes only financial information that accurately represents the 

substance of the nature of the underlying financial activity). 

Appendix I: Objective, Scope, and 

Methodology
Appendix I: Objective, Scope, and 

Methodology

Page 22 GAO-14-697 CCIIO Financial Management Information 

analyzed the information we received, conducted extensive follow-up 

inquiries with agency officials to ensure that we had received what we 

requested, and compared the information to available supporting 

documentation. Specifically, we

• compared the detailed financial information CMS extracted from the 

Healthcare Integrated General Ledger Accounting System (HIGLAS) 

to its related totals, where available, to determine whether all 

appropriate information had been extracted and the amounts provided 

by CMS were complete and

• estimated the amount of salaries based on detailed information on 

individual grade levels and pay rates that CMS obtained from its 

payroll system and compared the amount to the total salaries CMS 

obtained from HIGLAS to determine whether the total number of 

employees and related staff salary data were reliable as of 

September 30, 2013.

To determine the reasonableness of CCIIO’s estimated funding and 

spending amounts for fiscal year 2014, we compared CMS’s estimates to 

the President’s budget, with the exception of changes made subsequent 

to preparation of the President’s budget.4

As described in our report, we could not determine the reliability of most 

of the data provided to us. We also met with officials from the Office of 

Inspector General of HHS and CMS’s independent financial statement 

auditor to determine whether they were aware of any internal control or 

substantive issues pertinent to CCIIO-related activities that could affect 

our ability to rely upon the financial management information CMS 

provided.

For such changes to the 

estimates, we obtained an understanding of the basis upon which the 

changes were developed to determine if they were reasonable. 

 4

Office of Management and Budget, Fiscal Year 2014 Budget of the U.S. Government

(Washington, D.C.: Apr. 10, 2013).
Appendix II: Comments from the Department 

of Health and Human Services

Page 23 GAO-14-697 CCIIO Financial Management Information 

Appendix II: Comments from the Department 

of Health and Human Services
Appendix II: Comments from the Department 

of Health and Human Services

Page 24 GAO-14-697 CCIIO Financial Management Information 
Appendix II: Comments from the Department 

of Health and Human Services

Page 25 GAO-14-697 CCIIO Financial Management Information 
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 26 GAO-14-697 CCIIO Financial Management Information 

Beryl H. Davis, (202) 512-2623 or davisbh@gao.gov

In addition to the contact named above, Charles Fox (Assistant Director), 

William Brown, Joshua Edelman, Wilfred Holloway, Robert Mabasa, 

Phillip McIntyre, and John Warner made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(197234)
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